Data Privacy Notice for Online Students Studying in the E.U.

This Notice describes New York University’s (“NYU”) practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation for purposes of recruiting and evaluating prospective students and those students enrolled online and located in the European Union. This Notice applies to NYU, with global headquarters at 70 Washington Square South, New York, NY 10012, as well as to its affiliated legal entities and branches (collectively “NYU,” “us” or “our”). with respect to prospective students and their families located in the European Union, Iceland, Norway, Liechtenstein, and Switzerland. All such prospective students and their families in the E.U. (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

• Questions
• The Information We Process About You
• Purposes and Legal Basis for Processing Your Data
• Recipients of Your Personal Information
• Transfers to Third Countries
• Data Retention
• Your Rights
• Annex A: NYU Local Data Protection Contacts
• Annex B: National Data Protection Authorities

Questions?

You can contact NYU’s Data Protection Officer with any questions about this notice, our data collection practices, or your rights. You can reach NYU’s Data Protection Officer, Tani Raiford, at:

Tani Raiford
c/o Data Protection Officer’s Office
10 Astor Place, room 502E
New York, NY 10003 
+1 212 998 1180
privacy@nyu.edu 

Contact information for NYU’s local data protection contacts for NYU’s EU Global Sites is provided in Annex A.

This general notice may be supplemented by additional notices at the point of any data collection.  In addition to this notice: 

• NYU’s Annual FERPA Notice provides information about your rights under the Family Educational Rights and Privacy Act
• The NYU Student Health Center Notice of Privacy Practices describes how your health information may be used and disclosed by the Student Health Center
  

If you have specific questions about any of the data processing activities described in this or any other notice, please contact the DPO.

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The Information We Process About You

We process the information we collect from you directly, either during our communications with you about NYU or as part of your application to NYU, including applications for financial aid. In addition to submitting an application directly to us, you may submit an application to certain programs through the Common Application or via other third party sites through which NYU collects prospective student information or financial aid related data.

We also process the information we collect from you directly during our communications with you, when you sign up for classes or other services, when you make use of NYU equipment, facilities, and resources, when you take classes, when you apply for financial aid, when you make use of the Student Health Center, and when you make use of other required or optional services as a member of the NYU community. This includes information about you created by our faculty and staff, like your grades, scores, records of engagement and participation, and recorded observations about you. It also includes information about your payments made to us for tuition and other expenses.

In some cases, we will require that certain information be provided in order for us to provide you with a service or take an action you request. We will indicate when such information is required, and failure to provide required or mandatory information may result in our being unable to provide you with a service or take an action your request.

In some cases, we may use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate your grades or test scores as part of larger processes of determining your eligibility for enrollment in certain programs, receipt of certain academic honors, or to provide you with offers of academic support. Similarly, the information in your financial aid application may be used to generate a profile of your financial circumstances that is used to make decisions about your eligibility for scholarships, loans, and other financial assistance throughout your enrollment at NYU. You can find out more about the logic we use in our automated decision-making processes by contacting the DPO.

In addition, we may collect the following kinds of information about you from third parties:

• Your contact and demographic information, including publicly available information, which we collect from third parties who provide us information about prospective students who may be interested in attending NYU. We may also collect this contact information from students about their parents and family members.  
• Specific personal background and health details, which we may collect from third parties.
• Information we collect from other students or NYU staff: Other students may provide us with information about you, whether in the process of reporting an incident or complaint on campus, alerting us to an emergency situation involving you, or through campus activities. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.
• Information we receive about you from journals, research publications, or other platforms through which you publish academic content.
• Health, wellness, and insurance information about you that we receive from other healthcare providers and/or insurance companies.
• Information about your prior or concurrent educational history, which we collect from other educational institutions, educational agencies such as international credential evaluation services,or from our own records (in the event of a re-enrollment or enrollment for a different degree).

NYU maintains video surveillance and card swipe systems for the security of our premises. NYU or our contracted service operator may process images and video of you, and information about your use of and access to our premises, in connection with the operation of these systems.

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Purposes and Legal Basis for Processing Your Data

We process your Personal Information to operate NYU and the programs you are enrolled in, to provide you with financial aid, and to provide you with additional related services (like housing, internet access, and health services through the Student Health Center and other programs). We also use this data to:

• administer programs and make decisions about course offerings,
• file required reports with applicable governmental authorities,
• award financial aid,
• administer our programs and provide appropriately tailored services, including student health services, financial aid, and research and reporting activities,
• monitor trends within our student body and individual courses, 
• plan course offerings,
• verify identity,
• ensure that the university is prepared for emergencies, 
• enforce NYU policies and applicable laws,
• manage university billing, collecting,
• refunding and cashiering functions,
• provide desktop and software support services,
• provide immigration and mobility services for you when you travel abroad to study or perform research,
• deliver online courses,
• manage admission and enrollment for Global Programs,
• facilitate internal research,
• plan orientation and support services for students,
• perform academic planning for global sites,
• coordinate events such as conferences and professional development, and
• facilitate student directory and promotional activities.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us or that we collect about you.

• We have a legitimate interest in retaining and educating qualified students, complying with laws and regulations that govern our conduct in the countries where we operate, and administering NYU and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes. You can obtain additional information about the legitimate interests we have in processing your information by contacting the DPO.
• During the period of your enrollment, we may also be required to process your Personal Information to complete a contract that you have entered into with us, including to be admitted to a program, or receive financial aid, housing, or another service from us. You can obtain additional information regarding processing we do to enter into contracts with you by contacting the DPO.
• We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as immigration laws or laws that require reporting of personal information to city administration for local registration purposes.
  

You can obtain additional information about the processing we do to comply with applicable laws by contacting the DPO.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so, (ii) because we are required to process the information to comply with applicable laws or (iii) because processing is necessary for the provision of healthcare to you. We may also process sensitive data where necessary to protect your vital interests and you are physically or legally incapable of giving consent, for example, to admit you to the hospital if you are sick or injured and unable to complete the admission information on your own.

You can obtain more information about our processing of Sensitive Personal Information by contacting the DPO. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of conducting scientific, statistical, or historical research or for the purpose of creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.

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Recipients of Your Personal Information

Your Personal Information will be received and processed by NYU employees and personnel, including third parties who provide services to NYU in connection with the purposes of processing described above, and that provide us with technical support for the application process, and provide us with application collection services.

For example, we may disclose your information to service providers who help us make travel arrangements, support our information technology systems, or provide services to our students. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. We provide Personal Information to partner universities for group travel and collaborative events; research partners; printers and mailing houses; the College Board and similar entities, and the National Student Clearinghouse for reporting and enrollment verification purposes. You may contact the DPO to learn more about the categories of service providers to whom your data is disclosed.

We also disclose your information to government authorities as required by laws that regulate higher education, immigration, tax, national security, and criminal activity.

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Transfers to Third Countries

NYU is a global university headquartered in the United States and your data will be transferred to our headquarters when we evaluate your application for enrollment.  Your data may also be shared with other Global Sites if you are participating at a program at that site or otherwise to facilitate central management of NYU’s programs and administer NYU’s global operations. We may also share your medical information with third-party medical providers pursuant to your consent or an an emergency basis.

NYU has executed Standard Contractual Clauses, as approved by the European Commission. These clauses permit NYU to transfer data from the EU to third countries, including the United States. If you would like to receive a copy of NYU’s Standard Contractual Clauses, you can contact the DPO.

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Data Retention

You can find information about how long we retain personal data by consulting our Retention and Destruction of Records Policy.  Certain of our EU Global Sites may retain data for shorter or longer periods to meet local legal requirements or business practices.  You can obtain additional information about any of these retention periods by contacting the DPO.

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• Your Rights

You have the right to the following information regarding NYU’s processing of your Personal Information:

• the purposes of the processing,
• the categories of Personal Information concerned,
• the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
• where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

• The right to request access to the Personal Information that NYU has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
• The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that NYU directly transfer your Personal Information to one or more third parties.
• The right to object to the processing of your Personal Information for marketing and other purposes.
• The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
• The right to lodge a complaint with the supervisory authority for the country where you live or work or where you believe that your rights have been violated. See Annex B for a list of supervisory authority contacts for NYU Global Sites in the EU.

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Annex A: NYU Local Data Protection Contacts

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Annex B: National Data Protection Authorities

This list is provided for your reference, but you may file a complaint with the data protection authority in any Member State where you habitually work, live, or believe an infringement of EU data protection law occurred. You may consult a list of data protection authorities.

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