Hobart and William Smith Colleges

PRIVACY NOTICE FOR EU STUDENTS AND REQUEST FOR CONSENT FOR PROCESSING

Pursuant to the provisions of Regulation (EU) 2016/679 (the “GDPR”), this notice is to provide you with information about the processing of the personal data of students Hobart and William Smith Colleges (the “HWS”). HWS collects personal data about students in a variety of ways and for a variety of reasons. For example, we may collect personal data from you when you register for classes or apply for financial aid. In each case, HWS’s use of personal data will comply with the provisions of this Notice.

• The Data Controller is HWS. You may contact the colleges with any questions about this Notice by contacting the Office of the Registrar (registrar@hws.edu).
• All personal data will be processed exclusively for HWS’s legitimate interests connected or related to providing education, financial aid, housing and related services to each student that provides personal data. In some cases, we may process personal data you provide to fulfill our contractual obligations to you, for example if you purchase books or event tickets from HWS. We may also process student personal data to fulfill our obligations established by applicable law and regulation.
• Personal data may include special categories of personal data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or the person’s gender identification. HWS will process special categories of personal data only with your explicit consent for the following purposes: in connection with the provision of primary or ancillary educational services, to provide student health services, financial aid packaging and services, athletic participation (including sports medicine services), club and miscellaneous student activities participation, volunteer opportunities and co-curricular opportunities including but not limited to study abroad opportunities, career services activities, or community engagement activities, course registration, and required reporting to clearinghouses or to comply with any and all legal requirements.
• Your personal data will be handled by employees, contractors and agents of HWS that are responsible for activities related to the purposes specified above. HWS may also provide your personal data to its service providers performing services on our behalf relating to the specified purposes, such as our hosting service providers, and to public or private entities as may be necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process, and to enforce our rights or protect our property.
• The personal data you have provided may be transferred to the United States of America pursuant to the terms, conditions and limits specified by Chapter V of the GDPR.
• HWS will store your personal data for as long as necessary to fulfill the original purpose for which it was provided and to meet its legal and regulatory obligations, and in compliance with HWS’s document retention policy.
• You have the right under the GDPR to request from HWS access, rectification and erasure of your personal data, to request a copy of your personal data, to request that HWS restrict the processing of your personal data and to object to the processing of your personal data.
• You can withdraw your consent to the processing of special categories of personal data, the processing of which by HWS is based on your explicit consent, at any time by contacting the Office of the Registrar at registrar@hws.edu, but this will not affect the lawfulness of processing your personal data based on your consent before withdrawal. If you withdraw your consent, we may not be able to provide certain services to you.
• You have the right to lodge a complaint with a supervisory authority.
• Submittal and processing of personal data is necessary in order to achieve the purposes specified above. Failure to provide such personal data will make it impossible for HWS to carry out the necessary activities to achieve the specified purposes.

ACKNOWLEDGEMENT OF CONSENT

Those who consent to this policy:

• Consent to the use of personal data for the purposes outlined in this notice.
• Consent for personal data (including health data) to be transferred to the United States of America, even if the EU authorities have not deemed the United States of America to provide an adequate level of protection for personal data;
• Consent to the use of special categories of personal data for the purpose of processing my application and engaging in the related purposes specified in this notice, which may include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or gender identification.
• Consent to waive any right to privacy or confidentiality regarding HWS’s reporting to the appropriate authorities if I am seriously ill; suffer an injury; am the victim or perpetrator of harassment, whether on or off campus; am the victim or the perpetrator of sexual or gender-based misconduct and/or of criminal behavior, whether on or off campus, and I grant HWS staff, faculty and administrators full authority to report to the appropriate authorities any and such all incidents, under the applicable laws (including but not limited to Title IX and Clery Act), whether or not it involves disciplinary action.