1. Commitment to protecting privacy and transparency
- You are a “Person” or “Data Subject”—meaning a natural person, not a corporation, partnership, or other legal entity—who is physically present in the EEA;
- It is with respect to your “Personal Information”—meaning any information relating to an identified or identifiable person—that is provided while you are physically present in the EEA;
- Such Personal Information is not earlier or later provided to UIAA while you are outside the EEA; and
- Such Personal Information is provided to UIAA:
- During the course of UIAA offering you goods or services; or
- While UIAA is monitoring your behavior.
3. What Personal Information does UIAA process?
UIAA processes the following general categories of Personal Information: names; addresses; telephone numbers; email addresses; identification numbers including but not limited to social security numbers, driver’s license numbers, University identification numbers, and personal identification numbers (PINs); usernames; passwords; demographic information; education history; background check information; personal references; financial information including but not limited to credit and debit card numbers, tax information, and financial aid information; transaction history; business information; passport and visa information; work history; social media URLs; donation history; insurance information; military service; IP addresses; location information; device information; metadata; any requests for accommodations or leave; and other information to support the purposes set forth in Table 1, below.
UIAA requires Personal Information only when necessary. Table 1 identifies the purposes for which UIAA processes Personal Information and the legal basis for each purpose.
In order to fulfill certain of the purposes identified in Table 1, UIAA may need to request special categories of Personal Information—information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data; biometric data for the purpose of uniquely identifying a natural person; data concerning health; or data concerning a natural person’s sex life or sexual orientation.
Before UIAA processes your special category Personal Information or your criminal conviction Personal Information, if any, UIAA will ask for your affirmative consent unless UIAA has another legal basis for the processing, in which case UIAA will inform you of that basis.
Purposes for which UIAA processes Personal Information
|To process Personal Information collected from individuals who contact UIAA: (i) to deal with their inquiries or requests; or (ii) to provide them with news by mail or email about UIAA or any projects, campaigns, programs or events that UIAA may be involved in or how they can support UIAA||Legitimate interests of UIAA – legitimate interest in being able to process Personal Information collected from individuals who contact UIAA|
|To stay connected with University alumni and to provide information about the UIAA and the University||Legitimate interests of UIAA – legitimate interest in communicating unsolicited non-commercial messages|
|To contact individuals regarding UIAA and University events and programs, as well as to offer you products and services due to your affiliation with the University||Consent|
|To host and allow individuals to attend and participate in UIAA events and programs||Performance of a contract or to take steps at the Data Subject’s request prior to entering into a contract|
|To allow individuals to visit UIAA facilities||Legitimate interests of UIAA – legitimate interest in physical security|
|To facilitate networking and mentorship opportunities involving alumni, faculty or staff, non-alumni mentors, and current University students||Legitimate interests of UIAA – legitimate interest in maintaining a positive lifelong relationship with Data Subjects|
|To facilitate the use of volunteers and to evaluate and manage individuals who volunteer to assist UIAA in any capacity, and to perform related activities required to foster and maintain these relationships||Legitimate interests of UIAA – legitimate interest in physical security|
|To conduct direct fundraising marketing by mail, telephone, or electronic message (e.g., email or SMS)||Consent|
|To conduct transactions and business with individuals, such as processing membership dues and other payments made by credit card to UIAA and payments made by UIAA to you||Performance of a contract or to take steps at the Data Subject’s request prior to entering into a contract|
|To facilitate application for and sponsoring of visas to work at UIAA, including all functions necessary to comply with applicable immigration laws||Performance of a contract or to take steps at the Data Subject’s request prior to entering into a contract|
|To respond to a UIAA member’s request regarding Alumni Association records pertaining to that UIAA member||Legitimate interests of UIAA – legitimate interest in maintaining accurate records|
|To respond to an individual’s request for records relating to that individual’s time at UIAA, such as tax documents, employment documents, etc.|
|To engage the services of an independent contractor and all uses incident to that engagement|
|To employ persons to work for UIAA and all uses incident to that engagement including but not limited to evaluation and management of employees and administration of employee benefits|
|To facilitate review and evaluation of UIAA programs by the UIAA, government entities, third-party ranking organizations, and other appropriate bodies||Legitimate interests of UIAA – legitimate interest in maintaining a world-class higher education alumni association for the benefit of the University|
|To promote safety, integrity, and security of UIAA’s information technology systems||Legitimate interests of UIAA – legitimate interest in maintaining IT and network security|
|To protect the UIAA community, including you, and to keep its members safe wherever they are located||Legitimate interests of UIAA – legitimate interest in physical security|
|To report salary data to social security or tax authorities and otherwise comply with applicable EU or Member State laws||Necessary for compliance with a legal obligation|
|To respond to subpoenas, court orders, agency requests, and other legal requests for records relating to an individual’s association with UIAA||Legitimate interest of UIAA – legitimate interest in complying with U.S. and state laws and not being held in contempt of court or having penalties imposed|
4. How does UIAA receive your Personal Information?
UIAA may collect your Personal Information in various ways, for example:
- if you supply Personal Information when using our Website such as signing up to receive more information, entering your data on a form for event registration, and/or asking about volunteer opportunities or other ways you can support us;
- when your Personal Information is shared with UIAA by the University, the University of Illinois Foundation (“UIF”), or the University of Illinois Foundation UK Limited (“UIUK Foundation”);
- when you inquire about making a donation to the UIAA and/or the University or if you agree to make a donation to UIAA;
- when your Personal Information is shared with UIAA by contracted vendors to whom you directly provided information;
- from web tools, cookies, and related technologies; and
- if you provide your details to UIAA for another purpose.
Your Personal Information may be processed by UIAA directors, employees and volunteers as may be necessary to carry out the purposes for processing the information and the activities of UIAA.
UIAA may share your Personal Information with UIF and the UIUK Foundation, which may use the information to assist in raising funds to support the University and its programs. In addition, your Personal Information may be shared with the University, including each component university’s alumni association, which shares our commitment to treating Personal Information responsibly.
UIAA may share your Personal Information with third parties, such as: service providers to facilitate the full range of UIAA functions (e.g., cloud storage, software), vendor partners to connect you with other alumni and current students (e.g., PeopleGrove), and other alumni and friends of the University through the alumni directory, and to offer you products and services due to your affiliation with the University (e.g., alumni travel and financial product opportunities).
UIAA keeps records in accordance with all applicable laws and for purposes of business continuity and in support of anticipated constituent requests. All retained information is stored in a manner designed to ensure its accessibility, integrity, confidentiality, authenticity and legibility.7. What are your rights as a Data Subject?
Right of access
You have the right to request that UIAA confirm whether it is processing your Personal Information. If UIAA is processing your Personal Information, you have the right to access that Personal Information, and UIAA will provide you with a copy of that Personal Information unless prevented by applicable law.
Right to have inaccurate Personal Information corrected
You have the right to request that UIAA correct any inaccurate Personal Information that it maintains about you. You also have the right to request that UIAA complete any incomplete Personal Information that it maintains about you, which could be accomplished by incorporating a supplementary statement that you submit. If UIAA concurs that the Personal Information is incorrect or incomplete, UIAA will promptly correct or complete it.
Right to erasure
You have the right to request the erasure of Personal Information that UIAA maintains about you in certain circumstances. These circumstances are identified in Article 17 of the GDPR and include that the Personal Information is no longer necessary in relation to the purpose(s) for which it was collected.
Right to restriction of processing
You have the right to request that UIAA restrict the processing of your Personal Information where one of the reasons identified in Article 18 of the GDPR apply. These reasons include that the Personal Information is inaccurate, the processing is unlawful, or UIAA no longer needs the Personal Information.
If UIAA grants your request to restrict processing, UIAA will only process that Personal Information with your consent, for the protection of the rights of another natural or legal person, for reasons of important public interest, for the establishment, exercise or defense of legal claims, or as otherwise required by applicable U.S., state, or EU law.
Right to data portability
Where the basis for processing is either consent or performance of a contract between you and UIAA, and where the processing is carried out by automated means, you have the right to receive your Personal Information that you have provided to UIAA. UIAA will provide the Personal Information in a structured, commonly used, and machine-readable format. Where technically feasible and upon your request, UIAA will transmit the Personal Information directly to another entity.
Right to withdraw consent
If the basis for processing your Personal Information is consent, you may revoke your consent at any time. Upon receipt of your notice withdrawing consent, and if there are no other legal grounds for the processing, UIAA will stop processing the Personal Information unless the processing is necessary for the establishment, exercise, or defense of legal claims. Revoking consent does not affect the lawfulness of processing that occurred before the revocation.
Right to object to processing
In certain situations, you may have the right to object to processing of your Personal Information.
- Public Interest or Legitimate Interests. If the basis for processing your Personal Information is public interest or legitimate interests, you have the right to object to processing the Personal Information. UIAA will cease processing unless UIAA demonstrates overriding legitimate grounds for processing or the processing is necessary for the establishment, exercise, or defense of legal claims.
- Direct Marketing. If UIAA is using your Personal Information for direct marketing purposes such as fundraising, you have the right to object at any time, and UIAA will stop using your Personal Information for that purpose.
Right to file a complaint
You have the right to submit a complaint with an EU supervisory authority, in particular the one in the EU Member State of your habitual residence, place of work, or place of the alleged violation, if you believe that UIAA’s processing of your Personal Information violates the GDPR.
For more information on the process for submitting a complaint, consult the relevant EU supervisory authority: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.8. How to exercise your rights
In order to exercise any of these rights, except the right to file a complaint with an EU supervisory authority, you should submit your request to our UIAA data privacy team:
Telephone: +1 217-244-0640
University of Illinois Alumni Association
Alice Campbell Alumni Center
601 S. Lincoln Avenue
Urbana, IL 61801
Attn: GDPR Compliance
At that time, you will be asked to: 1) identify yourself; 2) provide information to support that the GDPR applies to you (see Section 2, above); 3) identify the specific information or data that you are concerned about; and 4) state what right(s) you wish to exercise.
To expedite processing your request, please identify the data collection location (e.g., the website where your Personal Information was collected), if known.9. How does UIAA respond to requests for Personal Information?
In addition to the rights provided by the GDPR, you may also have rights with respect to your Personal Information pursuant to U.S. federal law, state law, or UIAA policy. When you submit a request to UIAA to exercise your rights, UIAA will respond in accordance with existing UIAA policies and procedures that implement the relevant privacy law(s).10. Existence of automated individual decision-making
UIAA, in conjunction with the University and UIF, uses automated decision-making, including profiling, to help identify prospective supporters of the University and its activities. The logic takes an all-factor approach to assessing a possible donor’s propensity to support the University and may result in a prospective donor being contacted to explore support opportunities.
You will not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the decision is necessary for entering into or performing a contract or unless you explicitly consent.11. Transfer of Personal Information outside the EEA
UIAA is based in the U.S. and is subject to U.S. and Illinois law. Personal Information that you provide to UIAA will generally be hosted on U.S. servers. To the extent that UIAA needs to transfer your information either (a) from the EEA to the U.S. or another country or (b) from the U.S. to another country, UIAA will do so on the basis of either (i) an “adequacy decision” by the European Commission; (ii) EU-sanctioned “appropriate safeguards” for transfer such as model clauses, a copy of which you may request, if applicable, by contacting UIAA as set forth in Section 12; (iii) your explicit and informed consent; or (iv) it being necessary for the performance of a contract or the implementation of pre-contractual measures with UIAA, in which case UIAA will inform you of the intent to transfer the Personal Information. Please note that the U.S. is not currently considered a safe harbor country under the GDPR.12. How do I contact the data controller?
Telephone: +1 217-244-0640
University of Illinois Alumni Association
Alice Campbell Alumni Center
601 S. Lincoln Avenue
Urbana, IL 61801
Attn: GDPR Compliance
Last revised: 02/18/2020