To better protect the privacy of users of the Columbia College
website, we have developed this statement to explain our online information
practices, and how the information we obtain is used. Please refer to
How we use your data
If you have any questions in relation to this policy or generally how your personal data is processed by us please contact our Data Protection Officer by letter addressed to: Chief Information Officer, Columbia College, 1001 Rogers Street, Columbia, MO 65216; or by email at GStanowski@CCIS.edu
This policy applies to any personal data that we collect about you when you:
- visit the website (our "website"),when you request, submit, and/or provide information to us, and in other scenarios discussed in greater detail below.
Who are we?
We are a "controller" of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with legal obligations and the EU Data Protection Laws, when applicable.
Collection of personal information
We collect your name and contact details (including your address, telephone number and e-mail address), personal information details (including your date of birth, gender, social security number, date of marriage, ethnic origin and race, citizenship status, education history, military history, family history (including spouses name) and employer name (including employment history).
The main purpose for which we use your information is to provide you with the services that you request from us. However, we also use both your non-personally identifiable information and your personal data for the further purposes below.
We collect your personal information to make our Web services customizable for each user. For each visitor to our website, our Web server automatically recognizes your operating system and Internet browser. Our Web server additionally records usage of pages by our visitors. We retain this information for research reports, and sometimes use this information so that we may improve the design and content of our website and advertising efforts.
Some of Columbia College's websites and services collect personally identifiable information to further adapt to our website visitors' needs. Some sites and services may require that you provide personally identifiable information in order to participate.
We may use the information you provide about yourself to fulfill your requests for our products, programs, and services, or to respond to your inquiries about our offerings. We sometimes use this information to communicate with you, such as to notify you when we make changes to our services, to fulfill a request by you, or to contact you about your account with us. We may also use your information to update internal systems.
We may also use the information you provide to us to assess your suitability for a degree program, or for employment with Columbia College.
Personal information is also collected as part of our efforts to keep our sites safe and secure (for example through the use of CCTV on our sites).
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
Children's Online Privacy Protection
In compliance with the Children's Online Privacy Protection Act of 1998, no one under 13 years of age can use the web site. If you are a minor between the ages of 13 and 18, you may use the site only in conjunction with your parent, legal guardian or other responsible adult.
From where do we get this information?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to the website or through your communications with us. We also obtain some information from other third parties, including previous schools and/or military branches.
Information that you give us
You may share personal data about yourself and your circumstances by:
- applying for employment with the college;
- filling in forms on the website, registering to use the website, and continuing to use the website;
- giving us information about yourself in any communications with us either by telephone, e-mail, post or otherwise, either in connection with your application or to report a complaint or issue;
- signing in at reception on one of our sites or hosted events;
- submitting an application for a degree program to us;
You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to provide services to you, respond to your queries, communicate with you effectively, or process your application.
Information that we collect about you
We collect personal data about you:
- when you send us electronic correspondence (including email and text messages);
- when you visit the website, including details of your visits to the website including, but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, acquisition data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access;
- if you visit one of our sites, data including your name and CCTV images;
- when you call Columbia College, including information about complaints and services, we monitor and/or record calls between our staff and you for the purposes of resolving complaints, training and to improve our quality and service standards.
Information that we receive from other sources
- the College may from time-to-time share your some of your information with third-party providers for the limited purposes of communicating with you regarding the educational programs we offer, or in connection with the College’s data-collecting practices to help evaluate and improve our educational services, website, and/or marketing and advertising. The College cannot and does not make any representations about the practices or policies of third parties with whom your information may be shared and the College disclaims liability relating to the same.
- from your previous school.
Special categories of personal data
EU Data Protection Laws define certain personal data as falling into ‘special categories of personal data’ such as personal data regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying a person, data concerning your health (including mental and physical health), or data concerning your sex life or sexual orientation.
We may ask you for some sensitive details or you may voluntarily give such personal data to us in connection with our obligation to provide information in relation to race and/or ethnicity for national statistical analysis. We will only process this personal data where we have an additional legal basis.
We may share any of your personal data which falls into a special category of personal data with IPEDs federal surveys, state mandated reporting and/or other public reporting as aggregated data.
Collection of information by third-party sites
Some of our Web pages may contain links to other websites whose information practices may be different than our own. Visitors should consult the other sites' privacy policies as we have no control over information that is submitted to, or collected by, these third parties.
Basis for using your information
Necessary for the entry into our performance of a contract
When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfill our obligations under such contract (e.g. to provide our educational services to you), we will need to collect, process and share (as further detailed in this policy) your personal information. Failure to provide the requisite personal information when entering into the contract will unfortunately mean we cannot provide our services to you.
Legitimate business interests
- carry out research and better improve our marketing and advertising efforts for a better personalized experience;
- provide you with the services you have requested;
- carry out research to understand current and prospective students, employees, alumni, and other users of the website use our services;
- develop and improve our services to you and to other users of the website and our services;
As indicated below, we may also pass your personal data to certain third parties in accordance with our legitimate business interests.
We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the EU Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the EU Data Protection Laws on the basis that we have a legitimate business interest.
We have a legitimate interest in processing your information as:
- we have legitimate interest in serving the appropriate marketing material to ensure a better experience and match with our product and services;
- you benefit from the provision the services;
- we have a legitimate interest in recording calls to monitor staff performance, train staff, and improve our processes;
- we will both benefit from the ability to enforce or apply rights under any contract between us;
- we are required to ensure health and safety of our sites and have a legitimate interest in ensuring any processes are effective;
- we have a legitimate interest in ensuring the security of our sites, and in assisting with the prevention and detection of crime;
- we would be unable to provide our services without processing your information.
Impact of processing
We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.
Columbia College recognizes the importance of protecting the privacy of our current and prospective students, employees, alumni, and other users of the website. However, we need to use some of the personal data we collect so that we can conduct our legitimate business by providing information of interest to our current and prospective students, alumni, or other users of the website.
We may, therefore, send you marketing messages by email and post about us and our events and offers where you have not unsubscribed and where you have purchased similar services from us, or where you have otherwise consented.
We use your personal data falling into special categories of personal data where you have explicitly consented for us to do so.
You have the right to withdraw your consent to processing of this nature at any time.
Who do we share your information with?
We may also use a number of carefully selected third parties to supply us with products and services, such as legal advice. We will only share your information with these suppliers where it is necessary for them to provide us with the services we need. We do not share your information with third parties for marketing purposes.
Your information will never be shared, given, or sold to a third party without your express consent. However, Columbia College may release personal information when we believe that such release is reasonably necessary to comply with law, enforce or apply the terms of any of our user agreements, or protect the rights, property, or safety of Columbia College staff, faculty, students, applicants or alumni.
Where is your information stored and how long do we keep it?
Transfers outside of the European Economic Area
If you are in the European Economic Area ("EEA") and are providing personal data to us you are transferring that information outside the European Economic Area to the US, which is a country deemed by the European Commission to be an inadequate destination in relation to the protection of the privacy rights of EEA residents and for which additional protections need to be put in place to protect those EEA residents' privacy rights. However, where you are resident in the EEA and need to transfer your personal data to us in order to apply for a place on a course or where the transfer of your personal data to us is necessary in order for you to take up the offer of a place on one of our courses, an exception to the above rule allows us to collect and use your data for these purposes without such additional protections in place.
Retention of your personal data
We will typically keep your personal data from your involvement with us for certain timeframes and consistent with our data and information preservation obligations. This allows us to better serve you and enables us to deal with any issues or concerns you may have about how we delivered our services to you, and also to allow us to bring or defend legal proceedings.
- cookies are refreshed in accordance with our cookies policy.
How Columbia College protects your information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features including the appropriate software, hardware, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.
What rights do you have?
In some instances, we may be unable to carry out your request, in which case we will write to you to explain why. Where you are unhappy with our response or the way in which we have handled your personal data you have the right to complain to the data protection regulator in your EU home country.
You have the right to request access to your personal data
You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
You have the right to ask us to rectify your personal data
You have the right to request that we rectify your personal data if it is not accurate or not complete.
You have the right to ask us to erase your personal data
You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide the debt management services to you, where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see right 6 below).
You have the right to ask us to restrict or block the processing of your personal data
You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don't need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.
You have the right to port your personal data
You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organization, or to request us to do this for you.
You have the right to object to our processing of your personal data
You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defense of legal claims.
You have the right not to be subject to automated decisions
You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
You have the right to withdraw your consent
You have the right to withdraw your consent where we are relying on it to use your personal data.
Questions and concerns
This policy was last reviewed and updated in July 2019.