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GDPR Student Privacy Notice

Purpose of this Notice

Snow College is committed to safeguarding the privacy of individuals who apply for admission to the College. This Notice explains how we will collect, use and disclose your personal data. When you submit your application to us, or otherwise provide us with information in your application for admission, or use our websites and other services, you consent to our collection, use, and disclosure of that information as described in this Privacy Notice.

Throughout this Notice, “College” "we", "our" and "us" refers to Snow College, "you" and “your” refers to those expressing an interest in becoming a student at the College (both prior to and at formal application stage), together with those who later become a registered student at the College.

We are the data controller for personal data that we process about you.

European Union GDPR

Snow College is the data controller and a processor for personal data you supply. This Notice is intended to comply with the European Union GDPR requirements as to controllers and processors.

Anything you are not clear about

If there is anything you are unclear about, please contact our Data Privacy Officer, who shall be happy to answer any queries you may have concerning this Notice or the way in which we process your personal data.

The Data Privacy Officer's contact details are provided at the end of this Notice.

What is and where does the College get your personal data from?

‘Personal data’ means any information which relates to or identifies you as an individual including your name, address, phone number, education and other information asked for on the admissions application. Personal data requested does not contain “special categories of data” as described under the GDPR. Such “special categories of data" will include information about your racial or ethnic origin, religious beliefs or other philosophical beliefs, physical or mental health. If you become a student at Snow College, you may be asked for special categories of data but you can decide at that point if you wish to share with the College sensitive personal data.

We obtain personal data about you from the following sources:

  • from you when you apply for admission or register as a student with us;
  • from third party sources. When we obtain personal data about you from third party sources, we will look to ensure that the third party has lawful authority to provide us with your personal data.

The provision of personal data is necessary to apply for admission to and attend Snow College. Failure to provide such data will result in your application not being considered or prevent you from attending Snow College.

Categories of personal data being processed, the purposes for which we process your personal data and the legal basis for that processing and internal sharing

Snow College will process the personal information provided on your application and the other information referred to herein for the purposes of identifying you, processing your application, verifying the information provided, deciding whether to offer you admission, and communicating that outcome. If accepted and you decide to attend, we process your personal data for the administration of your position as a student with us. We may use and share your Information and Sensitive Information internally with other University offices and units to support your success as a student. We will also share your Information with other University offices to deliver education, advising, residence, athletic, student development, financial aid, and for fundraising if you are enrolled as a student of the University. We also might de-identify your Sensitive Information to use for research or statistical purposes.

We set out in Table 1 of this Notice in more detail the categories of personal data processed and the purposes for which we will process your personal data.

Who else might we share your data with?

We may disclose your information to third parties as follows:

Consent. We may use and disclose your Information to third parties if we have your consent to do so.

Parents and Guardians. In some cases, we may share your Information with a parent or guardian if necessary to properly complete the admissions process, report certain information as allowed by FERPA, or in the event of an emergency.

Service Providers. We may use third parties to support our operations. In such cases, we may share your Sensitive Information and Information with such third parties who are obligated to safeguard it from unauthorized disclosure.

College Counselors and Administrators. We may use your Information and share it with your school counselors and administrators.

College Affiliated Programs. We may share your Information with third parties that are affiliated with the University for the purpose of contacting you about goods, services, or experiences that may be of interest to you.

Research and Studies. We may share your Information with third parties that study admissions or other topics related to higher education. We may also share your Information with third parties that conduct research or develop products or services designed to improve admissions and other higher education functions.

Other Higher Education Organizations. We may share your information with other Higher Education organizations, in order to assist with transfers and tracking.

Required by Law. We may share your Information with third parties to the extent we are required to do so by law, court order, or subpoena. In the case of international applicants, we may share you information with the United States government or appropriate agencies including to act as your sponsor for visa purposes.

Emergency Circumstances. We may share your Information with third parties if, in our sole judgment, such disclosure is necessary to protect the health, safety, or property of any person.

De-Identified and Aggregate Information. We may collect, use and disclose Sensitive Information or other Information about our applicants in de-identified or aggregate form without limitation.

Additional notices and guidance/policies

We also have some additional notices, guidelines and policies with further useful information about the way in which we process your personal data:

  • Attendance monitoring – We conduct attendance monitoring for a number of reasons including to assist with student visas for international students and ensure the proper engagement of our students.
  • Our Alumni – As an integral part of the College’s services to its students it provides alumni activities. For more information see https://www.snow.edu/advancement/alumni/index.html
  • Our website – We use cookies on our website for session tracking and analytics. Please see our Privacy Statement for information on the use of cookies at:https://www.snow.edu/general/privacy_statement.html
  • FERPA – The College complies with the United States Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99) which is a Federal law that protects the privacy of student education records. Information regarding that as well as what FERPA Directory Information is and when it can be disclosed can be found at Snow College's Policy on the Confidentiality of Student Records https://www.snow.edu/offices/registrar/Policies/FERPA_Policy.html See also https://www.snow.edu/catalog/registration.html#records

Unwanted communication

We will from time to time communicate with you by email, text, mail or phone. If, at any stage, you are concerned about the content of these communications, e.g. unwanted marketing information, or wish to change the method of communication that we use please unsubscribe to general email communications.

If you are unsuccessful in unsubscribing from our communications and/or remain concerned, please contact our Data Protection Officer.

Retention periods

We store your personal information for as long as necessary to complete the application process. If you are successful, your information will be kept as part of your student record for the duration of your studies and permanently with regard to grades, degrees, certificates and other information showing your studies at Snow College. If you are unsuccessful, your information will be normally kept for at least one year after the completion of the application process.

Your rights as a data subject

We thought it would be helpful to set out your rights under GDPR. You have the right to:

  • withdraw consent where that is the legal basis of our processing;
  • access and/or a copy of your personal data that we process;
  • rectify inaccuracies in personal data that we hold about you;
  • be forgotten in certain circumstances, that is your details to be removed from systems that we use to process your personal data;
  • restrict the processing in certain ways;
  • obtain a copy of your data in a commonly used electronic form; and
  • object certain processing of your personal data by us.

Please see https://www.snow.edu/offices/registrar/Policies/FERPA_Policy.html for further information on the above rights and how to exercise them. You may also contact the Data Protection Officer for further information.

Updates to this Notice

We may update or change this Notice at any time. Your continued use of College services or enrollment after any such change indicates your acceptance of such changes.

Legal basis for processing your data under GDPR

(Article 6(1)(a)), Consent – on specific occasions the College will only process certain data if you consent e.g. on registration you only need to provide certain “special categories” of data if you agree to that.

(Article 6 (1)(b)), necessary for the performance of your student contract – on many occasions the College will process your data to enable it to meet its commitments to you e.g. those relating to acceptance, teaching and assessment.

(Article 6 (1)(c)), necessary to comply with a legal obligation – the College does have legal obligations to provide your personal data to others e.g. the United States government if you are an international student.

(Article 6 (1)(d)), for the purpose of protecting the vital interest of yourself or another – sometimes in extreme circumstances the College will have to release information to protect your interests or the interests of others e.g. in medical emergencies.

(Article 6 (1)(e)), processing necessary for the performance of a task carried in the public interest – the College is an educational establishment and in particular its educational activity is conducted in a public interest (including your interest and the interest of others). E.g. your personal information may be disclosed to others if you commit a violation of the student code of conduct.

(Article 6 (1)(f)), processing is necessary for the purposes of the legitimate interest of the College or a third party subject to overridden interests of the data subject – the College (and sometimes third parties) has a broad legitimate interest in activities that connect to the activities and education of students. Subject to those interests not being overridden by the interests of fundamental rights and freedoms of students, it will pursue those interests. Where Article 6(1)(f) is used the “legitimate interest” is generally the interest of the College (or third party) in providing or supporting the provision of higher education to its students.

(Article 22(2)(a)), automated decision making necessary for performance of a contract – the College will sometimes automate decisions relating to its services it is providing to you.

(Article 9(1)(a)), processing “special categories” of data where you have given consent – the College will process certain sensitive information about you with your consent, e.g. to provide a reasonable accommodation.

(Article 9(1)(g)), processing “special categories” of data where necessary for reasons of substantial public interest.

(Article 9(1)(f)), processing “special categories” of data in connection with legal claims.

It is recognized that some of the above grounds will overlap and that the College could rely on multiple grounds justifying its lawful processing. The College also reserves the right to rely upon other grounds that are not referred to here.

Concerns and contact details

If you have any concerns with regard to the way your personal data is being processed or have a query with regard to this Notice, please contact our Data Privacy Officer, Paul Tew at (435) 283-7290 or ude.wons@wet.luap

Our general postal address is 150 College Ave E, Ephraim, UT 84627.

TABLE 1
No. Specific Purposes Legal Basis – reference to Article 6 GDPR unless indicated to the contrary
1. Admission, registration and administration of studies. (1)(b) or (1)(f)
2. Academic assessment and progression. (1)(b) or (1)(f)
3. Administration of student related policies and procedures including appeals, complaints, grievances, disciplinary matters, and matters relating to health and conduct and to cheating and plagiarism (1)(b) or (1)(f)
4. Pursuit of social and sporting activities e.g. relating to use of the College’s sports facilities. (1)(b) or (1)(f)
5. The provision of College accommodation and other support services such as those of the Library, Accessibility Services, or financial aid. (1)(b) or (1)(f)
6. The granting of awards (including the publication of awards via the College's web site). (1)(b) or (1)(f)
7. Processing and recovery of accounts and fees. (1)(b) or (1)(f)
8. Research and statistical analysis. (1)(b) or (1)(f)
9. Production of statistical returns required for third party government bodies e.g. visa compliance information. (1)(c) or (1)(e) or (1)(f)
10. Creation of e-mail addresses, available to those within and outside of the College. (1)(b) or (1)(f)
11. Direct communications of or about (i) student benefits and opportunities offered by or through the College and (ii) College activities and events organized for students. (1)(b) or (1)(f)
12. Host mailing of services or career opportunities of direct relevance to student interests. (1)(b) or (1)(f)
13. Administration of employment contracts where the student is employed by the College. (1)(b) or (1)(f)
14. Administration of Alumni membership. (1)(b) or (1)(f)
15. Consideration and granting of prizes, scholarships and awards: of discretionary funding available to students; and of other such awards. (1)(b) or (1)(f)
16. In relation to the safety of individuals and their property and the protection of College assets, including the use of CCTV. (1)(b) or (1)(f)
17. The production of student identification cards; and the inclusion of photographic images on the College’s computerized student record system. (1)(b) or (1)(f)
18. The operation of a lecture capture facility relating to the recording of educational activities e.g. lectures, by the College. (1)(b) or (1)(e) or (1)(f)
19. To the police or other regulatory body where pursuant to the investigation or disclosure of a potential crime. (1)(f)
20. To close family and the emergency services where there is an emergency situation e.g. illness, serious injury or bereavement. (1)(f)
21. To other educational institutions involved in the delivery of a student’s course of study, e.g. affiliated colleges, exchange institutions including those outside of the United States, institutions to which a student transfers or continues their education. (1)(b) or (1)(f)
22. To professional bodies where registration with that body is related to or a requirement of the student’s studies. (1)(b) or (1)(e) or (1)(f)
23. To any third party accessing the College’s e-mail directory of student e-mail addresses or other FERPA Directory Information. (1)(b) or (1)(f)
24. To external agents of the College in relation to the repayment of student debts. (1)(f)
25. To Data Processors in order for them to process data on behalf of the College for any of the purposes for which the College is permitted to process the data, including the provision of academic and other services by the College. (1)(b) or (1)(f)
26. In relation to the provision of references for students or former students. (1)(f)
27. To external bodies and individuals who have funded student scholarships and awards. (1)(b) or (1)(f)
28. To the College’s external lawyers, insurers in respect of accidents occurring within the institution and external auditors.  
28. "Sensitive personal data” or “special categories of data” for the assessment and provision of services and accommodations to students with disabilities. Article 9(1)(a)