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PRIVACY STATEMENT

The University of Cincinnati (UC) recognizes the importance of privacy and is
committed to protecting the personal data of our students, faculty, staff,
alumni and guests.  This Privacy Statement explains the type of personal data UC
collects and how that data is used.

WHERE UC OBTAINS PERSONAL DATA

FROM YOU OR AT YOUR DIRECTION

UC receives personal data from multiple sources, most often directly from you or
from a third party whom you have directed to provide information to UC (e.g.,
application for admission to UC through the use of CollegeNet or the Common
App).

PUBLICLY FACING TECHNOLOGY SERVICES

The university’s publicly facing technology services (ex.: websites, student
information system, learning management system, and similar) collect personal
information that you knowingly and voluntarily provide when completing
applications and forms, sending emails, registering for classes or other
programs, responding to surveys, or ordering merchandise. Your personal
information can be used to provide you with the needed information, products or
services, as well as helping to enhance your experience with the university’s
resources and technology services.

 * The IP address from which you access our website
 * The name of the domain from which you access the Internet (for example,
   aol.com, if you are connecting from an America Online account)
 * The type of browser and operating system used to access our website
 * The date and time you access our site
 * The pages, files, documents, and links that you visit
 * The Internet address of the website from which you linked to this website

COOKIES

Cookies are small pieces of data stored by the web browser on your local
computer or mobile device, often used to remember information about preferences
and pages you have visited. By setting preferences in your browser, you can
refuse to accept cookies, disable cookies, and remove cookies from your hard
drive.

The university’s website uses cookies to personalize its content and enhance
your experience accessing technology services.

LINKING

Within our website there are links to third-party websites. When you link to
third-party websites, you leave UC’s website and no longer will be subject to
our privacy policy. UC is not responsible for the privacy practices or the
content of third-party websites, and such links are not intended to be an
endorsement of those sites nor their content.


HOW WE USE PERSONAL DATA

In order for UC to achieve its core mission, it is essential and necessary for
UC to process personal data of its students, employees, applicants, research
subjects, alumni and others involved in our educational, research, service and
community programs.  UC processes personal information for various lawful
reasons, including, without limitation:

 * Academic admissions and enrollment
 * Student registration
 * Residence life
 * Delivery of classroom, on-line, and study abroad education programs
 * Administration and oversight of recreation programs
 * Student organizations
 * Student affairs activities
 * Distribution of grades, materials, and other communications by and among
   students, faculty, and staff
   Research
 * Program development and analysis
 * Hiring and employment
 * Provision of clinic services or health insurance
 * Engagement with the community at-large
 * Compliance with its internal policies, procedures, and guidelines
 * Compliance with all applicable federal, state, and local laws
 * Records retention

Personal data that UC processes typically includes, but is not limited to, name,
Social Security number, date of birth, address, email, phone number,
transcripts, work history, financial information, information for payroll,
research subject information, medical and health information (for admissions,
student health services, travel, etc.) and donations.

If you refuse to provide personal data that is required by UC in connection with
one of UC’s lawful bases to collect and process the personal data, such refusal
may make it impossible for UC to provide the requested or necessary service.

SHARING OF PERSONAL DATA

UC shares personal data with other parties when one or more of the following
conditions apply:

 * We have previously notified you that sharing the information is necessary
 * We have your consent to share the information
 * We need to share your information to provide the service or product you
   requested
 * We need to send your information to companies who provide a service or
   product to you on behalf of UC
 * The information is student directory information
 * To respond to subpoenas, court orders, or any other legal requirements
 * When it is necessary to protect and defend the legal rights and/or property
   of UC
   To protect your safety and/or the public’s safety.
 * As applicable to staff, faculty, applicants and students, common examples of
   UC’s sharing personal data include, but are not limited to:
 * Agencies of the State of Ohio and/or the United States Government (e.g. U.S.
   Citizenship and Immigration Services, U. S. Department of Education)
 * Your funders and/or lenders
 * The providers of any external/collaborative learning and training placements
   or fieldwork opportunities
 * External auditors, examiners and assessors
 * Relevant professional or statutory regulatory bodies
 * Relevant university student union(s) and student clubs and societies, in
   order to facilitate your membership of those bodies
 * Local authorities
 * Police and other law enforcement agencies
 * Affiliated entities (e.g., The University of Cincinnati Foundation)
 * Companies or organizations providing specific services to, or on behalf of,
   UC
 * Prospective and actual research funders or sponsors
 * External providers of any staff benefits or retirement plans
 * If applicable, staff or faculty unions
 * Others as may be required by the law

We generally do not actively share personal information gathered from the
university’s technology services such as our web servers. As UC is a public
institution, some information collected from our websites, including information
from our server logs, e-mails delivered to the UC, and information collected
from digital forms, may be subject to the Ohio Public Records Act.  In some
cases, we may be required by law to release information gathered through and/or
by UC technology services.

UC complies with the Family Educational Rights and Privacy Act (FERPA), which
prohibits the release of education records except in limited circumstances. UC
also complies with the applicable provisions of the Gramm-Leach-Bliley Act
(GLBA) and the Health Insurance Portability and Accountability Act (HIPAA) where
relevant and appropriate.

UC will comply with its published data protection policies in the processing of
your personal data, except for legally permitted exceptions.  Please see UC’s
Office of Information Security website for related policies and further detail.

If you have specific questions regarding the collection and use of your personal
data, please contact the Director of Privacy within the Office of General
Counsel.

DATA RETENTION

Generally, UC retains data it collects as specified in its General Records
Retention Schedule.

EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR)

The EU GDPR provides broad privacy protections to individuals physically located
in the European Economic Area (EEA) (data subject(s)).  Under certain
circumstances, the GDPR may apply to UC activities in the EEA, for example, when
a student attends a study abroad program in the EEA or when a faculty member is
temporarily assigned to work on behalf of UC in the EEA.  When subject to the
GDPR, UC will comply with the regulation’s core privacy principles.

GDPR LAWFUL BASES FOR PROCESSING PERSONAL DATA

Under the GDPR, UC must have a lawful basis to process a data subject’s personal
data. Although there will be some instances where the processing of personal
data will be pursuant to other lawful bases (e.g., processing necessary to
protect the vital interests or safety of a data subject, processing related to
legal action involving the university, etc.), the following lawful bases will
apply to most UC data processing activities:

 * Processing for the purposes of the legitimate interests pursued by UC or by a
   third party;
 * Processing for the performance of a contract to which the data subject is
   party or in order to take steps at the request of the data subject prior to
   entering into a contract;
 * Processing for compliance with a legal obligation to which UC is subject; and
 * Processing pursuant to the consent of a data subject for one or more specific
   purposes.

GDPR INDIVIDUAL RIGHTS OF THE DATA SUBJECT

Subject to all other applicable laws and regulations, including all laws of the
United States and the State of Ohio, where legally applicable, certain data
subjects have the following rights under the GDPR:

 

 * To access the personal data we maintain about you;
 * To be provided with information about how we process your personal data;
 * To correct or modify your personal data;
 * To have your personal data deleted;
 * To object to or restrict how we process your personal data;
 * To request your personal data to be transferred to a third party; and
 * To file a complaint.

Please be aware that under certain circumstances, the GDPR or other applicable
laws may limit a data subject’s exercise of the above rights. To exercise the
above rights, data subjects should contact Privacy@uc.edu. Please note that
exercising these rights is not a guarantee of a requested outcome.

COMMENTS/QUESTIONS

Please email us if you have questions about this Privacy Statement, or if you
find UC web pages that do not adhere to this statement.

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