The College recognizes the General Data Protection Regulation (GDPR) and the rights of European Union citizens whose information may reside in its data processing systems and is actively working towards efforts that show compliance of data processing of personal information for these EU citizens. This document contains information that shows the college's preparedness and efforts towards compliance where personal data is processed for EU Citizens.
The college identifies 'Data Subjects' as any natural person to whom personal data relates. Within the context of the college the data subjects fall into the following categories:
As defined within the context of GDPR is any data that can be directly or indirectly related to a natural person (data subject). Personal data includes any identifiable personal data that can connect personal data to a data subject e.g. name, citizen Id, phone number, email address, gender, nationality, address, interests, career details etc.
The College may, from time to time, be required to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership and criminal records and proceedings.
The College shall so far as is reasonably practicable make all efforts to ensure all personal data is:
The college houses personal data to recognize, process and communicate with its data subjects of prospective students, current students, prospective employees, current employees, alumni, donors, and vendors. The processing of this data is lawful and necessary and falls into one or more of the following categories:
(a) Consent: We use personal information while processing data for communicating with prospective students and prospective employees. While we do not have an implied contract with these data subjects at this point, the data subjects give us their implied consent to communicate with them by completing an application which is an intent to come to the college, use Federal financial aid at the college, work for the college, or do business with the college (students, employees, vendors).
(b) Contract: We use personal information while processing data that is necessary for the implied contract the college has with the individual e.g.
(c) Legal obligation: We will share personal information with companies, organizations or individuals outside of the College if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
(d) Public task: the processing is necessary for the college to perform a task in the public interest or for our official functions as a private college within the State of NC and the USA, and the task or function has a clear basis in law. Examples of these are:
Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.
The College is also required to protect the personal data with respect to the laws of the United States as well as provide information to State and Federal authorities with respect to these laws. The college complies with data requirements under the United States FERPA (The Family Educational Rights and Privacy Act), GLBA (The Gramm-Leach-Bliley Act) and HIPAA (Health Insurance Portability and Accountability Act of 1996)
The College acts as a Data Controller for all the personal data of its data subjects. The Data is processed by two parties.
Data subjects have the right of access to information held by the College. Any data subject wishing to access their personal data should put their request in writing to the RCM identified below.
Certain data is exempted from the provisions of the Rights of Access to Information under GDPR. Below are examples of some of the exceptions:
The College will make every reasonable effort to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the relevant college department of any changes to information held about them.
The college is committed to protecting the privacy of children therefore the college does not knowingly collect or process data from children under 16 years of age except in compliance with children's online privacy protection law. Accordingly, children under the age of 16 may only use services and programs offered by the college with the permission and supervision of their parents. Additionally, teachers and departments of the college that provide programs and services in the classroom with children under 16 years of age are required to obtain express consent of such children's parents in compliance with the applicable law, prior to permitting such children to access or use the services or programs.
If an individual believes that the College has not complied with this Policy or acted otherwise than in accordance with the GDPR, the person should contact the RCM and file their complaint in writing as well as utilize the College's grievance procedures.
The college regularly reviews our compliance with this Policy. We value your feedback so we may contact you to ask for more information or to follow up. We will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the individual rights or transfer of personal data that we cannot resolve with our data subjects directly.
The college takes data security very seriously and takes multiple layers of industry appropriate steps to ensure protection and security of personal data entrusted with the college. The college uses multiple industry standard solutions and processes to detect, report and investigate a personal data breach.
We work hard to protect the College and our data subjects from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:
The GDPR introduces a duty on all organizations to report certain types of data breaches to the EU Information Commissioner's Office and in some cases to the individuals affected. If the data breach falls into these categories, the college with help from the SIRT will make the appropriate reports.
The college provides several layers of data security training to its employees on a regular basis. From May 25, 2018 onwards, employees and offices who interact with EU citizens will also include training on personal data as defined by GDPR and how to ensure effective protection of this data.
When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction.
The College may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data. The College may store some data such as registers, photographs, exam results, achievements, books and works etc. indefinitely in its archive.
The College Risk and Compliance Manager (RCM) will act as the point person to accept requests from Data Subjects for Personal Data Rights Requests.
The College is located at 1 Brevard College Drive, Brevard NC 28712 and all its lead data protection supervisory authority operates from this location.
Policy Accepted: 6/6/2018
Next Policy Review: 06/06/2019