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Clayton State University Privacy & Legal Notice

Below is the Clayton State University privacy and legal notice for both its website and for compliance with the European Union General Data Protection Regulation (“EU GDPR”). The Office of Marketing and Communications is responsible for information related to the Clayton State University website and the Office of Data Privacy for compliance with the EU GDPR.

What we collect and why

Clayton State University collects information from individuals or entities when they access any Clayton State University website.  Information that is collected from this contact is the contactor’s IP address, date and time of the website access along with the web pages(s) visited.  In addition, Clayton State University may also collect any information that it receives from your web browser, including browser type and version, and operating system.  This information helps us understand aggregate uses of our site, track usage trends and improve our services.

Cookies

Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user.  Our website uses persistent cookies in conjunction with a third party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.

Security

Our office is committed to ensuring the security of your information. We have put in place reasonable physical, technical and administrative safeguards designed to prevent unauthorized access to or use of the information collected online.

Sharing your information

We will not share your information with third parties except:

Links to other websites

This site may contain links to other websites not affiliated with the University. We are not responsible for the privacy practices of these other sites. We encourage you to read the privacy statements of other sites for assurance that their practices safeguard your privacy.

Legal Notice

Notwithstanding any language to the contrary, nothing contained herein constitutes nor is intended to constitute an offer, inducement, promise, or contract of any kind. The data contained herein is for informational purposes only and is not represented to be error free. Any links to non-Clayton State University information are provided as a courtesy. They are not intended to nor do they constitute an endorsement by the Clayton State University of the linked materials.

 

Email Policy

Email standard policy – Office 365


European Union General Data Protection Regulation (EU GDPR) Privacy Notice

Lawful Basis for Collecting and Processing of Personal Data

Clayton State University is an institute of higher education involved in education, research, and community development.  In order for Clayton State University to educate its students both in class and on-line, engage in world-class research, and provide community services, it is essential, necessary, and Clayton State University has lawful bases to collect, process, use, and maintain data of its students, employees, applicants, research subjects, and others involved in its educational, research, and community programs. The lawful bases include, without limitation, admission, registration, delivery of classroom, on-line, and study abroad education, grades, communications, employment, applied research, development, program analysis for improvements, and records retention. Examples of data that Clayton State University may need to collect in connection with the lawful bases are: name, email address, IP address, physical address or other location identifier, photos, as well as some sensitive personal data obtained with prior consent.

For more information regarding the EU GDPR, please review Clayton State University EU GDPR Compliance Policy

Most of Clayton State University collection and processing of personal data will fall under the following categories:

  1. Processing is necessary for the purposes of the legitimate interests pursued by Clayton State University or third parties in providing education, employment, research and development, community programs.
  2. Processing is necessary 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. This lawful basis pertains primarily but not exclusively to research contracts.
  3. Processing is necessary for compliance with a legal obligation to which Clayton State University is subject. This lawful basis pertains primarily but not exclusively to compliance with state and federal laws. Examples are providing enrollment data to the US Department of Education and providing employment and payroll data as required by the US Internal Revenue Service.
  4. The data subject has given consent to the processing of his or her personal data for one or more specific purposes.  This lawful basis pertains primarily but not exclusively to the protection of research subjects, providing medical and mental health services.

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

Types of Personal Data collected and why

Clayton State University collects a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often the data is used for academic admissions, enrollment, educational programs, job hiring, provision of medical services, participation in research, development and community outreach. Data typically includes name, address, transcripts, work history, information for payroll, research subject information, medical and health information (for student health services, or travel), and donations. If you have specific questions regarding the collection and use of your personal data, please contact eugdpr@clayton.edu.

If a data subject refuses to provide personal data that is required by Clayton State University in connection with one of Clayton State University lawful bases to collect such personal data, such refusal may make it impossible for Clayton State University to provide education, employment, research or other requested services.

Where Clayton State University gets Personal and Sensitive Personal Data

Clayton State University receives personal and sensitive personal data from multiple sources. Most often, Clayton State University gets this data directly from the data subject or under the direction of the data subject who has provided it to a third party (for example, application for admission to Clayton State University through use of the Georgia Futures admission’s application).

Individual Rights of the Data Subject under the EU GDPR

Individual data subjects covered by Clayton State University EU GDPR Compliance Policy rights:

  1. information about the controller collecting the data
  2. the purposes and legal basis/legitimate interests of the data collection/processing
  3. recipients of the personal data
  4. if Clayton State University intends to transfer personal data to another country or international organization
  5. the period the personal data will be stored
  6. 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
  7. the existence of the right to withdraw consent at any time
  8. the right to lodge a complaint with a supervisory authority (established in the EU)
  9. why the personal data are required, and possible consequences of the failure to provide the data
  10. the existence of automated decision-making, including profiling
  11. 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.

Any data subject who wishes to exercise any of the above-mentioned rights may do so by filling such request at openrecords@clayton.edu.

Cookies

Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user.  Our website uses persistent cookies in conjunction with a third party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.

Security of Personal Data subject to the EU GDPR

All personal data and sensitive personal data collected or processed by Clayton State University under the scope of the Clayton State University EU GDPR Compliance Policy must comply with the security controls and systems and process requirements and standards of NIST Special Publication 800-171 as set forth in the in the Clayton State Controlled Unclassified Information Policy.

We will not share your information with third parties except:

Data Retention

Clayton State University keeps the data it collects for the time periods specified in the University System of Georgia Records Retention Schedules: https://www.usg.edu/records_management/schedules/.

For examples of Student Records Retention Schedules, see: https://www.usg.edu/records_management/schedules/934.

For examples of Human Resources (Employment) Records Retention Schedules, see: https://www.usg.edu/records_management/schedules/93.