Policy Author:
Office of Information Technology
Responsible Office – Department:
Office of Information Technology
Effective Date of Policy:
August 20, 2022. Updated May 2023
Daemen University is committed to protecting the privacy of information and data that may be used to identify you (your “personal information”). This policy describes practices regarding the ways we may collect, use, disclose, or otherwise process your personal information.
Information We Collect and How We May Use Your Personal Information
Personal Information Collected from Applicants and Prospective Students
Daemen University collects and uses personal information about applicants and other prospective students, including students interested in our summer programs (referred to here as “applicants”). If you are or have been an applicant, we may collect and use the following types of personal information about you:
- Information and supporting documentation that you provide in your application, including through third parties, such as The Common Application,
- Related application materials (e.g., recommendation letters, references, and applicable test scores),
- Information that you have permitted a third party, such as The College Board, to release (e.g., AP or SAT scores, demographic information, family information, and academic information),
- Contact information for prospective students that we receive from other institutions and from vendors who conduct advertising activities for us,
- Financial information, including financial information about your family members (e.g., information collected in connection with applications for financial aid, loans, and scholarships), and
- Survey responses if you respond to a survey sent by us or on our behalf.
How We May Use Your Personal Information
Your personal information is used to evaluate your application and related activities, such as assessing requests for financial aid, communicating with you about your application, and other administrative functions related to the admissions and enrollment process. We may also use or disclose your personal information for the following purposes:
- To consider requests for accommodations,
- For research, reporting, and statistical purposes,
- To provide you with information about Daemen University and events that you might be interested in attending,
- To send surveys for research purposes,
- For compliance with legal obligations, to respond to subpoenas, court orders, or other legal processes, and to enforce our agreements,
- To prevent or investigate fraud or other unlawful activity and to protect the security of Daemen University’s property, websites, and other systems,
- To meet the obligations of private organizations with oversight over Daemen University, such as accreditation organizations, and
- To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.
How We May Share Your Information
We may share your information with the following individuals and entities:
- Individuals who assist in the application process, such as faculty and outside consultants,
- Other departments within Daemen University, including our Institutional Advancement office,
- Your financial institutions and funders (e.g., as necessary for obtaining loans, scholarships, or other funding),
- Other educational institutions (e.g., to send you information about jointly hosted informational events),
- Vendors who provide services to Daemen University,
- Governmental bodies as necessary for compliance with the law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights, and
- Private organizations with oversight over Daemen University, such as accreditation organizations.
Legal Basis for Processing (for personal information subject to the General Data Protection Regulation (“GDPR”)
Concerning personal information subject to the GDPR, we rely on the following lawful bases for processing:
- Our legitimate interests, such as conducting our admissions activities,
- To provide you with services or perform contractual obligations, such as processing your application for admission,
- For compliance with University legal obligations
- When necessary for scientific or historical research or statistical purposes, and
- With your consent, when applicable.
Personal Information Collected From Students, Faculty, and Staff
When you are a student at Daemen or a member or prospective faculty and staff member, we maintain records containing your personal information. We may collect and use the following types of personal information about you, as applicable:
- Your contact information and biographical data (e.g., name, address, date of birth, race, ethnicity, family information),
- Application materials and supporting documents (e.g., applications for admission or employment),
- Copies of identification documents and other official documents (e.g., driver’s license, I-9 form, passport/visa information),
- Employment and/or educational records (e.g., job history, job reviews, transcript information),
- Academic work product and related information (e.g., research and course-related content),
- Records about your other activities (e.g., involvement in clubs, disciplinary actions, and similar incidents),
- Financial information (e.g., payroll information, information related to tuition payments),
- Information about technology usage (e.g., software downloads to ensure student status for specific software titles), and
- Health information. Most health information about students is stored in the Counseling, Health, Insurance, and Prevention (CHIP) Center records to provide you with health care services. However, some are stored in other locations, such as our Accessibility and Disability Resources Office. Employee health information relevant to the role and/or reasonable accommodation process is kept in a confidential file in the Employee Engagement Office.
How We May Use Your Personal Information
We use this information for the following purposes as applicable:
- To provide educational, employment, and/or related services (e.g., maintaining relevant academic records or employment, providing access to university facilities and support services, such as counseling and library services),
- To administer the financial aspects of the relationship (e.g., payroll, collecting tuition, coordinating with lenders or other funders),
- To enable your participation at events and in other opportunities (e.g., graduation, study abroad programs, athletics, internships),
- To protect the educational integrity of the school (e.g., disciplinary actions),
- To accommodate special needs (e.g., disability accommodations),
- For research and statistical purposes related to our educational and/or other services,
- To provide basic contact information in student, faculty, and/or staff directories,
- For the general operations of the university and related administrative functions,
- For compliance with legal obligations, to respond to subpoenas, court orders, or other legal processes, and to enforce our agreements,
- To prevent or investigate fraud or other unlawful activity and to protect the security of the University’s property, website, and other systems,
- To meet the obligations of private organizations with oversight over Daemen University, such as accreditation organizations, and
- To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.
How We May Share Your Personal Information
We may share your personal information with the following:
- Faculty and staff at Daemen University, to fulfill their responsibilities,
- Your lenders, funders, and/or other sponsors,
- Providers of any external program, such as study abroad programs, internships, and other collaborations,
- Your host institution and host family (in connection with study abroad or faculty or student exchange programs),
- Student clubs and related organizations,
- Other departments within Daemen University, including our fundraising offices,
- Individuals or entities inquiring about your attendance or employment history. We will require your written authorization before attendance or employment history information is shared,
- Vendors who provide services to Daemen University,
- Governmental bodies as necessary for compliance with the law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights, and
- Private organizations with oversight over Daemen University, such as accreditation organizations.
Legal Basis for Processing of personal information subject to the GDPR
Concerning personal information subject to the GDPR, we rely on the following lawful bases for processing:
- Our legitimate interests or those of third parties (e.g., evaluating candidates for admissions, financial aid, housing, and/or maintaining a community for alumni), such as fulfilling our educational mission,
- To provide you with services or perform on contractual obligations, such as providing you with educational services or managing your employment relationship,
- To improve the student experience and welfare while studying at Daemen University,
- For the performance of tasks we carry out in the public interest, such as teaching and research,
- For compliance with our legal obligations,
- When necessary for scientific or historical research or statistical purposes, and
- With your consent, when applicable.
Daemen University requires you to provide us with any information we reasonably request to enable us to administer our relationship with you. If we require your consent for any specific use of your personal information, we will collect it at the appropriate time, and you can withdraw consent where applicable.
For Alumni, Donors, and Friends of Daemen University
Personal Information We May Collect
Daemen University holds personal information about its alumni and other supporters (such as donors, prospective donors, volunteers, and family members of students). If you are an alumnus or another supporter, we may collect and use the following types of personal information about you:
- Academic information (e.g., major, transcript, degree),
- Biographical information (e.g., name (preferred name), date of birth, ethnicity, sexual orientation, religious affiliation),
- Contact information (e.g., email address, phone number),
- Your activities while at our institution (e.g., club memberships),
- Your involvement with the university and other interests (e.g., attendance at events, philanthropic interests),
- Family information (e.g., marital status, name of spouse),
- Health information (e.g., disability, food allergies),
- Financial information (e.g., history of donations, wealth information), and
- Employment information.
We collect data about alumni and other supporters from various sources, including directly from the individual (for example, by filling out a form on our website) and from other individuals (for example, students provide information about family members). We also retain information from your student records if you studied here. We also collect information from publicly available sources, such as social media, and from third parties, such as companies that conduct wealth screening or other people that might know you and your philanthropic interests.
How We Use Your Personal Information
Your personal information is used for the following purposes:
- Sending you informational publications (e.g., Daemen Voice, newsletters from departments and clubs you may have an interest in),
- Conducting surveys so that we can learn more about our alumni and other supporters,
- Sending you information about fundraising campaigns, events, and volunteer opportunities that may be of interest to you,
- Conducting wealth analysis and research to understand your philanthropic interests and ability to give to ensure that our fundraising efforts are tailored to your interests,
- For administrative purposes (e.g., processing donations and issuing a tax receipt, managing events, such as reunions),
- For research and statistical purposes,
- To publicly acknowledge gifts (with the consent of the donor),
- For compliance with legal obligations, to respond to subpoenas, court orders, or other legal processes, and to enforce our agreements,
- To prevent or investigate fraud or other unlawful activity and to protect the security of University property, website, and other systems,
- To meet the obligations of private organizations with oversight over Daemen University, such as accreditation organizations, and
- To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.
How We May Share Your Personal Information
We share your personal information with the following:
- Academic departments, clubs, and interest groups,
- Other University alumni (limited contact information only)
- The Alumni Association, specific alumni clubs, organizations, and similar affiliates,
- Other individuals or entities with a legitimate interest in your personal information, such as scholarship supporters,
- Vendors who provide services to Daemen University,
- Governmental bodies as necessary for compliance with the law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights, and
- Private organizations with oversight over Daemen University, such as accreditation organizations.
Legal Basis for Processing (for personal information subject to the GDPR)
Concerning personal information subject to the GDPR, we rely on the following lawful bases for processing:
- Our legitimate interests, such as maintaining alumni relationships and conducting fundraising activities,
- To provide you with services or perform on contractual obligations, such as providing certain alumni services,
- For compliance with our legal obligations,
- When necessary for scientific or historical research or statistical purposes, and
- With your consent, when applicable.
Website Visitors
Personal Information We May Collect
The Daemen University website is an information system intended to present many audiences with an integrated view of the University. If you visit this site to view or download information or submit information to us, our third-party vendors or we may automatically collect the following types of personal information:
- The name of the domain from which you access the Internet,
- The date and time of your visit,
- The page/s you visit, and
- Your computing platform and operating system.
Some of this information may be collected through cookies, text files placed on your device by a web server, or similar technologies, such as web beacons. Some of these cookies are managed by third parties that we do not control, such as Google Analytics. You can accept or decline cookies by changing your browser settings. If you choose to decline cookies, some features on our website may not work properly.
If you use our website to complete forms, use our applications, or submit information to us (such as through our alumni and supplier registration pages), we will collect the information that you provide to us, as well as related information, such as your login ID.
How We May Use Your Personal Information
The data collected with cookies and similar technologies are used in the aggregate to analyze site traffic, manage the website, and provide accountability regarding our work’s usefulness.
If you provide us with information through our alumni and supplier registration pages, we will use that information for the purposes described on the form or registration pages.
We may also use your personal information for the following purposes:
- For compliance with legal obligations, to respond to subpoenas, court orders, or other legal processes, and to enforce our agreements,
- To prevent or investigate fraud or other unlawful activity and to protect the security of Daemen University’s property, website, and other systems,
- To meet the obligations of private organizations with oversight over Daemen University, such as accreditation organizations, and
- To protect the health, safety, or rights of you, other students, faculty, staff, and visitors.
How We May Share Your Personal Information
Personal information collected automatically on our website may be disclosed to third parties when the third party is an institutionally authorized provider of services to the University. Information collected through website forms is used as specified or as described in this policy.
Our website contains links to many sites that are beyond our control. The University is not responsible for these other sites’ privacy practices or content. Users of these services are subject to the privacy policies established by the third-party provider.
Legal Basis for Processing (for personal information subject to the GDPR)
Concerning personal information subject to the GDPR, we rely on the following lawful bases for processing:
- Our legitimate interests, such as monitoring our website usage,
- To provide you with services or perform on contractual obligations, such as managing our relationships with our suppliers and alumni,
- For compliance with our legal obligations, and
- With your consent, when applicable.
Transfer of Information to the United States
Daemen University is located in the United States. Daemen University will process the information we collect from you in the United States. Daemen may also transfer your personal information to third parties, including our vendors, as described in this notice, that may be located outside the European Economic Area (“EEA”).
The United States has not sought nor received a finding of “adequacy” from the EEA, which means that the data protection laws in the United States may not offer you the same protections as in the country where you reside when personal information is collected. Concerning transfers outside the EEA, Daemen generally relies on derogations for specific situations. In some circumstances, Daemen may enter into standard contractual clauses governing the import or export of personal information or rely on your consent. In all cases, Daemen University endeavors to apply suitable safeguards to protect the privacy and security of your personal information, particularly sensitive data, and to use it in a manner consistent with this Privacy and Cookie Policy.
Retention of Data
Daemen University retains student personal information indefinitely for academic record-keeping, alumni data, and archiving purposes. The applicable Daemen University record retention and destruction policy retains additional student information.
Alumni Communications from Daemen University
Daemen University and the Daemen University Alumni Association periodically send marketing communications to alumni, supporters, and other members of the Daemen community, such as newsletters, event invitations, and fundraising information. If you would like to request that Daemen University or the Daemen University Alumni Association limit or stop these marketing communications with you, please contact us at privacy@daemen.edu. If you request to be removed from our mailing lists, we will retain your contact information to ensure that we do not continue to contact you for these purposes. If applicable, we will continue to process your personal information for other purposes consistent with this policy.
Individual Rights
If you are located in the EEA, you may have the following legal rights under applicable law concerning the personal information processed by Daemen University:
- To withdraw consent at any time if we are processing your personal information based on consent,
- To access the information that Daemen has about you,
- To request that Daemen rectify or erase your information,
- To request that Daemen restrict the way it uses your information,
- To object to the way Daemen uses your information,
- To ask Daemen to transfer your information to someone else, and
- To complain with a data protection authority in the EEA.
Daemen University’s ability or obligation to comply with your requests may be limited by applicable law.
To request to exercise one of these rights, please contact us at privacy@daemen.edu.
For Current Students
The Family Education Rights Privacy Act (FERPA) generally bars the release of educational records to third parties without the current or former student’s written consent. For more information, click on the links below:
Authorization Form to Release Educational Record Information Former Student
Under the provisions of the Family Educational Rights and Privacy Act of 1974, you have the right to withhold the disclosure of any or all of the categories of Directory Information. Please carefully consider the consequences of any decision by you to withhold any category of Directory Information. Should you decide to inform the University not to release any or all Directory Information, any future requests from non-institutional persons or organizations will be refused.
For more information, click on the link below:
Non Disclosure of Directory Information Form
Changes to this Privacy and Cookie Policy
Daemen University reserves the right to amend this Privacy and Cookie Policy for Personal Data at any time, for any reason, without notice. Any changes will be published here, and you should check our website to access our current Privacy and Cookie Policy for Personal Data. This policy was last updated in May 2023.
Contact Information
The controller of the personal information described in this Privacy and Cookie Policy is:
Daemen University
4380 Main Street
Amherst, NY 14226
Email: privacy@daemen.edu
Questions, concerns, requests, or complaints regarding this policy and the processing of personal information should be directed to privacy@daemen.edu.