Policy Area: IT Policy Library
Approved Date: May 31, 2024
Approved By: Chief Information Officer
Effective Date: July 1, 2024
Current Version: 1.1
I. Overview
Virginia Union University will collect personal information about its employees and other constituents for various purposes, primarily relating to establishing and managing the employment, academic, or other institutional relationship between Virginia Union University and its human resources, students, and other affiliates. Virginia Union University shall identify the purposes for which personal information is collected at or before the time the information is collected.
The University may also collect personal information from other sources, including previous employers, work associates, personal references, or other third parties to whom the individual has given permission to disclose the information.
II. Purpose
Virginia Union University has a responsibility to inform employees, students, prospective students, and other constituents of the policies and practices for the management of personal information, and will make these policies and practices understandable and easily available.
III. Scope
Consent requirements may vary depending upon circumstances and upon the type of personal information that Virginia Union University intends to collect, use, or disclose. When determining whether an individual's consent is required, Virginia Union University will consider both the sensitivity of the personal information and the purposes for which Virginia Union University will use the information. If consent is required, Virginia Union University will determine the form of consent that is appropriate. Consent may be expressed, implied, or deemed, and may be obtained in person, by phone, by fax, by mail, by email, or via the Internet.
Subject to our legal rights and obligations, Virginia Union University may, from time to time, seek an individual's consent to collect, use, or disclose personal information for a new purpose.
IV. Policy
The collection of personal information will be limited to the amount and type of information required specifically for an identified purpose. Virginia Union University shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or if the use or disclosure is authorized by law.
Personal information collected in one business unit of Virginia Union University may be shared with other business units of Virginia Union University for the purposes as identified above. Virginia Union University may disclose personal information about its employees for human resources and benefits administration and in the context of providing references regarding current or former employees in response to requests from prospective employers.
Virginia Union University will compile and disclose certain information about employees to a limited number of third parties and those we are obliged to inform by law to administer staffing, compensation, and benefits programs.
Although the University will protect and limit the use of personal information about employees that is disclosed to third parties, Virginia Union University is not responsible for the subsequent uses or disclosure of the subject personal information by the third-party recipient, such as government agencies.
Virginia Union University takes appropriate steps to ensure that personal information is accurate, complete, and up to date to minimize the possibility that inaccurate personal information is used to make a decision about an individual.
Virginia Union University will provide adequate safeguard practices to ensure the security of personal information, protect the information against loss or theft, and safeguard the information from unauthorized access, disclosure, copying, use, or modification.
Only Virginia Union University employees with a business need to know, or whose duties so require, are granted access to personal information about Virginia Union University constituents.
Personal information is kept as long as necessary to satisfy the purposes. Personal information that has been used to decide about an individual shall be retained for a reasonable period, which will permit the individual to access the personal information after the decision has been made.
Files containing personal information are business records and, as such, property of Virginia Union University. Subject to Virginia Union University's legal rights and obligations, Virginia Union University shall, upon receipt of a written request, inform the individual of the existence, use, and disclosure of his or her personal information and shall, subject to reasonable limitations, permit the individual access to that information. Virginia Union University will respond to a request to access personal information within a reasonable time.
Personal information contained in business records may not be edited or removed except as follows:
Individuals can seek access to their personal information by sending a written request to the Human Resources Department.
V. Disclosure and Portability of Personally Identifiable Information (PII)
Virginia Union University is committed to the transparent, lawful, and responsible management of personally identifiable information (PII). This section describes the circumstances under which PII may be disclosed, the rights individuals have with respect to their data, and the mechanisms available for requesting access to or transfer of that data.
A. Disclosure to Third Parties
Virginia Union University may disclose PII to third-party vendors, contractors, and service providers who are engaged to perform functions or services on behalf of the University. Any such third party is required to maintain the confidentiality, integrity, and availability of the information transmitted and may not use PII for any purpose other than providing the contracted service. Categories of third parties to whom PII may be disclosed include:
Virginia Union University does not sell personally identifiable information to third parties and has not done so in the past twelve (12) months. Where PII is shared with a contracted entity, it is done solely to perform a defined institutional business purpose.
B. Disclosure Required By Law
Virginia Union University may disclose PII in response to valid legal processes, including but not limited to a court order, subpoena, search warrant, or other lawfully issued legal instrument. The University may also disclose PII to law enforcement or other governmental authorities where the University believes such disclosure is necessary to:
Disclosure under legal compulsion does not constitute a waiver of the University's data protection obligations, and the University will take reasonable steps to notify affected individuals of any such disclosure to the extent permitted by applicable law.
C. Individual Rights: Access and Data Portability
Virginia Union University recognizes and supports the rights of individuals to access, correct, and, where applicable, receive a portable copy of their personal information. Upon written request, the University will:
Requests to access or receive a portable copy of personal information should be submitted in writing to the Office of Human Resources or the Office of the Registrar, as appropriate. The University will respond to such requests within a reasonable timeframe, generally not to exceed thirty (30) calendar days, except where the request is complex or involves large volumes of records, in which case the University will notify the individual of any anticipated delay.
No fee will be charged for a data access or portability request unless the request is manifestly unfounded, repetitive, or excessive, in which case a reasonable administrative fee may be assessed.
D. Right to Opt Out
Individuals who do not wish to receive non-essential communications from Virginia Union University (including marketing, recruitment, or promotional correspondence) may request removal from applicable mailing or contact lists by submitting a written request to the Office of Communications or the Office of the Registrar. Opting out of non-essential communications will not affect the University's ability to send required academic, financial, or administrative notices.
VI. Privacy Statement
This Privacy Statement governs the collection, use, and protection of personal information across all Virginia Union University websites, systems, and institutional operations. It applies to current employees and faculty, enrolled students, prospective students, alumni, and other visitors or constituents who interact with the University. Virginia Union University is committed to maintaining the privacy and security of all personal information entrusted to it.
A. Prospective Student Data
Virginia Union University collects personal information from prospective students—including individuals who inquire about admissions, submit applications, register for campus visits or events, or otherwise engage with the University prior to enrollment—for the purpose of facilitating the admissions and enrollment process. This information may include:
Prospective student information is used to assess eligibility for admission, communicate admissions decisions and scholarship opportunities, provide information about programs and events, and support enrollment management activities. The University may share prospective student information with contracted enrollment management partners solely for the purpose of facilitating communication and outreach on behalf of the University. Virginia Union University does not sell prospective student information to third parties.
Prospective students who have not enrolled and wish to request deletion of their personal data from University recruitment systems may submit a written request to the Office of Admissions. The University will process such requests within a reasonable timeframe. Please note that opting out of recruitment communications will not prevent the University from sending information that is directly responsive to an inquiry or application submitted by the prospective student.
B. Non-Student Data (Website Visitors and General Public)
Virginia Union University's websites and digital platforms provide information and services to all visitors, including individuals who have no formal relationship with the University as a student or employee. The University may collect certain non-personal and personal information from these visitors, including:
Non-student visitors who prefer not to provide personal information through University websites may contact the relevant administrative office directly by telephone or mail to conduct any necessary business. Contact information for University offices is available at vuu.edu.
Information submitted by members of the general public—such as donors, community partners, event attendees, or guests—is used only for the specific purpose for which it was submitted (e.g., processing a donation, registering for an event, or responding to an inquiry) and is not used to build profiles or shared with third parties except as necessary to fulfill the stated purpose or as required by law.
C. Cookies and Online Tracking
Virginia Union University's websites may use cookies and similar tracking technologies to personalize content, analyze site traffic, and improve the user experience. Visitors may configure their browsers to refuse cookies or to alert them when cookies are being sent; however, doing so may affect the functionality of certain website features. The University does not use cookies to collect sensitive personal information and does not share cookie-derived data with third-party advertisers for commercial purposes unrelated to the University's mission.
D. FERPA Notice
Virginia Union University complies with the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. §1232g; 34 CFR Part 99. FERPA affords eligible students certain rights with respect to their education records, including the right to inspect and review their records, the right to seek amendment of records believed to be inaccurate, and the right to consent to disclosure of personally identifiable information from their records, except to the extent that FERPA authorizes disclosure without consent. Questions regarding FERPA rights should be directed to the Office of the Registrar.
E. Children's Privacy
Virginia Union University's online services are not directed to children under the age of 13. The University does not knowingly collect personal information from children under 13 without verifiable parental consent. If the University becomes aware that it has inadvertently collected personal information from a child under 13, it will take prompt steps to delete such information in compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§6501-6506.
F. Changes to this Privacy Statement
Virginia Union University reserves the right to update or amend this Privacy Statement at any time. Material changes will be communicated to affected constituents through the University's official website and, where appropriate, by direct notification. Continued use of University websites or services following notice of a change constitutes acceptance of the updated Privacy Statement.
G. Contact Information
For questions, concerns, or requests related to this Privacy Policy or Privacy Statement, please contact:
Virginia Union University, Information Technology Center
1500 N. Lombardy Street, Richmond, VA 23220
Telephone: (804) 257-5630
Website: www.vuu.edu
