EU General Data Protection Regulation Compliance Policy

Responsible office
Information Technology Services
Responsible party
Deputy Chief Information Officer
Last revision
June 2020
Approved by
The Cabinet
Approval date
June 2020
Effective date
May 2018
Last review
June 2020
Additional references
General Privacy Policy; Advancement Privacy Notice

Scope

All financial and administrative policies involving community members across campus, including volunteers are within the scope of this policy. If there is a variance between departmental expectations and the common approach described through college policy, the college will look to the campus community, including volunteers to support the spirit and the objectives of college policy. Unless specifically mentioned in a college policy, the college’s Board of Trustees are governed by their Bylaws.

Policy

Colorado College (CC) is an institute of higher education involved in education, research and community development. In order for CC to educate its foreign and domestic students, engage in research, and provide community services, it is essential and necessary, and CC has a lawful basis, to collect, process, use, and/or maintain the personal data of its students, employees, applicants, research subjects, and others involved in its educational, research, and community programs. These activities include, without limitation, admission, registration, delivery of classroom, field, and study abroad education, grades, communications, employment, research, development, program analysis for improvements, and records retention.

Colorado College takes seriously its duty to protect the personal data it collects or processes. In addition to CC’s overall data protection program, the European Union General Data Protection Regulation (“EU GDPR”) imposes obligations on entities, like Colorado College, that collect or process personal data about people in the European Union (“EU”). The EU GDPR applies to personal data CC collects or processes about anyone located in the EU, regardless of whether they are a citizen or permanent resident of an EU country. Among other things, the EU GDPR requires Colorado College to:

  1. be transparent about the personal data it collects or processes and the uses it makes of any personal data
  2. keep track of all uses and disclosures it makes of personal data
  3. appropriately secure personal data


This policy describes Colorado College’s data protection strategy to comply with the EU GDPR.

Lawful Basis for Collecting or Processing Personal Data

Colorado College (CC) has a lawful basis to collect and process personal data. Most of CC’s collection and processing of personal data will fall under the following categories:

  • Processing is necessary for the purposes of the legitimate interests pursued by Colorado College or by a third party.
  • 处理是履行数据主体为当事人的合同或在签订合同前应数据主体的要求采取步骤所必需的.
  • Processing is necessary for compliance with a legal obligation to which Colorado College is subject.
  • The data subject has given consent to the processing of their personal data for one or more specific purposes.

There will be some instances where the collection and processing of personal data will be pursuant to other lawful bases.

Data Protection & Governance

赌博正规的十大网站(CC)将保护其合法收集或处理的所有个人数据和敏感个人数据.  Any personal data and sensitive personal data collected or processed by CC shall be:

  • Processed lawfully, fairly, and in a transparent manner
  • Collected for specified, explicit, and legitimate purposes, and not further processed in a manner that is incompatible with those purposes
  • Limited to what is necessary in relation to the purposes for which they are collected and processed
  • Accurate and kept up to date
  • Retained only as long as necessary
  • Secure

Sensitive Personal Data & Consent

Processing of personal data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation is prohibited by Colorado College, unless one of the following applies:

  • the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, 除非欧盟或成员国法律规定第1段所述的禁令不得由数据主体解除;
  • 为了履行控制者或数据主体在就业、社会保障和社会保护法领域的义务和行使特定权利,处理是必要的,只要它是由欧盟或成员国法律授权的,或根据成员国法律制定的集体协议,为数据主体的基本权利和利益提供适当的保障;
  • 处理是必要的,以保护数据主体或其他自然人的切身利益,而数据主体在身体上或法律上没有能力给予同意;
  • processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, 宗教或工会的目的,并且条件是处理仅涉及该机构的成员或前成员,或与该机构就其目的定期联系的人,并且未经数据主体同意,个人数据不会在该机构之外披露;
  • processing relates to personal data which are manifestly made public by the data subject;
  • processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity;
  • processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, 尊重数据保护权利的本质,并提供适当和具体的措施来维护数据主体的基本权利和利益;
  • processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, 在欧盟或成员国法律的基础上,或根据与卫生专业人员签订的合同,并受条件和保障的约束,提供卫生或社会保健或治疗,或管理卫生或社会保健系统和服务;
  • processing is necessary for reasons of public interest in the area of public health, 例如防范对健康的严重跨界威胁,或确保卫生保健和医药产品或医疗装置的高质量和安全标准, 在欧盟或成员国法律的基础上,该法律规定了保护数据主体权利和自由的适当和具体的措施, in particular professional secrecy; L 119/38 EN Official Journal of the European Union 4.5.2016
  • processing is necessary for archiving purposes in the public interest, 基于欧盟或成员国法律的符合第89(1)条的科学或历史研究目的或统计目的,这些目的应与所追求的目标成比例, 尊重数据保护权利的本质,并提供适当和具体的措施来维护数据主体的基本权利和利益.

Individual Rights

Individual data subjects covered by this policy will be afforded the following rights:

  • information about the controller collecting the data
  • the data protection officer contact information (if assigned)
  • the purposes and lawful basis of the data collection/processing
  • recipients of the personal data
  • if Colorado College intends to transfer personal data to another country or international organization
  • the period the personal data will be stored
  • the existence of the right to access, rectify incorrect data or erase personal data, restrict or object to processing, and the right to data portability
  • the existence of the right to withdraw consent at any time
  • the right to lodge a complaint with a supervisory authority (established in the EU)
  • why the personal data are required, and possible consequences of the failure to provide the data
  • the existence of automated decision-making, including profiling
  • if the collected data are going to be further processed for a purpose other than that for which it was collected

Note: Exercising of these rights is a guarantee to be afforded a process and not the guarantee of an outcome.

Scope: 

本政策适用于受EU GDPR保护的个人数据和敏感个人数据,以及所有收集或处理受EU GDPR保护的个人数据和敏感个人数据的科罗拉多大学单位.

Procedures

5.1 Data Governance

Document Lawful Basis for Collection or Processing

收集或处理受欧盟GDPR保护的个人数据的所有科罗拉多大学单位必须记录收集或处理个人数据和他们收集或处理的敏感个人数据的法律依据, why they collect it, and how long they keep it. All data at Colorado College shall be kept in compliance with the college’s Records Retention Schedule

5.2.  Privacy Notice

Colorado College’s Privacy Notice

赌博正规的十大网站发给数据主体的隐私通知必须明确赌博正规的十大网站收集或处理个人数据的合法依据,并包括:

  1. whether their personal data are being collected or processed and for what purpose
  2. categories of personal data concerned
  3. to whom personal data is disclosed
  4. storage period (records retention period)
  5. existence of individual rights to rectify incorrect data, erase, restrict or object to processing
  6. how to lodge a complaint
  7. the source of the personal data (if not collected from the data subject)
  8. the existence of automated decision-making, including profiling

 

5.4 Individual Rights

Exercise of Rights

Any individual wishing to exercise their rights under this policy should contact privacy@aprender-a-bailar.com

5.5 Data Protection

Security of Personal Data

在本政策范围内,任何赌博正规的十大网站单位收集或处理的所有个人数据和敏感个人数据必须符合安全控制、系统和流程要求以及学院信息安全政策的标准 http://b0hzdz.aprender-a-bailar.com/basics/welcome/leadership/policies/information-security-policy

Breach Notification

Any Colorado College Unit that suspects that a breach or disclosure of personal data has occurred must immediately notify Colorado College’s Cyber Security at privacy@aprender-a-bailar.com

 

Responsible Party and Responsibilities:

Colorado College Units
To document the lawful basis for personal data or sensitive personal data collected or processed pursuant to this policy.

To cooperate with privacy@aprender-a-bailar.com when individuals inquire about their personal data or sensitive personal data collected or processed pursuant to this policy.

To immediately notify (24/7) and cooperate with Colorado College Cyber Security relating to any data breach: privacy@aprender-a-bailar.com

Privacy@aprender-a-bailar.com
To field inquiries about personal data or sensitive personal data collected from individuals while in the EU (See Section 2.4).

协调赌博正规的十大网站单位回应个人资料或敏感个人资料的查询,而从个人在欧盟收集.

Cyber Security
To answer questions about and review data security measures.

To handle data breach notification for the Institute.

Enforcement: 

Violations of the policy may result in loss of system, network, and data access privileges, 行政处罚(包括终止或开除),如学院的信息安全政策所述.

http://b0hzdz.aprender-a-bailar.com/basics/welcome/leadership/policies/information-security-policy

To report suspected instances of noncompliance with this policy, please contact privacy@aprender-a-bailar.com

 

Definitions

Collect or Process Data

Collection, storage, recording, organizing, structuring, adaptation or alteration, consultation, use, retrieval, disclosure by transmission/dissemination or otherwise making data available, alignment or combination, restriction, erasure or destruction of personal data, whether or not by automated means. 

Consent

 

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.

Under the EU GDPR:

  1. Consent must be a demonstrable, clear affirmative action.
  2. Consent can be withdrawn by the data subject at any time and must be as easy to withdraw consent as it is to give consent.
  3. Consent cannot be silence, a pre-ticked box or inaction.
  4. 如资料当事人没有真正或自由的选择,或无法在不造成损害的情况下拒绝或撤回同意,则不应视为自愿给予同意.
  5. Request for consent must be presented clearly and in plain language.
  6. Maintain a record regarding how and when consent was given.

Controller

 

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Colorado College Unit

A Colorado College office, program or department.

Identified or Identifiable Person

 

An identified or identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that person.

Examples of identifiers include but are not limited to: name, photo, email address, identification number such as CC ID#, CC Account (User ID), physical address or other location data, IP address or other online identifier.

Lawful Basis

 

Processing of personal data shall be lawful only if and to the extent that at least one of the following applies:

  1. The data subject has given consent to the processing of their personal data for one or more specific purposes;
  2. 为履行数据主体为当事人的合同,或为在订立合同前应数据主体的要求采取步骤,处理是必要的;
  3. Processing is necessary for compliance with a legal obligation to which the controller is subject;
  4. Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  5. 为履行为公众利益而执行的任务或为行使赋予控制者的官方权力而进行的处理是必要的;
  6. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

Legitimate Interest

 

如果数据控制者/处理者的合法商业目的需要处理个人数据,则该等处理是合法的, 除非这些利益被需要保护个人数据的数据主体的利益或基本权利和自由所压倒.

Personal Data

Any information relating to an identified or identifiable person (the data subject).

Processor

 

A natural or legal person, public authority, agency or other body who processes personal data on behalf of the controller.

Sensitive Personal Data

Special categories of personal data that require consent by the data subject before collecting or processing are:

  1. Racial or ethnic origin
  2. Political opinions
  3. Religious or philosophical beliefs
  4. Trade union membership
  5. Genetic, biometric data for the purposes of uniquely identifying a natural person
  6. Health data
  7. Data concerning a person’s sex life or sexual orientation
Report an issue - Last updated: 02/29/2024