Privacy Notice for Alumni, Donors, and Other Supporters
Introduction
This privacy notice describes how The New School collects and processes personal data about you at The New School; how we use, store, transfer, and protect this personal data; and your rights in relation to this personal data. This notice applies to The New School, with global headquarters at 66 West 12th Street, New York, NY 10011 USA, as well as to its affiliated legal entities and branches (collectively “we,” “us,” or “our”):
TNS Parsons (“Parsons Paris”) of 45 rue Saint-Roch, 75001 Paris, France is the European branch of Parsons School of Design. Parsons Paris works closely with our US-based operations and certain information is shared between entities, so for purposes of this privacy notice, both The New School and Parsons Paris are data controllers. For more information on how your information is shared with third parties, please refer to Section 3 of this notice.
This Privacy Notice applies to all personal data we collect or process about you in connection with The New School’s fundraising efforts, alumni relations, and donor outreach (collectively “Institutional Advancement”).
1. Personal data we collect and use
We collect and use certain personal data about you. Personal data is information about you through which you can be identified (including where you can be identified by combining the information with other information).
Note that we may be required by law to collect certain personal data about you, or as a consequence of our contractual relationship with you. Failure to provide this personal data may prevent or delay the fulfilment of these obligations. We will inform you at the time your personal data is collected whether certain data is compulsory and the consequences of the failure to provide such personal data.
1.1 Personal data we collect directly from you
We collect some personal data directly from you. Personal data that is collected directly from you may include the following:
Personal details, such as your name(s), date of birth, and place of birth;
Contact details, such as your phone number, personal email address, mailing address, personal and professional websites, and social media handles;
Demographic details, such as your age, marital status, languages spoken, national origin, and current nationality;
Information about your family, such as name of spouse, names of parents, and associated contact information;
Employment and education information, such as your occupation, job title, name of employer, work history, universities attended, major fields of study, degrees obtained, and graduation year;
Personal and professional announcements, such as awards, recognitions, and honors;
Information about your interests and preferences;
Financial information, such as your bank account or payment card information used for donations;
Photographs for use in identification; and
Communications you send us, such as emails or inquiry forms you submit.
1.2 Personal data generated by us
In addition, the following categories of personal data about you may be generated by The New School in the course of our relationship with you:
Information about your involvement with The New School and other interests, such as your attendance at events, philanthropic interests, and volunteer efforts;
Alumni records and academic information, if applicable, such as information about your major, transcript, degree, and date of graduation;
Photographs and video recordings of university-sponsored events;
Financial information, such as your history of donations; and
Employment details, if you are or were employed by The New School.
1.3 Personal data we obtain from other sources
The New School may also obtain the following categories of personal data about you from third parties:
Financial information, such as wealth information, your personal assets, and information about the value of your home;
Information about your philanthropic interests, activities, and preferences;
Career information, such as employers, dates of employment, and job titles;
Email tracking information;
Photographs of you from social media or other Internet sources; and
Address information.
1.4 Sensitive data we collect and use
Some of the categories of personal data that we collect are considered special categories of personal data under European Union law. In particular, we may process the following types of sensitive data:
Information about your racial or ethnic origin;
Information about your religious or philosophical beliefs;
Information about your gender identity, sex assigned at birth, and preferred pronoun (if you choose to disclose it); and
Health and medical information, such as information about disabilities and related accommodations and food allergies or other dietary restrictions, for purposes of event participation.
2. How we use your personal data and the basis on which we use it
The New School uses your personal data in connection with our Institutional Advancement efforts for the following purposes:
Sending you informational publications, such as newsletters from departments and clubs of interest to you. This processing is necessary to serve our legitimate interests in providing you information you request. Where required by law, we will obtain your consent before sending you electronic marketing communications;
Sending you information about fundraising campaigns, events, and volunteer opportunities that may be of interest to you. We rely on your express consent for this processing, and where required by law, we will obtain your consent to receive electronic marketing communications before sending such communications;
Conducting surveys so that we can learn more about our alumni and other supporters. This processing is necessary to serve our legitimate interests in fundraising, alumni relations, and donor outreach;
Conducting wealth analysis and research to understand your philanthropic interests and your ability to give, in order to tailor our fundraising efforts. This processing is necessary to serve our legitimate interests in fundraising and donor outreach;
Carrying out our contractual obligations to you and exercising our rights in this respect, where applicable (e.g. processing payment card information or issuing tax receipts for payments). Our basis for doing so is the performance of the contract we have with you;
Providing any services or information you request from us, including networking opportunities and ongoing career services. This processing is necessary to serve our legitimate interest in fundraising, alumni relations, and donor outreach;
Research and statistical analysis. This processing is necessary to serve our legitimate interests in understanding alumni and donor interests and improving the effectiveness of our fundraising and outreach efforts;
Publicly acknowledging gifts. We rely on your express consent for this processing;
Preventing and investigating fraud or other unlawful activity. This processing is necessary to serve our legitimate interests in preventing unlawful activity and protecting The New School’s interests;
Meeting the obligations of private organizations with oversight over The New School, such as accreditation organizations. This processing is necessary to serve our legitimate interests in maintaining accreditation;
Managing events and reunions. This processing is necessary to serve our legitimate interest in alumni relations;
Email tracking. This processing is necessary to serve our legitimate interests in gauging the effectiveness of our email communications and marketing campaigns;
Identifying alumni, including for creating an identification card for alumni that includes your photo. This processing is necessary to serve our legitimate interests in keeping our campus and associated facilities safe and secure.
Building profiles of alumni, donors, and prospective donors for internal use. This processing is necessary to serve our legitimate interests in supporting volunteerism, alumni engagement, and fundraising.
Promoting alumni-oriented lectures and presentations, activities, and events using still photography and video recording. This processing is necessary to serve our legitimate interests in supporting volunteerism, alumni engagement, and fundraising.
Operating our information technology systems. This processing is necessary to serve our legitimate interests in supporting your use of the systems, understanding usage and performance of the systems, investigating information security or data integrity incidents, and providing evidence in legal actions;
Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations (such as obligations to document charitable giving for tax purposes) and to serve our legitimate interest in efficient management and administration; and
Complying with legal obligations to which we are subject, including to defend your and our rights in legal proceedings and to cooperate with regulators, law enforcement, and governmental or other competent bodies. This processing is necessary to comply with our legal obligations and to serve our legitimate interests in complying with the laws to which we are subject.
2.1 How we use sensitive data
Information revealing an individual’s racial or ethnic origin. To the extent we process information revealing racial or ethnic origin, such information is voluntarily disclosed for purposes of statistical reporting related to diversity. We rely on your prior consent for such processing.
Information about religious and philosophical beliefs. To the extent that we process information about an individual’s religious and philosophical beliefs, we do so to maintain records of contributions to or activity with religious and political causes or organizations.
Information about an individual’s gender identity, sex assigned at birth, and preferred pronoun. To the extent we process information about an individual’s gender identity, sex assigned at birth, and preferred pronoun, such information is voluntarily disclosed to help us address you in the manner you prefer. We rely on your prior consent for such processing.
Health and medical information. We process health and medical information to comply with obligations under social protection laws (e.g., to provide disability accommodations) or, where not required by law, in reliance on your express consent (e.g., to accommodate the dietary or other needs of our alumni and other supporters).
3. Who has access to your personal data
We treat your personal data with care and confidentiality. Your personal data will be available for the purposes mentioned above and only to employees on a need to know basis and to the extent reasonably necessary to perform their functions. We may share your personal data with third parties under the following circumstances:
Service providers and business partners. We may share your personal data with our service providers and business partners that perform services for us. For example, we may partner with other companies or entities to provide services for you such as processing recurring gifts payments, sending newsletters, maintaining our systems of records, or partnering with us for fundraising or other initiatives.
Other New School alumni. We may share your personal data with other New School alumni, subject to your express consent.
The New School’s global headquarters and branch campuses. The New School’s branch campuses are a part of The New School, whose global headquarters is located in the United States. The branch campuses work closely with our US-based operations and, from time to time, with each other. As a result, we may share certain personal data about you collected or used in the context of Institutional Advancement with other New School personnel located at our main campus in the United States or other branch locations.
Law enforcement agencies, courts, regulators, government authorities, or other third parties. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise protect our rights or the rights of any third party.
Private organizations with oversight over The New School. We may share your personal data to the extent necessary to meet the obligations of private organizations with oversight over The New School, such as accreditation organizations.
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). Please see the section on “International transfer of your data” below for more information.
4. How your personal data is protected and stored
We implement physical, technical, and organizational measures designed to safeguard the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data.
We will retain your personal data for as long as we have a relationship with you (throughout the duration of your studies and in many cases afterwards, as part of the alumni community). Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to:
Maintain alumni and donor records;
Comply with record retention requirements under applicable law;
Defend or bring any existing or potential legal claims; and
Resolve or otherwise address any complaints or queries relating to our programs
5. International transfer of your data
Your personal data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal data under the data protection laws of your locale.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
6. How to exercise your rights
You have certain rights regarding your personal data. You have the right to access personal data The New School holds, and in some situations you have the right to have that personal data corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). You may also object to how The New School uses your personal data if the legal basis for processing that information is our legitimate interest.
Where we are using your personal data on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to register a complaint to the appropriate data protection authority.
If you wish to exercise these rights, or notify us of a change in your details, please visit our Data Subject Access Rights webpage at ispo.newschool.edu/dsar.
7. How to contact us
If you have questions or concerns regarding the way in which your personal data has been used, please contact us at privacyoffice@newschool.edu or:
The New School
Office of Information Security and Privacy
71 Fifth Avenue, 9th Floor
New York, NY 10003 USA
Our representative in the European Union is TNS Parsons, of 45 rue Saint-Roch, 75001 Paris, France.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the appropriate data protection authority:
For Parsons Paris, the supervisory data protection authority is the Commission Nationale de l’Informatique et des Libertes – CNL, 3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07, https://www.cnil.fr/.
8. Changes to the privacy notice
You may request a copy of this Privacy Notice from us using the contact details set out above. We may modify or update this Privacy Notice from time to time.
Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
REVISED NOVEMBER 11, 2020
ADOPTED AUGUST 5, 2020