General Student Privacy Notice Information
At Webster, we may collect personal data from or about you in a number of ways, for example:
- From the information you voluntarily provide to us when you first express an interest in studying at Webster.
- When you voluntarily apply to study at Webster and complete other admissions-related processes and procedures, as well as when you enroll in courses.
- When you voluntarily communicate with us by telephone, email, via other University-approved means of communication, or via our website in order to make inquiries or raise concerns.
- As you interact with us during your time as a student at Webster for the various purposes described in this document.
- From third-party entities who you have requested or authorized to provide information, such as your previous or current school(s), previous or current high school(s) or equivalent, university, or employers, who may provide reference information about you or who may sponsor your studies, as well as other third-party individuals or entities that may provide information about you.
- Information collected through disciplinary and grievance procedures.
- Information collected through the administration of student housing.
- Information collected through surveys and feedback mechanisms.
- Information you may provide to other students when you agree to participate in internal and external research programs.
We may collect the following categories of personal data about you:
- Your name and biographical information such as your address, email address and telephone numbers as well as data that can uniquely identify you in our databases.
- Information about your family or personal circumstances where it is necessary to do so.
- Information relating to your education and employment history, school(s), previous or current high school(s) or equivalent, and other colleges or universities you have attended, the places where you have worked, the courses you have completed, dates of study, and examination results, including information relating to assessments of your work, details of examinations taken, your predicted and actual examination grades, information regarding academic and extracurricular interests, and other student record-related information.
- Records related to your use of our facilities and services.
- Photographs from events and CCTV footage.
- Information about your involvement, activities, and awards.
- Financial information including tuition, fees, donations, scholarships, etc.
- Sensitive (Special category) personal data, where necessary, including:
- Information about criminal convictions and offences.
- Information about your physical and mental health and medical conditions (e.g. disability accommodation, special educational support measures and dietary needs)
- Information about your racial or national origin, religious or similar beliefs, or sexual orientation.
We may use your personal data (including special category personal data) we collect from and about you during your association with us for the following purposes:
- Recruit and/or admit you as a student at Webster.
- Facilitate academic matters, including for:
- The provision of our core teaching, learning, and research services (e.g. registration, assessment, attendance, managing progress, academic misconduct investigations, certification, and graduation).
- Maintaining student records.
- Assessing your eligibility for bursaries and scholarships.
- Provide library, IT, media, and other information services.
- Provide support of our core services in non-academic matters, including:
- Providing support of our core student services in non-academic matters.
- Monitoring of equal opportunities.
- Safeguarding and promotion of students’ welfare.
- Ensuring students’ safety and security.
- Managing student employment, assistantships, and internships.
- Managing student accommodations.
- Managing the use of social media.
- Managing facilities on campus, including parking.
- Administer finances such as fees, scholarships, federal and state grants, or financial aid.
- Provide other administrative functions, such as:
- Carrying out research and statistical analysis.
- Carrying out audits to ensure compliance with our regulatory and legal obligations.
- Providing operational information.
- Promoting our services.
- Preventing and detecting crime.
- Dealing with grievances and disciplinary actions.
- Dealing with complaints and inquiries.
- Provide for archiving and statistical purposes.
We process your personal data because it is necessary for the execution of a contract with you or in preparation for a contract or service you have requested, including to interact with you before you are enrolled as a student, as part of the admissions process such as sending a brochure or answering inquiries about courses:
- To provide you with services as outlined in our various policies.
- Address any concerns or feedback you may have.
- Facilitate any other purpose for which you provide us with your Personal Information.
We also process your personal data where it is necessary for our legitimate interests. In this respect, we may use your personal data for any of the following:
- To provide you with educational services which may not be set out in our Student Code of Conduct or our Extended Campus Code of Conduct, but which are nevertheless a part of our academic and educational mission.
- To monitor and evaluate the performance and effectiveness of the university, including by training our employees or monitoring their performance.
- To maintain and improve the academic, corporate, financial, and human resource management of the University.
- To promote equality and diversity throughout the University.
- To seek advice on our legal rights and obligations and to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other students or faculty, visitors to the University, or anyone else who could be harmed by such activities.
- To perform our duties in carrying out our mission, vision, and values; our Strategic Plan; and our Policies and Community.
We also process your personal data where we are required to do so by law and for the purposes of achieving and maintaining compliance with our legal obligations. In this respect, we may also use your personal data for the following:
- For the prevention and detection of crime.
- In order to assist with investigations (including criminal investigations) carried out by the police and other responsible authorities.
We also may process your personal data where:
- It is necessary for emergency medical purposes.
- It is necessary to protect your or another person’s vital interests.
- We have your specific or, where necessary, explicit consent to do so.
Where it is necessary to do so, we may share the minimum personal data necessary to carefully evaluated third party organizations or entities who help us to provide our essential educational services. Our third parties operate under a formal data processing contract designed to preserve and safeguard your rights over the processing of your personal data and ensure that your data is only processed by third-parties for limited purposes in accordance with our instructions.
We do not sell or rent your personal data.
We are not responsible for the privacy practices of third parties with whom we do not partner, nor can we endorse or take any responsibility for all the privacy practices or policies of our relationship partners. You are advised to check the privacy practices and policies of each third party with whom you independently choose to share your personal data.
Third party recipients may include:
- Our affiliates and contractors where there is a legitimate reason for their receiving
the information, including:
- Third parties who work with us to provide student accommodation.
- Third parties who work with us to provide student support services (i.e. counseling, health services, etc.).
- Third parties who are contracted to provide services such as IT, security, and staffing.
- Organizations operating software on our behalf, and
- Internal and external auditors.
- Those with an interest in tracking student progreee and attendance including:
- Student sponsors (scholarship or other donors).
- Current or potential education product and service providers.
- Current or potential employers (to provide references and, where students are sponsored by their employer and/or where you take part in a placement, to provide details of academic progress, involvement in institutional activities and attendance ).
- Professional and regulatory bodies in relation to the confirmation of qualifications, professional registration and conduct, and the accreditation of courses.
- Governmental departments and agencies where we have a legal obligation to provide information.
- Crime prevention or detection agencies.
- Parents, guardians, emergency contacts and next-of-kin (where there is a legitimate reason for disclosure).
- Third party communication and data services providers.
- Third parties engaged to plan and hold annual commencement and graduation ceremonies,
including to:
- Facilitate the ceremony (local newspapers, commemorative clothing providers, photographers, caterers, etc.).
- Preparing the commencement booklet.
- Promoting and archiving the ceremony on our website.
- Third party organizations contracted to perform surveys on our behalf.
In some cases, you will be asked to opt into these data sharing arrangements. In those cases, you should carefully consider the possible impact that not opting in will have on provision of our core teaching, learning, and research services to you. If you do not wish to participate in any of the surveys, please inform your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document.
There may be occasions when we transfer your data overseas, for example, if we communicate with you using a cloud based service provider or use software that stores data outside of the EU, EEA and Switzerland. We also may need to process your personal data for managing scholarships and study programs that take place overseas, or when we are reporting to overseas establishments such as those offering international opportunities. Such transfers will only take place if one of the following applies:
- The country receiving the data is considered by the EU/EEA/Switzerland to provide an adequate level of data protection.
- The transfer is governed by approved contractual clauses.
- You have given your consent to the transfer.
- The transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract.
- The transfer is necessary for the performance of a contract with another person, which is in your interests.
- The transfer is necessary in order to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent.
- The transfer is necessary for the exercise of legal claims; or
- The transfer is necessary for important reasons of public interest.
We may display your University email address on our websites, which are accessible to internet users, including those in countries overseas.
Please tell us promptly about any changes to the personal data you have voluntarily provided to us. This is particularly important with respect to your contact details. If you are a current student, you may do this through Connections Portal login on the University's website. Otherwise please contact your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document.
We will retain your personal data for as long as necessary to meet the uses described in the “How Webster Uses Current and Prospective Student Information” and in compliance with legal, statutory and regulatory document retention obligations. Where you have exercised one of the rights listed below with respect to erasure of your personal data, we may need to retain your personal data for an overriding purpose if the information is necessary for complying with a legal obligation, or for the performance of a task carried out in the public interest, for archiving purposes in the public interest, for scientific or historical research purposes, for statistical purposes, or for the establishment, exercise, or defense of legal claims.
Under the General Data Protection Regulations (GDPR), you have the following rights:
- To obtain access to the personal data that we hold about you.
- To object to processing on grounds relating to your personal data where you feel processing by us has a disproportionate impact on your interests, rights, and freedoms.
- If you believe that your personal data is, or has become, incorrect or is incomplete, you may request to review, revise, correct, or update any of the personal data we may hold about you free of charge.
- To restrict the processing activities related to your personal data (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal).
- To request that we erase your personal data.
- To have personal data, which you have voluntarily provided to us, produced in a structured, commonly used, and machine-readable format, including for the purpose of transmitting it to another party.
- To require us not to send you marketing communications. (See information on the California Consumer Privacy Act (CCPA) below.
Please note that the individual rights described are not absolute, and we may be entitled to refuse requests where certain exceptions apply. If you have given your consent and you wish to withdraw it, please contact your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
If you have any questions about your rights regarding your personal data, or wish to exercise any of the rights granted to you, please simply write to us at the postal address or contact your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document.
Webster University is committed to answering your questions, resolving complaints about your privacy and our processing of your personal data. If you have an inquiry or complaint regarding this Privacy Notice, you should first contact privacy@webster.edu. In the event that a resolution cannot be reached, you may also contact your local data protection authority which may investigate your complaint further.
Austria
Österreichische Datenschutzbehörde
Wickenburggasse 8
1080 Vienna
Austria / Europe
The Netherlands
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
Switzerland
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH - 3003 Berne
Greece
Data Protection Authority Offices
Kifissias 1-3,
115 23 Athens,
Greece
This Privacy Notice is not directed to “children,” as defined per EU Member State and international privacy legislation, and we do not seek, nor do we knowingly process, personal data relating to children. Where a prospective or current student is classified as a child in the geographic locations in which we operate, we will make reasonable efforts to verify that consent is given or authorized by the holder of parental responsibility over the child, where personal data of the child is to be processed.
Webster takes reasonable and appropriate organizational and technical security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
Webster reserves the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of our policies and this Privacy Notice at any time, consistent with the requirements of applicable law. When we do, we will post the revision(s) on our website. If we change the Privacy Notice in a material way, we will provide appropriate notice to you. The “Effective Date” at the top of this Privacy Notice reflects the date of the most recent revisions.
If you have questions about our University Privacy Statement, this Privacy Notice, our privacy practices, or any other aspect of your privacy and the security of your Personal Information, please contact your Privacy Manager or our Office of Privacy by phone or email using the contact details provided below.
Edna Schick-Bodrič
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 12 699 293 4334
edna.schick-bodric@webster.ac.at / privacy@webster.edu
Ellie Despotaki
Ipitou Str. No 9, Athens 105 57, Greece
Tel. +30 211 990 5302
despotakie@webster.edu / privacy@webster.edu
Allison Snowden
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 1 269 9293 4324
allison.snowden@webster.ac.at
Mr. Michel Pollak
15, Route de Collex, 1293 Bellevue, Switzerland
Tel. +41 22 959 80 03
michelpollak74@webster.edu
Chris (Mac) McDonnell
Boommarkt 1, 2311 EA Leiden, The Netherlands
Tel. +31 71 516 8000 x4526
mcdonnell16@webster.edu
9 Ipitou St., Athens 105 57, Greece
Tel. +30 211 990 5302
privacy@webster.edu
Gaga Gvenetadze
82 I. Chavchavadze Avenue, Tbilisi 0612, Georgia
Tel. +995 598 389 037
gagagvenetadze@webster.edu
Shakhnoza Kholmatova
13 Alisher Navoiy Str., Tashkent 100011, Uzbekistan
Tel. +998 55 503 0066
shakhnozakholmatova@webster.edu