The purpose of this policy is to protect the privacy of your personal information is important to Luther College. We respect your right to privacy and recognize our obligation to keep information about you secure and confidential. We have implemented appropriate technological safeguards and usage policies to ensure that the personal information you submit to Luther College is used only for official college business.
This policy applies to all applicants, students, faculty and staff, alumni and other members of our community.
A. General Policy – U.S. Based
Protecting the privacy of your personal information is important to Luther College. We respect your right to privacy and recognize our obligation to keep information about you secure and confidential. We have implemented appropriate technological safeguards and usage policies to ensure that the personal information you submit to Luther College is used only for official college business.
Luther College receives your personal information solely for the purpose of establishing and maintaining our relationship with you. For that relationship to proceed as effectively and conveniently as possible, we use technology to manage and maintain your information. We will not sell, rent, or share your personal information with other individuals, private or public organizations for any purpose outside official college business. We will not share your personal information with any unauthorized third parties.
We do not disclose any personal information about you to anyone, except as permitted by law. For example, we share such information with the U.S. Department of Education and state agencies. We are permitted by law to disclose personal information about you to "nonaffiliated third parties" in certain circumstances; for example, we may share your personal information as necessary to administer a transaction you have requested or to process a service on your behalf.
We restrict access to your personal information to our employees who need to know the information in order to provide service to you, such as processing your application for admission. We maintain physical, electronic, and procedural safeguards in compliance with federal regulations to safeguard your personal information.
Luther College considers privacy, security, and service in our online operations to be just as critical as in the rest of our operations. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.
Luther College uses a variety of proven protections to maintain the security of visitor’s information. For example, we make use of secure socket layer connections, firewall technology, and encryption to protect your information.
When you visit Luther College’s website, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our websites. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and function.
Luther College uses demographic information gathered through Google Analytics, including its Demographics and Interests reports, to gain a deeper understanding of who our visitors are, what they are interested in, and how they are using our website.
In addition, as you browse our website, advertising cookies may be placed on your computer so that we can understand what you are interested in. This allows our display advertising partners to present you with targeted advertising on other sites based on your previous interactions with our websites.
We may also use the information we collect from you to:
In the event that Luther College becomes aware that site security is compromised or nonpublic user information has been disclosed to unrelated third parties as a result of external activity, including but not limited to external security attacks, we shall take reasonable measures which we deem appropriate, including but not limited to internal investigation and reporting, and notification to and cooperation with law enforcement authorities, notwithstanding other provisions of this Privacy Statement.
B. Privacy Notice – E.U. Based
Luther College seeks to comply with the requirements of the General Data Protection Regulation (“GDPR”) for persons residing or located in the European Union (“EU”). The GDPR requires organizations which process the personal data of EU-based individuals, such as Luther College, to take measures to protect personal data and allow individuals to maintain control of their personal data.
This Privacy Notice outlines the collection, use, and disclosure of personal data provided to the College by applicants, students, faculty and staff, alumni and other members of our community in the EU. When information is submitted to the College, or you use the College’s websites and other services, you consent to the collection, use, and disclosure of that data as described in this Privacy Notice. To the extent any other College policy/procedure and this Privacy Notice conflict, this Privacy Notice controls for individuals located in the EU and/or under the GDPR.
For purposes of this Privacy Notice, “personal data” means any information which relates to or identifies you as an individual.
Purpose for the Collection and Use of Personal Data
Applicants for enrollment:
The College will use the details you provide on your application, including any completed application forms, references, or transcripts, for the purposes of:
As well as circulating your application and related materials to the appropriate staff at the College, we will share your personal data for the above purposes as relevant and necessary to matriculate you as a student. This includes disclosures to third parties for financial aid, housing, immigration, and companies providing specific services to the College.
If you are accepted as a student, the College will keep a record of your application materials. The College will also maintain records about your studies at the College, your use of the academic and non-academic facilities and services the College offers (including student organizations and healthrelated resources), and student housing. This personal data will include data such as your name, home address, date of birth, course studies and/or educational program, financial aid, and information about your grades and student conduct.
The College will process your personal data for the purposes of providing you an education at Luther College, including the following:
Your personal data is shared with relevant administrators, faculty, and staff at the College as required to facilitate these operations. We will share your personal data for the above purposes as relevant and necessary to third parties, including for financial aid, housing, immigration, and companies providing specific services to the College.
Applicants for employment:
The College will use the details you provide on your application for employment, including any completed application forms, references, resumes/CVs, for the purposes of:
If you are required to undergo certain additional recruitment checks or procedures as part of the job application and offer process (for example, criminal convictions checks or visa application procedures), you will be informed and we will follow the procedures below for “special information” as applicable.
As well as circulating your application and related materials to the appropriate staff at the College, we will share your personal data for the above purposes as relevant and necessary to assess your application and onboard you as an employee.
Once employed, the College will keep a record of the details you provided in your application materials, as well as interview and onboarding documentation. The College will maintain various administrative and financial records about your employment at the College, and about your use of the academic and non-academic facilities and services that we offer. The personal data collected and stored for employees includes contact information; financial information as necessary for payroll and benefit processing; employment contracts as applicable; performance reviews; wage and payroll records; disciplinary information; and any other information required to be compiled and retained under state and federal law.
The College will process your personal data for the purpose of employing you at the College, including the following:
Your personal data is shared with relevant administrators, faculty, and staff at the College, as well as third parties, as required to facilitate these operations. However, please see the College’s policies on Employment Records in the Network Use Policy for specifics and safeguarding employee information.
Alumni and College Supporters:
The College stores information regarding alumni which was provided to the College during enrollment. Personal data retained on alumni includes the details of education (programs of study and graduation date), contact information, details of interactions with the College (including membership in student organizations), family details, communication preferences, financial information, careers, and information on areas of interest. Supporters of the College who are not alumni may also voluntarily provide the same or similar personal data.
This personal data is used for alumni relations, supporter communications, and fundraising, including specifically:
Your personal data is shared with relevant College staff, as well as third parties, as required to facilitate and carry out these functions. You have the right to object to the collection, processing, or use of your personal data, and may do so at any time.
Other Community Members
Any other individuals providing personal data to the College, such as family members of students and applicants, retirees, event patrons, customers, contractors and vendors, and research subjects, also fall under this Privacy Notice as applicable. Any personal data collected, processed, and used, will be for the purpose of furthering the College’s mission and provision of services as set forth above.
Storage and Transmission
Your personal data is created, stored and transmitted securely in a variety of paper and electronic formats, including some databases. Access to your personal data is limited to staff who have a legitimate interest in it for the purpose of carrying out their duties, and our use of your personal data will not be excessive.
“Sensitive” Categories of Information
In carrying out its functions as described above, the College may process some data about you that is classed as “sensitive” or “special category” personal data, and which requires additional protections. This includes information concerning your ethnicity, sexual orientation, religious beliefs or health/disability for planning and monitoring purposes, or in order to provide care, help or reasonable accommodations. For certain roles, other sensitive information may be processed, such as information about past criminal convictions, working with children or vulnerable adults, and your fitness to practice in certain regulated professions. Access to, and the sharing of, your “sensitive” personal data are controlled very carefully. You will normally be given further details about our use of any such data when we collect it from you.
Legitimate Bases for Collecting and Processing Personal Data
We consider the processing of your personal data for the above purposes to be either necessary for us to comply with a legal obligation (such as to administer visa applications); necessary for the performance of tasks we carry out in the public interest (such as admissions research); or as necessary for legitimate interests of the College or third parties in operating this institution and providing education, when it does not outweigh your rights to privacy. The College may also obtain specific, written consent as a legitimate basis for collecting and/or processing personal data. The College may also rely on any other legitimate basis for processing permitted under the GDPR, and will inform you as required.
Individual Rights of the Individuals under the GDPR
In addition to the right to receive the information provided in this Privacy Notice, individuals covered by this Privacy Notice have the right to:
Note that some of these rights are qualified under the GDPR, and that many rights afford individuals a process but may not guarantee a particular outcome.
Any person who wishes to exercise any of the above-mentioned rights may do so by filling such request with: (1) For Students and Applicants - The Registrar ([email protected]); (2) For Employees and Applicants for Employment – The Office of Human Resources ([email protected]); and (3) For Alumni/Supporters – [email protected]
Third Party Disclosure
Luther College may share your personal data with third parties as follows:
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies.” Cookies set by parties other than the website are called “third party cookies.” Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What cookies and other tracking technologies does Luther use?
We use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. Specifically, the cookies we use are:
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.
How can you disable cookies and other tracking technologies?
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com. Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Your information will be retained by the College in accordance with applicable state and federal laws, and the applicable retention periods in College Records Retention Management policy. Your information will be destroyed upon your request unless applicable law requires destruction after the expiration of an applicable retention period. The manner of destruction shall be appropriate to preserve and ensure the confidentiality of your information.