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Effective Date: August 1, 2020
PLEASE READ THE PRIVACY NOTICE CAREFULLY. IT IS YOUR CHOICE WHETHER OR NOT TO PROVIDE PERSONAL INFORMATION TO US. IF YOU CHOOSE TO DO SO, YOU ARE GIVING US YOUR EXPRESS CONSENT TO USE, PROCESS, AND DISCLOSE YOUR PERSONAL INFORMATION AS SET FORTH IN THE PRIVACY NOTICE. IF YOU CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION TO US, YOU WILL NOT BE ABLE TO USE OUR SERVICES.
1. Introduction
Washington State University is committed to safeguarding the privacy of data provided by individuals who use our services, online or offline. This Privacy Notice outlines the collection, use, and disclosure of information provided to Washington State University for the purpose of recruitment, admission, and initial enrollment.
2. Scope of This Privacy Notice
For purposes of this Privacy Notice, “Personal Information” refers to information concerning an identifiable natural person that is provided to the University. Identifiable means that a natural person can be identified by a specific factor such as a name, identification number, location data, or other specific information related to genetic, cultural, or social identity. Personal Information does not include aggregate information that can no longer be attributed to a natural person. Personal Information is required for the University to provide services to you. If you are not willing to provide required Personal Information, you will not be able to use our services.
For purposes of this Privacy Notice, “Sensitive Information” includes but is not limited to ethnic origin, religious or philosophical beliefs, sexual orientation, trade union membership, criminal convictions, educational records, and medical information and records. The Sensitive Information you provide to the University is voluntary. If you have voluntarily provided information concerning your race, religion or philosophical beliefs, or sexual orientation through the recruitment, admission, or initial enrollment process, it may be shared with other administrative offices to identify activities of interest, to administer University polices, and to provide support services. Information concerning a criminal conviction may be collected and shared with federal and international authorities to comply with applicable laws and University policies.
From time to time, you may receive email or other material with links to other websites. We encourage you to review the privacy statements of other websites to understand their information and privacy practices before providing personal information, either directly or indirectly through our forms.
Washington State University collects and processes your Personal Information to manage you as a person throughout the recruitment, admission, and initial enrollment. If you are offered admission and enroll, your information will be used to manage you as a student, e.g., student accounts, provide academic advising, develop and deliver education programs, track academic progress, provide medical services, and enforce University policies. Your information and sensitive information may also be used to analyze and improve education programs, and may be de-identified for regulatory reporting, auditing, accreditation purposes, general demographic and statistical research to improve University programs, and other related University processes and functions. We will share your information with other University divisions and departments as necessary to administer and manage academic progress, and to enforce University policies. Finally, we share your information and sensitive information with third parties that have entered into contracts with the University to perform these functions on behalf of the University, which include an obligation to keep them confidential.
3. Information We Collect
We collect information to operate effectively and provide you with the best experiences with our services. You provide some of this information directly, such as when you create an account, start or submit a form hosted by us, or contact us for support. We get some of the information, such as your IP address, by recording how you interact with our services. We may also get information about you from our client institutions or other third parties.
Information That You Provide To Us
We ask for and store information about you such as your name, address, phone number, and email address when you register for an account to access or our services.
We ask for, collect, and store information from you when you start or submit forms (such as the admission application) on our site, or as you use interactive features of our sites, including participation in surveys, discussions, contests, requesting customer support, or otherwise communicating with us. This information may include non-text components such as images and videos.
A third party intermediary is used to manage electronic payment processing. This intermediary is not permitted to store, retain, or use your cardholder data for any purpose except for electronic payment processing on our behalf.
By voluntarily providing us with your information, you represent that the data is accurate and that you are the owner of such data or otherwise have the requisite consent to provide it to us.
Information That We Collect From You On Our Websites
Logs:
As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and services. In such cases, we treat the combined information in accordance with this Privacy Notice.
Analytics:
We collect analytics information when you use our Websites or our mobile applications to help us improve them. We may also share anonymous data about your actions on our Websites and our mobile applications with third party service providers of analytics services. We do not link analytics information to your personal information.
Information Collected From Other Sources
We may also obtain other information, including personal information, from third parties and combine that with information we collect through our sites. For example, we may receive information from other universities you have attended and test scores that you want associated with your application. In addition, we may have access to certain information from a third party social media or authentication service if you log into our services through such a service or otherwise provide us with access to information from the service. Your information and interactions with these features are governed by the privacy statement of the companies that provide them.
Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Notice. You should check your privacy settings on these third party services to understand the information sent to us through these services.
4. How We Use Your Information
We use the information we collect for a variety of purposes within the scope of recruitment, admission, and initial enrollment.
General Uses
We may use the information we collect about you for a variety of purposes, including the following:
• To provide, operate, maintain, develop, and improve student enrollment services.
• To complete recruitment, admission, and initial enrollment processes and send you related information.
• To send messages, including responses to your comments, questions, and requests.
• To provide customer service and support; and send you technical notices, updates, security alerts, and administrative messages.
• To monitor and analyze trends, usage, and activities in connection with our sites and service.
• To investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities.
• To personalize our sites and services to match your interests and preferences.
• For other purposes for which we obtain your consent. You can revoke your consent to receive marketing communications from us by following the unsubscribe instructions included in our communications.
How Long We Retain Your Information
Your information will be retained by the University in accordance with applicable federal laws, and the applicable retention periods in Washington State University’s policies. Your information will be destroyed upon your request if prior to the expiration of the applicable retention period. The manner of destruction shall be appropriate to preserve and ensure the confidentiality of your information given the level of sensitivity, value, and criticality to the University.
When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it. If this is not possible (for example, because your information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.
5. Sharing Of Information Collected
We share your information as necessary to provide the services you requested for recruitment, admission, and initial enrollment.
To Provide the Services You Request
Personal information is required for us to be able to provide services to you. You are required to provide personal information in order to create an account with us. When you submit an application, the information you entered into the application form will be disclosed to other departments at the University. In addition, please note that when you enter information into an application form, the information you entered will be available for processing whether or not you ever complete the form and submit it. You may access a form that is “in progress” and modify the information you have entered into it by following the instructions on the form. After you submit the form, you will not be able to access or modify the information submitted on that form without assistance from the University.
Third Party Service Providers
We share information, including personal information, with third party service providers that we use to provide hosting for and maintenance of our websites, application development, backup, storage, payment processing, analytics, and other services for us. These third party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third party service providers to use the personal information that we share with them for their marketing purposes or for any purpose other than in connection with the services they provide to us.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
6. Your Privacy Rights
You have certain rights regarding your personal information, as set forth in this Privacy Notice and applicable law.
Right to Access and Right to Delete
If you provide us with personal information in connection with your use of our services, you have the right to access this information and the right to have this information deleted, subject to certain limitations. In some cases, services require you to contact us to request access or deletion.
We will not deny you access to your personal information unless applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you.
To make a request to delete your personal information maintained by us, contact us using the contact information contained in this Privacy Notice. We will respond to your request to delete your information within thirty (30) days. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.
We do not guaranty the complete or comprehensive removal of content and information posted by you in the following circumstances: (i) if any applicable law requires us to maintain the content or information; (ii) if we have anonymized the content or information so that you cannot be individually identified; or (iii) if you fail to follow the instructions for submitting a request for removal of the content or information.
GDPR Privacy Rights
You have the right to request access to, a copy of, rectification, restriction in the use of, or erasure of your information in accordance with all applicable laws. The erasure of your information shall be subject to the retention periods of applicable federal law and the record retention schedule in Washington State University’s policies. If WSU is collecting your information based on your consent, you may also have the right to withdraw consent to the use of your sensitive information without affecting the lawfulness of the University’s use of the information prior to receipt of your request.
If your information was created or collected from within and transferred out of the European Union to the University, you may exercise these rights by contacting WSU’s Chief Information Security Officer, Thomas Ambrosi. You may also file a complaint with the appropriate supervisory authority in the European Union.
8. Children’s Personal Information
We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Notice.
If you are over the age of 13 but under the age of 16 and reside in the European Union, your parent or legal guardian may need to expressly consent to your using our Websites or services.
Notice to Parents and Legal Guardians
If you consented to our collection, use, disclosure, or other processing of your child’s personal information, you may review or have deleted the personal information we have about your child, and you can refuse to permit further collection, use, disclosure, or processing of such personal information in accordance with applicable law.
9. Other Important Privacy Information
Below you will find additional privacy information you may find important.
Security
We implement appropriate technical and organizational security measures to protect your information when you transmit it to us and when we store it on our information technology systems. Unfortunately, no data transmission or storage can be guaranteed to be 100 percent secure. When you send us information over the Internet, we use industry standard SSL (secure socket layer) encryption. Your password is protected so that only you can access it and view the information that you provide to us through the online applicants’ site. We strongly advise you not to share your password with anyone.
Passwords
Your password is protected so that only you can access it and view the information that you provide to us. We strongly advise you not to share your password with anyone. We are not responsible for the consequences of any passwords that you disclose or which are lost or stolen. Please advise us immediately if you believe your password has been misused or otherwise misappropriated.
Cookies
We may use cookies or other technologies to collect information about your preferences and history, and to customize your online experiences. You may refuse to accept cookies by following the procedures specific to your Web browser. If you do so, your browser may react strangely, and you may not be able to use some services on our online services.
Statement Changes
We may update or change this Privacy Notice at any time. Your continued use of the University’s website and third-party applications after any such change indicates your acceptance of these changes.
Updated August 1, 2020
10. Contact Us
If you have questions regarding this Privacy Notice or about our privacy practices, please contact WSU’s Chief Information Security Officer, Michael Walters, michael.walters@wsu.edu.