The University respects individual privacy and the laws governing it and remains committed to protecting and safeguarding the Personal Information of our students, faculty and staff, alumni, donors and others who access its products and services. This policy statement affirms the University’s commitment to maintaining that privacy and to inform interested parties of University policies and practices followed in protecting such Personal Information. This privacy commitment includes ensuring the accuracy, confidentiality and security of Personal Information and allowing individuals to request access to, and correction of, their Personal Information. This policy applies to all University officers, employees, contractors, agents and others who provide services to or on behalf of Living University in connection with the delivery of products, services and information.
Personal Information means information about an identifiable individual, such as name, age, date of birth, home address and phone number, marital status, financial information and details of one’s involvement with the University. Personal Information does not include Contact Information. The University may collect information provided in writing (including via electronic media) or verbally about its students, faculty, alumni, donors and others who access its products and services and does so for the following purposes, depending upon the specific circumstances:
- Fulfillment of requests for literature;
- To respond to requests for information, counseling and guidance;
- To provide instruction, mentoring, counseling and follow up activities for students;
- Communicating with and understanding the needs of students, faculty, staff, alumni and their families;
- To deliver requested products and services;
- Maintaining a record of one’s involvement with the University;
- Fund-raising and institutional advancement activities;
- Recording and processing donations and gifts;
- To provide receipts for income tax purposes ;
- Managing the University’s relationship with students, faculty, staff, alumni and donors;
- Meeting any legal, licensure, accreditation or regulatory requirements;
- Analysis for management purposes; and
- Other purposes consistent with the foregoing in order to fulfill the University’s mission.
The University obtains the consent of its students, faculty, alumni and others accessing its products and services to collect, use or disclose Personal Information (except where, as noted below, the University is authorized to do so without consent). Consent can be provided orally, in writing, electronically or through an authorized representative, or it can be implied where the purpose for collecting, using or disclosing the Personal Information would be considered obvious and the individual voluntarily provides Personal Information for that purpose. Consent may be implied where the individual concerned is given notice and a reasonable opportunity to opt out of his or her Personal Information being used for mail outs or fund-raising and the individual does not opt out.
Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for the University to use their Personal Information in certain ways. An individual’s decision to withhold or withdraw consent to certain uses of Personal Information may restrict the University’s ability to provide particular services or products. If so, the University should explain the situation to assist the individual in making the decision.
The University may collect, use or disclose Personal Information without an individual’s knowledge or consent when permitted by law including, by way of example:
• When the collection, use or disclosure is required or authorized by law (e.g., Directory Information permitted by FERPA; see Page 49 Students’ Rights in Regard to Official Academic Records for definition of Directory Information);
• In an emergency that threatens an individual’s life, health or personal security;
• When the Personal Information is available from a public source (e.g., a telephone directory); and
• When the University seeks or otherwise requires legal advice from an attorney.
Use of Personal Information
The University limits its collection, use and disclosure of Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing services, products or information to students, faculty, staff, supporters and others who access its products and services. The University uses only fair and lawful methods to collect Personal Information. The University’s use of Personal Information is limited to the purposes described in this policy. The University does not use or disclose an individual’s Personal Information for any additional purpose without consent.
Disclosure of Personal Information
As a general rule, all information concerning students, faculty, alumni, donors and others who access University products and services is held in strict confidence and, except in limited circumstances, not revealed to anyone else unless expressly or implicitly authorized by such individuals. Where the University is obliged or permitted to disclose Personal Information without consent, the University does not disclose more information than necessary.
Personal Information collected by the University is collected for its own requirements and the University does not sell, loan or share such Personal Information with outside entities; however, the University may publish or otherwise release certain Personal Information as Directory Information as authorized pursuant to the Family Educational Rights and Privacy Act (FERPA) and various University policies, rules and procedures related thereto. Moreover, there are a few exceptions including but not limited to the following:
• The University may, with consent, provide Personal Information to another entity affiliated with it if it has no local presence where the person is located or if the entity’s activities are more closely matched to his or her needs and requirements.
• The University may provide Personal Information to third party agencies or ministries (e.g., a Living Church of God entity worldwide) with which we have a joint venture or affiliation.
• The University may provide Personal Information to outside suppliers or contractors from whom it obtains services.
• The University may disclose Personal Information to meet regulatory requirements or otherwise without consent, as required or permitted by law in fulfillment of its mission.
Retention of Personal Information
When the University uses an individual’s Personal Information to make a decision that directly affects the individual, it retains that Personal Information for at least one year so that the individual has a reasonable opportunity to request access to it. Subject to the foregoing, the University normally retains Personal Information only as long as necessary to fulfill the identified purpose or a legal or business purpose. In that the University endeavors to maintain a lifelong relationship with its students, faculty, alumni, donors and others, it therefore may retain any Personal Information provided until a period of seven years from the last contact with said person, unless otherwise instructed and/or subject to legal requirements. When a person’s Personal Information is no longer required by Living University for business, legal, accreditation, licensure, archival, or other normal business purposes, the University maintains procedures to destroy, delete, erase or convert it into anonymous form. Currently, the principal place in which the University holds Personal Information is Charlotte, North Carolina, U.S.A. Such information may also reside in such other University locations as its business operations may require.
Ensuring Accuracy of Personal Information
The University endeavors to ensure that any Personal Information provided by its students, faculty, staff, alumni and others and in its possession, is as accurate, current and complete as necessary for the purposes for which it uses that information. The University makes reasonable efforts to ensure such Personal Information is accurate and complete where it may be used to make a decision about the individual or disclosed to another entity. Individuals may request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information should be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought. If Personal Information is demonstrated to be inaccurate or incomplete, the University normally corrects the information as required and sends the corrected information to any organization to which it disclosed the Personal Information in the previous year or if it is otherwise reasonable to do so. If the correction is not made, the University notes the correction request in the appropriate file.
Protection of Personal Information
The University is committed to ensuring the security of Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risk. The University endeavors to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to ensure that Personal Information is appropriately protected. This also applies to the disposal or destruction of Personal Information. The University further protects Personal Information by restricting access to it to those University workers that the management of the University has determined a need to know that information in order that the University may provide its products and services. If a University worker misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination with cause. If any individual or organization misuses Personal Information provided to them for the purpose of providing services to or for the University, this will be considered a serious issue for which action may be taken up to and including termination of any agreement between the University and that individual or organization. The University reviews its procedures and security measures from time to time to ensure that they remain effective and appropriate.
Access to Personal information
Students, faculty, staff, alumni, donors and others who access University literature and services have a right to access their Personal Information, subject to certain exceptions. In certain exceptional situations, the University may not be able to provide access to certain Personal Information that it holds about an individual. For example, the information may be protected by a solicitor client (or “attorney-client’) privilege. By way of further example, Living University may not provide access to Personal Information if doing so would reveal Personal Information about another individual. If access cannot be provided, the University notifies the individual of the reasons for refusal. A request to access one’s own Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. A request to access Personal Information should be forwarded to the Registrar, who serves as the University’s Privacy Officer. Upon request, the University may advise as to how an individual’s Personal Information has been used and is being used and to whom it has been disclosed, if applicable.
Privacy on the Internet is extremely important. As online users provide the University with personal information, they are provided with the terms and conditions surrounding the nature of and what the university does with that information. See Online Privacy Statement.