PRIVACY

About This Policy

Policy Statement

North Central University collects personal information sent to the university, or information the university is permitted to obtain from third parties, for purposes relevant to university operations in pursuit of its academic mission. Examples include information needed for student admission (including financial aid information), employment, bookstore ordering, gifts/fundraising, institutional research, and topical surveys.

The university may use user information in order to process student, financial aid, or job applications, student or employee registrations, and other services and benefits that we provide to our students, employees and other persons. Any email address, postal mailing address, phone number or other contact information you provide may be used to send information, respond to inquiries, and/or other requests or questions. The university also collects information from you when you access the university’s website(s) and when you subscribe to our email services.

The university will not sell or rent personal information to any outside entity. However, we may share your data internally between university departments. Data stored by the university is not shared with outside agencies except as otherwise described in this policy.

Information We Collect and How We Use Your Personal Information

Prospective Students and Applicants
The university collects and uses personal information about applicants and other prospective students (referred to collectively as “applicants”). If you are or have been an applicant, we may collect and use the following types of personal information about you:

• Information and supporting documentation that you provide in your application, including through third parties.
• Related application materials (e.g., transcripts, recommendations, references, and test scores).
• Information that you have permitted a third party such as The College Board or ACT to release to the university (e.g., test scores, demographic information, academic information).
• Contact information that we receive from you, from other institutions, or from vendors who conduct advertising activities for us
• Financial information (e.g., information collected in connection with your applications for financial aid, loans, or scholarships).
• Survey responses, if you choose to respond to a survey sent by us or on our behalf.

The university will use your personal information primarily for our legitimate interests in evaluating your application, and for related activities, like evaluating requests for financial aid, communicating with you about your application or potential application, and for other administrative functions related to our admissions and enrollment process.

To the extent applicable, we may also use or disclose your personal information for the following purposes, based on our legitimate interests:

• For compliance with legal obligations.
• To consider requests for accommodations.
• For research and statistical purposes.
• To provide you with information about the university, including events that you might be interested in attending.
• To send you surveys for research purposes.

We may share your information with the following individuals and entities, as applicable and to the extent permitted by law:

• Individuals who assist us in the application process, such as faculty and outside consultants.
• Governmental bodies as necessary for compliance with law.
• Other departments within the university, including Institutional Research.
• Your financial institutions and funders (e.g., as necessary for obtaining loans, scholarships, or other funding).
• Other educational institutions (e.g., in order to send you information about jointly hosted informational events).
• Vendors who provide services to the university.

Students, Faculty, and Staff
When you are a student at the university, or a member or prospective member of the faculty and staff, we maintain records containing your personal information. We may collect and use the following types of personal information about you, as applicable:

• Your contact information and biographical data (e.g., name, address, date of birth, race, ethnicity).
• Application materials and supporting documents (e.g., applications for admission or employment).
• Copies of identification documents and other official documents (e.g. driver’s license, I-9 form, passport/visa information).
• Employment and/or educational records (e.g., job history, job reviews, transcript information).
• Academic record, work product, and related information (e.g., research and course-related content).
• Internal research and survey data (e.g. course evaluations).
• Records about your other activities (e.g., for students, involvement in clubs, disciplinary actions and similar incidents).
• Financial information (e.g., payroll information, information related to tuition payments).
• Certain health information (e.g., disclosed disabilities, allergies).
• Information about technology usage (e.g., IP addresses, software licensing).
• Motor vehicle records, in connection with an application to drive university vehicles.

To the fullest extent possible, the university complies with FERPA regulations, and all student records are subject the university Managing Student Records policy. To the extent applicable, we use this information for the following purposes necessary for your student or employment relationship with the university, as well as for our other legitimate interests:

• For general communications about the university.
• To provide educational, employment, and/or related services (e.g., maintaining relevant records of your studies or employment, providing you with access to facilities and support services, such as counseling and IT services).
• To administer financial aspects of the relationship (e.g., payroll, collecting tuition, coordinating with lenders or other funders).
• To enable your participation in events and other opportunities (e.g., graduation, study abroad programs, internships).
• To protect your safety and health and that of other students, faculty, staff, and visitors, and to protect the educational integrity of the school (e.g., security operations, disciplinary actions, assistance in the event of an emergency).
• To accommodate special needs (e.g., disability accommodations).
• For research and statistical purposes related to our educational work and/or related services.
• To fulfill our responsibilities under applicable law (e.g., employer obligations, immigration, Title IX).
• To provide basic contact information in student, faculty, and/or staff directories.

As applicable and to the extent permitted by law, we may share your personal information with the following:

• Faculty and staff at the university, in order to enable them to fulfill their responsibilities.
• Your lenders, funders, and/or other sponsors.
• With your approval to providers of external programs, such as study abroad programs, internships, and other collaborations.
• Host institutions and host families, in conjunction with your participation in study abroad or faculty or student exchange programs.
• Student clubs and related organizations.
• Governmental bodies, including as necessary for compliance with law and law enforcement authorities.
• Private organizations with oversight over the university, such as accreditation agencies.
• Vendors who provide services to the university.
• Individuals or entities inquiring about your attendance or employment history.

Alumni and Other Supporters
The university holds personal information related to its alumni and other supporters (such as donors, prospective donors, volunteers, and family members of students). If you are one of our alumni or otherwise a friend or supporter of the university, we may collect and use the following types of personal information about you:

• Academic information (e.g., major, transcript, degree).
• Biographical information (e.g., name, date of birth, gender, ethnicity).
• Contact information (e.g., email address, phone number).
• Your activities at the university (e.g., club memberships).
• Your involvement with the university and other interests (e.g., attendance at events, philanthropic interests).
• Family information (e.g., marital status, name of spouse).
• Health information (e.g., disability, food allergies).
• Financial information (e.g., history of donations, wealth information).
• Employment information.
• Survey and interest information.

The university collects and uses data about alumni and other supporters where it is necessary for our legitimate interests. We may obtain the data from various sources, including information obtained directly from you (for example, when you fill out a form on our website), as described below. We also retain and may use information from your student records if you studied here. We also collect information from public sources, such as social media, and from third parties, including companies that conduct wealth screenings. Your personal information is used to provide you with certain alumni services, and for our legitimate interests in maintaining alumni relationships and conducting fundraising activities, including:

• Sending you informational publications (e.g., NCU Magazine, newsletters from departments and clubs you may have an interest in) or other university communications.
• Conducting surveys, so that we can learn more about our alumni and other supporters.
• Providing services (e.g., networking opportunities and ongoing career services).
• Sending you information about fundraising campaigns, events, mentoring and volunteer opportunities that may be of interest to you.
• Conducting wealth analysis and research to understand your philanthropic interests and ability to give, in order to ensure that our fundraising efforts are tailored to your interests.
• For administrative purposes (e.g., processing donations and issuing tax receipts, or managing events, such as reunions).
• For research and statistical purposes.
• To publicly acknowledge gifts (with the consent of the donor).
• To meet legal obligations.

As applicable and to the extent permitted by law, we may share your personal information with the following:

• University departments, clubs, and interest groups.
• Other university alumni (limited contact information only).
• University alumni associations or societies, specific alumni clubs and organizations and similar affiliates.
• Other individuals or entities with a legitimate interest in your personal information, such as scholarship supporters.
• Third parties engaged by the university to assist with the activities listed here.

For All Categories of People
For all categories of people, the university may use or disclose your personal information to the extent necessary to protect the rights of the university. This includes situations in which the university has a good-faith belief that disclosure is necessary in order to protect, enforce or defend the legal rights, privacy, safety, security or property of the university, its employees, students, or members of the public; to protect against fraud; or for other risk management purposes.

Website Visitors
When you visit the northcentral.edu domains, site activity information may be gathered with the use of cookies or pixels.

• Your Internet location (IP address).
• Which pages you visit on our site.
• From which page you came to our site (referring site).
• Date and time.
• Which software you use to visit our site and its configuration.

Cookies are small files that are stored on your computer unless you block them. We use cookies to save your preferences for future visits and compile aggregate data about site traffic and interactions. We may contract with third-party service providers to assist us in better understanding our site visitors and to improve site functionality. You may disable cookies through your individual browser options.

Tracking pixels, like cookies, can be written into websites and other digital marketing materials. Pixels are used to provide analytics and insight into web traffic, digital preferences and activity. Data curated from the pixel is managed directly by the third-party platform responsible for providing the pixel (Facebook, Google, Twitter etc.). You can manage what these platforms can collect about your online activity by managing your personal privacy and advertising settings within those platforms.

Beyond the northcentral.edu main web site, university servers automatically collect and log information when you use the university’s other web sites or computer systems. Log data may include your Internet Protocol (IP) address, date and time the website or systems were used, and technical information about your devices and preferences. Log data may be used to facilitate your access to university websites and services, monitor system performance, troubleshoot problems, and facilitate the university’s response in the event of prohibited uses of computing resources, or unauthorized access to sensitive data.

The university web site contains links to many outside sites that are beyond our control. the university is not responsible for the privacy practices or content of those other sites. This is true even if you use your university-related username to log into an outside site, or if you are connecting to a university-related account on such a platform (for example, the university’s official Facebook page). In these cases, use of your data is governed by the provider’s privacy policies, not by the university. Public information in posts (e.g., name, user name, comments, status updates, profile info, picture) are always public.

Location of Servers and Transfer Information to the United States
The data stored by the university are stored on campus servers in the United States or in cloud-hosted services which are largely outside the European Union. If you are located outside the United States, please note that your personal data will be transferred to and stored on a server most likely located in the United States. By submitting your personal data to the university, you consent to this transfer and to the collection, storage, processing and use of your personal data in the United States.

Retention of Data
The university retains personal information about students and alumni indefinitely for the purpose of alumni relationships, academic record-keeping, and archiving purposes. Other personal information will be retained in accordance with applicable the university data retention policies.

Communications from the University
The university periodically sends marketing communications to alumni, supporters, and other members of the university community, such as newsletters, event invitations, and fundraising information. The university provides opt-outs for such communications, as required. If you ask to be removed from our mailing lists, we will retain your contact information to ensure that we continue to honor your request in the future.

Rights for Individuals in the European Economic Area
You have the right in certain circumstances to:

• Access your personal information
• To correct or erase information
• Restrict processing
• Object to communications, direct marketing, or profiling.

To the extent applicable, the EU’s General Data Protection Regulation provides further information about your rights. You also have the right to lodge complaints with your national or regional data protection authority.

If you are inclined to exercise these rights, we request an opportunity to discuss with you any concerns you may have. To protect the personal information we hold, we may also request further information to verify your identity when exercising these rights. Upon a request to erase information, we will maintain a core set of personal data to ensure we do not contact you inadvertently in the future, as well as any information necessary for archival purposes. We may also need to retain some information for legal purposes, including to comply with US government laws and regulations (e.g., US IRS compliance). In the event of an actual or threatened legal claim, we may retain your information for purposes of establishing, defending against or exercising our rights with respect to such claim.

If you provide information directly to the university from the European Economic Area (EEA), you consent to the transfer of your personal information outside of the EEA to the United States. You understand that the current laws and regulations of the United States may not provide the same level of protection as the data and privacy laws and regulations of the EEA.

You are under no statutory or contractual obligation to provide any personal data to us (other than personal data provided in connection with your status as a university student or employee, if applicable).

COPPA Compliance
The university complies with the Children’s Online Privacy Protection Act of 2013 (COPPA). COPPA imposes certain requirements on operators of websites or online services directed to children under 13 years of age, and on operators of other websites or online services that have actual knowledge that they are collecting personal information online from a child under 13 years of age. It is our policy to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 13. If you are under the age of 13, please do not supply any personally identifiable information through the site. If you are under the age of 13 and have already provided personally identifiable information through the site, please have your parent or guardian contact us immediately using the information below so that we can remove such information from our files.

How We Protect Your Data
The university employs a variety of technical and procedural measures to protect your information from misuse and unauthorized access. These measures include practices that limit access to your information to the fewest number of individuals who need that information for operational and strategic purposes. The university implements a number of technology strategies such as firewalls, vulnerability management, log monitoring, data encryption, and other technical measures to safeguard your data from unauthorized access.

Reason For Policy

The university has established this privacy policy to demonstrate our firm commitment to privacy and the safe-handling of data and information.

Policy Scope

This policy applies to anyone who provides or has previously provided personal information to university, who authorizes university to obtain data from third parties, or who accesses university websites. 

The university privacy policy does not apply to non-personal information that does not identify you as a specific person, for example, interests and anonymized data. This policy does not apply to publicly available information (for example, about your online activity or from commercially available sources) that we do not possess or control. 

This Privacy policy is designed to assist you in understanding how we collect, use, and share personal information you provide to the university.

Procedures

• There are no procedures associated with this policy.

Forms

• There are no forms associated with this policy.

Appendices

• There are no appendices associated with this policy.

Additional Contacts

Definitions

Confidentiality
Ensuring that information is not disclosed to unauthorized individuals. 

CookiesSmall files that are placed on your computer, mobile device or any other device by a website, containing
the details of your browsing history on that website among its many uses. 

Electronic Records
Electronic transmissions or messages created, sent, forwarded, replied to, transmitted, distributed, broadcast, stored, held, copied, downloaded, displayed, viewed, read, or printed by one or several electronic systems or services. This definition of electronic records applies equally to the contents of such records, attachments to such records, and transactional information associated with such records. 

Personally Identifiable Information (PII)
Information maintained by the University that can be used to distinguish or trace an individual’s identity that specifically includes Social Security Numbers (SSNs), credit card numbers, bank account numbers, Driver’s License numbers, state ID numbers, passport numbers, biometric data (including fingerprints, retina/facial images, and DNA profile), or protected health information. These data elements are defined by the University as personally identifiable information.

University Record
By law, University records are any papers, books, photographs, tapes, films, recordings, or other documentary materials, or any copies thereof, regardless of physical form or characteristics, made, produced, executed, or received by any department or office of the university or by any academic or administrative staff member in connection with the transaction of university business, and retained by that agency or its successor as evidence of its activities or functions because of the information contained therein.

University Electronic Record
A University Record in the form of an electronic record, whether or not any of the electronic communications resources utilized to create, send, forward, reply to, transmit, store, hold, copy, download, display, view, read, or print the electronic communications record are owned by the University. This implies that the location of the record, or the location of its creation or use, does not change its nature as a university electronic record for purposes of this or other university policy.

Until determined otherwise or unless it is clear from the context, any electronic record residing on university-owned or controlled telecommunications, video, audio, and computing facilities will be deemed to be a university electronic record for purposes of this policy.

Responsibilities

All Users

• Read and understand this policy.

University Departments

• Read and understand this policy.
• Comply with all statements in this policy.

RELATED INFORMATION

Related Policies & Procedures

• Information Security
• Acceptable Usage of Information Technology
• Managing Student Records

Related Legislation

• GFLBA – Gramm-Leach-Bliley Act which protects consumer financial information
• HIPAA – Health Insurance Portability and Accountability Act which protects personal health information
• GDPR – General Data Protection Regulation which requires business to protect personal data (as defined under GDPR) and privacy of EU and EEA (European Economic Area) citizens who are Customers
• FERPA – Family Educational Rights and Privacy Act which protects personally identifiable student records

History

Issued
2022-07-20