Privacy Statement

Grinnell College Privacy Policy

If you view our website, apply to Grinnell as a student, employee, or faculty member, enroll at Grinnell, make a donation, complete any online or hardcopy forms, or utilize any of the third-party systems or services that we use, you should be aware that we will collect certain personally identifiable data from you (“Personal Data”).  Grinnell respects your privacy and is committed to protecting your Personal Data and keeping it secure. This statement explains how and why we collect Personal Data from or about you, how we use it, when and why we share it with others, how we secure it, and what rights and choices you have in relation to your Personal Data.

Website

Information Collected From You

When you use our website, we may collect the following Personal Data from you: (i) personal information, such as your name, mailing address, email address, phone number, and student ID number (if you are a student or former student of Grinnell); and (ii) web analytical information collected automatically when you interact with our website, such as your IP address, browser type, internet service provider, and clickstream data. The Personal Data collected by us, or on our behalf, is collected: (i) to provide requested products and services; (ii) to respond to your inquiries and provide customer support; (iii) for our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc., that we think may be of interest to you; (iv) to analyze how sites and services are being accessed and used; (v) for investigation of information security and information asset protection-related incidents; (vi) to test, correct, and improve our content, applications, and services; (vii) to develop new applications, products, and services; (viii) to improve site and service performance and delivery; and (ix) for other purposes as described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above to process transactions requested by you and meet our contractual obligations; on the basis of our legitimate interests (for example, website analytics); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Cookies

Unless you take steps to browse the internet anonymously, or opt out, Grinnell, similar to most institutions and organizations on the internet, tracks web-browsing patterns to inform our understanding of how our website is being used. Generic information is collected through the use of “cookies,” which are text files placed on your computer, to evaluate usage patterns so that we can improve both content and distribution. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, doing so may prevent you from using the full functionality of our website. If you would like to learn more about cookies, please refer to the following website: http://www.allaboutcookies.org/.

Some sections of our website use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use our sites. The information generated by the cookie about your use of the website includes your IP address. This information will be transmitted to and stored by Google on its servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. In addition to the standard Google Analytics setup, we have implemented Google Analytics Demographics and Interest Reporting. We have minimal control over the code that is provided to us by Google.  The information we do receive is provided in aggregate form and used to improve the content of this website. Please visit the following pages for more information on Google Analytics terms of use and Google’s privacy practices. To opt out of Google web traffic data collection, you may alter your browser settings to refuse the use of cookies.  However, please note that if you do this you may not be able to use the full functionality of this website. If you are visiting this site using a mobile device, such as a smartphone or tablet, please refer to the manufacturer’s instructions on how to manage cookies. Google also provides the following option to opt out of Google Analytics tracking.

In addition to our cookies, cookies may be set by an organization other than us. These “third-party cookies” may, for example, originate from websites such as YouTube, Twitter, Facebook, Google Plus, or other social media services for which we have implemented “plug-ins” in our website.  Since the cookie policies of these sites change over time, you should determine their policies by visiting the privacy policy pages of these sites directly.

External Links

Our website may contain links to external websites not owned by, or officially affiliated with, us in any way. We are not responsible for the privacy practices or the content of such websites.

User Generated Content

We may offer opportunities for you to engage in discussions on our website, including submitting comments and replies on selected news stories. Any information you disclose in your submission of comments, including name, email, website, and the comment itself, becomes our property and is visible on our internal servers. Additionally, information regarding your name and comments shall be public on the site once a comment or reply is approved for submission on the website. Comments are up to the discretion and approval of our website moderators, and we reserve the right to reject or remove any content from appearing on our website. You shall not upload to, or distribute or otherwise publish on, our website any libelous, defamatory, obscene, pornographic, abusive, or otherwise illegal material; or any comment deemed to contain any of the above. You agree that you will not deliberately disrupt discussions with repetitive messages, meaningless messages, or “spam.” You agree not to use language that abuses or discriminates on the basis of race, religion, nationality, gender, sexual preference, age, region, disability, etc. You may not impersonate another user or any faculty or staff member by choosing a similar screen name. You must disclose conflicts of interest. Any comments deemed to contain the above will not be approved for distribution or, if approved, will be removed thereafter.

You acknowledge that any submissions you make to the site (i.e., user-generated comments) may be edited, removed, modified, published, and displayed on our website, and you waive any rights you may have in having the material altered or changed in a manner not agreeable to you. Submissions made to the site may also be included in our RSS feeds and APIs and made available for republishing through other formats. We reserve the right to delete, move, or edit submissions that it deems abusive, defamatory, obscene, in violation of copyright or trademark laws, or otherwise unacceptable. By making a submission, you are consenting to its display and publication on the site and in the services and for related online uses. When you share or recommend (with or without adding your own comments) any articles or content from the Services to your Facebook, Twitter, or Google Plus profile, that action is governed by their respective privacy policies.

Site Access

We may terminate your account or access rights to our website at any time, without notice, for conduct that we believe violates this agreement or other policies or guidelines. We may terminate your account or your access rights to the websites for online conduct that we believe is harmful to other users, to us, or to other information providers.

Admissions and Financial Aid

When you apply for admission to Grinnell and/or seek financial aid, we collect a significant amount of Personal Data from you. The primary source of this Personal Data is your application for admission and/or your application for financial aid.  We collect: (i) contact information, such as your name, address, email address, and phone number; (ii) demographic information, such as your gender or gender identity, and age; (iii) educational background, including the names of any prior schools, transcripts, school activities, and any disciplinary records; (iv) testing history, such as your scores on the ACT and SAT; (v) information about your personal interests, extracurricular activities, background, and other personal information you may choose to volunteer; (vi) employment history; (vii) personal financial information, such as your government identification number, personal and business tax information, wage reports and statements, bank statements, socioeconomic status, scholarships, and grant information; (viii) family information, such as family member names, ages, educational history, occupations, and income and net worth; and (ix) payment information, such as the name of your bank and your bank account number. We may solicit additional Personal Data, for example, from the persons who interview you during the application process, if applicable, or from other available sources when identifying potential candidates for admission in connection with recruiting activities.  The Personal Data collected by us, or on our behalf, during the admissions process is collected for the primary purposes of evaluating your candidacy for admission and eligibility for financial aid, and, if you are admitted and enroll, facilitating your education (such as by sharing your Personal Data with faculty and staff). We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, to process your application for admission); to process transactions requested by you and meet our contractual obligations (for example, to process your tuition payments); as necessary for compliance with our legal obligations (for example, financial aid reporting); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Current Students

In addition to the information that we collect from prospective students during the admission process and from current students seeking financial aid (described above under “Admissions and Financial Aid”), we collect the following Personal Data from our students after they have enrolled at Grinnell: (i) education information, such as your transcripts, school activities, honors, and awards; (ii) your photograph (for example, for your student identification card); (iii) disciplinary records; (iv) your health and health insurance information; and (v) your contact details. The Personal Data collected by us, or on our behalf, is collected for the primary purpose of facilitating your educational and social opportunities at Grinnell, in addition to satisfying our legal, regulatory, and contractual obligations, and the other activities described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, operating as an educational institution and ensuring your well-being and safety); to process transactions requested by you and meet our contractual obligations (for example, to process your purchase of books from the campus bookstore); as necessary for compliance with our legal obligations (for example, financial aid reporting); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Research

Faculty, staff, and students conducting research may collect, use, and share your Personal Data as part of a research project in which you have agreed to participate. Before our faculty, staff, or students collect your Personal Data for research purposes, they will give you a consent form that requests your consent to collect your Personal Data, and explains the types of Personal Data that will be collected and the purposes for which such Personal Data is being used, and, if applicable, shared with third parties.  Unless otherwise set forth on the consent form, the Personal Data collected by our faculty, staff, and student researchers is collected for the primary purpose of furthering research and understanding in fields of academic study. If you have questions about how we process your Personal Data in connection with a research project conducted by our faculty, staff, or students, you should contact the faculty or staff overseeing the research project or the contact persons listed on the consent form you signed where you agreed to participate in the research project.

Alumni and Donors

We collect and use Personal Data about our alumni, donors, and prospective donors, including Personal Data you provide to us (for example, when you connect with us on social media, update your alumni profile on our website, make a donation, or register to attend events that we sponsor).  If you were a student at Grinnell, some of your Personal Data is transferred from your student records into our alumni databases.  We may also collect Personal Data from publicly-available sources or third-party sources that support our alumni and fundraising efforts.  The Personal Data collected by us, or on our behalf, is collected for the primary purpose of providing you opportunities to interact with us, as well as with other alumni and students, and to enable your gifts or donations to us.  The Personal Data we collect includes: (i) contact information, such as your name, address, email address, and phone number; (ii) demographic information, such as your gender or gender identity, and age; (iii) educational background, such as your prior and subsequent schools, transcripts, school activities, honors, and awards; (iv) personal information, such as your personal interests, memberships, and extracurricular activities; (v) professional and employment-related information; (vi) personal financial information, such as your government identification number, banking information, and socioeconomic status; (vii) family information, such as family member names, ages, educational history, occupations, income levels, and net worth; and (viii) your donation history to us.   We process your Personal Data as part of our alumni and donor outreach and services in order: (i) to provide you opportunities to interact with us, and with other alumni and students; (ii) to enable alumni and donor communications, (iii) to promote events and fundraising opportunities; (iv) to request and process your donations to us; (v) to communicate with you about opportunities for giving, and to understand better your interests and how you might help support us through volunteerism and philanthropy;  (vi) to conduct analytics to improve our alumni and donor services, and analyze engagement and donation trends; (vii) to satisfy legal, regulatory, and contractual obligations; or (viii) to engage in other activities described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, requesting gifts or donations); to process transactions requested by you and meet our contractual obligations (for example, registration for events or processing of donations); as necessary for compliance with our legal obligations (for example, to provide required tax information); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Employees

We collect your Personal Data when you apply to work for us, upon hiring, and throughout your employment with us. The following Personal Data collected by us, or on our behalf, is collected for the primary purpose of facilitating your employment with us: (i) contact information, such as your name, address, email address, and phone number; (ii) payment information, such as the name of your bank and bank account number for processing your compensation; (iii) tax information, such as your government identification number, wages, and tax filing status; (iv) personal information and history, such as your marital status and other information about your background, and, when relevant for your position or as required by law, credit history, driving record, self-reported and publicly-available criminal records, citizenship and work authorization status; (v) employment history, such as prior employers, titles, wages, and work experience; (vi) educational history, such as prior schools, transcripts, awards, and honors; (vii) information for family members included in any benefit plans; (viii) demographic information, such as your gender or gender identity, age, and date of birth; (ix) job performance information, such as performance reviews, training records, and disciplinary records; and (x) health information, such as medical conditions that may impact your ability to work.  We process this Personal Data: (i) to evaluate your application for employment; (ii) to administer human resources-related processes, including payroll processing and the provision of employee benefits; (iii) to satisfy legal, regulatory, and contractual obligations; and (iv) for other purposes as described under “Other Uses of Personal Data” below. We process your Personal Data for the purposes described above on the basis of our legitimate interests (for example, making hiring decisions, conducting performance reviews, making decisions about your compensation, and ensuring your well-being and safety); to process transactions requested by you and meet our contractual obligations (for example, paying you and providing you with employment benefits); as necessary for compliance with our legal obligations (for example, to provide required information to tax authorities); or on the basis of your consent. Where we have determined that the legal basis for processing your Personal Data is that it is necessary to serve our legitimate interests, we have concluded that our interests do not inappropriately impact your fundamental rights and freedoms with respect to your Personal Data.

Third Parties Providing Personal Data

Your Personal Data may also be provided to us by third parties, such as other educational institutions, former employers, admissions test providers like ACT and SAT, and payment processors. We encourage you to review any privacy policies provided to you whenever you give your Personal Data to a third party.

Other Uses of Personal Data

In addition to the uses described above, we may use your Personal Data to: (i) contact you to respond to your requests or inquiries; (ii) provide you with newsletters, articles, service alerts, announcements, event invitations, or other information that we believe may be of interest to you; (iii) request donations from you; (iv) conduct research, surveys, or other similar inquiries to help us understand the trends and needs of our applicants, potential applicants, students, and others using our website or other services; (v) meet the requirements of our accreditors; (vi) assist our marketing and advertising efforts; (vii) prevent, investigate, or provide notice of fraud, unlawful or criminal activity, or other misconduct, security, or technical issues, including unauthorized access to or use of your Personal Data, our website, or our data systems; (viii) respond to subpoenas, court orders, or other legal process; (ix) enforce our contractual agreements; (x) protect the health, safety, rights, or property of you, us, or others; and (xi) meet any other legal obligations that we may have.

How We Share Your Personal Data

Where there is a legitimate reason for doing so, we may share your Personal Data with certain third parties that we work with, including: (i) third parties who work with us to provide services to you; (ii) third parties who provide services to us, including information technology and a web analytics services; (iii) auditors, attorneys, and other professional service providers; (iv) government entities to whom we have a statutory obligation to provide information; and (v) law enforcement agencies. We may also share your Personal Data with our Board of Trustees, faculty and staff members, employees, agents, contractors, consultants, volunteers, and students serving on official Grinnell committees or assisting school officials.  We also may release your Personal Data when we believe such release is appropriate to comply with the law, enforce our website policies, or protect our or others’ rights, property, or safety. We do not sell, trade, or otherwise transfer your Personal Data to third parties, except as explained herein; provided, however, that non-personally identifiable website visitor information may be provided to other third parties for marketing, advertising, or other uses without restriction.

Retention of Your Personal Data

We will retain your Personal Data for as long as is necessary for the purposes set out herein unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights, or otherwise to comply with our legal obligations.  Where we are processing your Personal Data based on your consent, we will retain your Personal Data for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased. Where we are processing your Personal Data based on a contract, we will retain your Personal Data for the duration of the contract plus any additional period of time that is necessary to comply with the law or that represents the statute of limitations for legal claims that could arise under the contract. Where we are processing your Personal Data based on a public interest, we will retain your Personal Data for the period of time that serves that underlying public interest. Where we are processing your Personal Data based on our legitimate interests, we will retain your Personal Data for a reasonable period of time based on the particular interest in question, taking into account your fundamental rights and freedoms with respect to your Personal Data.

Transfer of Your Personal Data

Your Personal Data will be stored on Grinnell’s servers, which are in the United States, and on the servers of cloud-based services Grinnell engages. If you are outside of the United States, you should understand that we may transfer your Personal Data to the United States.  Because the United States has not sought or received an adequacy decision under the European Union’s General Data Protection Regulation (GDPR), we rely on appropriate safeguards and on derogations for specific situations that are recognized under GDPR when transferring your Personal Data to the United States.

Your Rights with Respect to Your Personal Data

To the extent required by and in accordance with applicable law, upon your request, we will provide you with information about the Personal Data of yours that we possess.  In addition to obtaining that information from us, you may have a right to: (i) correct any of your Personal Data that is inaccurate; (ii) restrict or limit the ways in which we use or process your Personal Data; (iii) request that we delete your Personal Data; and (iv) obtain a copy of your Personal Data in an easily accessible format. You have the right to withdraw your consent to our processing of your Personal Data where our processing is solely based on your consent, subject to certain limitations at law; provided, however, that in certain cases, we may continue to process your Personal Data after you have withdrawn your consent and requested that we delete your Personal Data, if we have a legal basis to do so.  For example, we may retain Personal Data that is needed to comply with our legal obligations, if we still need the Personal Data for the lawful purposes for which we obtained it, or if it is necessary to retain the Personal Data to pursue our legitimate interest in keeping our services and operations safe and secure.

Questions/Concerns/Complaints

If you have questions, concerns, or complaints about how we are using your Personal Data, or wish to make any requests regarding your Personal Data, we ask that you contact our Data Protection Officer using the information listed below. If you reside in the European Economic Area, you also may have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority), which varies depending on your location.

Angela Voos, Data Protection Officer
Grinnell College, 1115 8th Avenue, Grinnell, IA 50112
(641) 269-3038
dpo@grinnell.edu

Grinnell College may update or change this policy notice at any time.

Effective Date:  May 25, 2018

Last revision date: August 15, 2018