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Area of Responsibility: Information Technology 
Responsible Contact: Chief Information Officer 
Policy Identification: Privacy Policy
Policy Effective Date: 07/21/2021 
Last Revised: 04/26/2022

PRIVACY POLICY


I. Overview

Virginia Union University will collect personal information about Employee for various purposes, primarily relating to establishing and managing the employment or other work relationship between Virginia Union University and its human resources.  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 Employee member has given permission to disclose the information.


II. Purpose

Virginia Union University has a responsibility to inform Employee 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 employee member’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, e-mail, or via the Internet.  Subject to our legal rights and obligations, Virginia Union University may, from time to time, seek an employee member’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 Employee member 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 Employee 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 Employee to a limited number of third parties and those we are obliged to do so by law to administer Staffing compensation, and benefits programs.     

Although the University will protect and limit the use of personal information about Employee 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 Employee.
 
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 Employee with a business need to know, or whose duties so require, are granted access to personal information about Virginia Union University Employee.  

Personal information is kept as long as necessary to satisfy the purposes.  Personal information that has been used to decide about an employee shall be retained for a reasonable period, which will permit the Employee member 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 Employee member 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:
When an employee can demonstrate that the personal information is not accurate or complete, the information will be annotated or amended as appropriate. 
When the information is (i) personal information about a third party, (ii) sensitive or confidential business information of Virginia Union University or a third party or (iii) any other information that Virginia Union University is required or permitted by law to remove.

Employee members can seek access to their personal information by sending a written request to the Human Resources Department.