This Guidance applies only to ASU’s use of your Personal Data that you submit or disclose to ASU (or to a third party that transfers it to ASU) while you are in the European Union (EU Personal Data).
This Guidance is provided pursuant to Regulation (EU) 2016/679 (“Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”) (the GDPR), effective May 25, 2018.
This Guidance supplements ASU’s Privacy Statement, and should be read together with ASU’s Privacy Statement. This Guidance is intended to be consistent with the GDPR principles of privacy, fairness, lawfulness, transparency, purpose limitation, accuracy, storage limitation, integrity, and accountability. For more information regarding the GDPR and these principles, the full text of the GDPR is available here.
The GDPR protects your rights to privacy and safeguards your EU Personal Data by putting you in control of how your EU Personal Data is used.
Personal Data means any information relating to you that can directly or indirectly identify you. This is a broad definition. For example, your Personal Data includes any of the following: your name, addresses (online and otherwise), id numbers, location data, date of birth, online identifiers, and social or cultural identity.
This Guidance describes how ASU uses your Personal Data for fundraising and alumni relations purposes. Developing a better understanding of our alumni allows us to keep in touch with you, to keep you apprised of our activities and developments, to provide services to you, and to identify ways you can support ASU, through donations or other forms of financial and non-financial support.
ASU’s processing of your EU Personal Data for the interdependent purposes described in this Guidance is necessary for one or more of the following: the pursuit of ASU’s legitimate interests; the carrying out of a task in the public interest; performing a contract with you, or to take steps at your request prior to contracting with you; or in the exercise of ASU’s authority as a constitutionally created institution governed by the Arizona Board of Regents, a body corporate of the sovereign State of Arizona in the United States of America.
There is no requirement for ASU alumni to provide any Personal Data to ASU.
Personal Data Held by ASU
ASU may hold information relating to you from a number of sources. A significant portion of the information we hold on alumni you provide to us. For example, you may give us information by filling in forms on ASU’s website, or by corresponding with us by telephone, email or otherwise. If you studied at ASU, some of your Personal Data is transferred from your student record to ASU’s alumni database. We will retain your Personal Data indefinitely in support of your lifelong relationship with ASU or until you request us to do otherwise.
Most ASU alumni records contain:
- details of your education (e.g., your schools, majors, and departments, the courses you have completed, and dates of study)
- unique personal identifiers and biographical information (e.g., student number, date of birth) your contact details (and we update these whenever you let us know they have changed)
- details of your interactions with ASU, including:
- your membership in clubs, societies, and alumni groups
- your attendance at ASU events
- other contact with ASU or our partners
- details of benefits and services ASU provided to you,
- your relationships with other alumni or supporters of ASU
- details about your family (e.g., your marital status, the name of your partner or spouse)
- personal data provided by you for specific purposes (e.g., disability and dietary preferences for event management purposes)
- your communication preferences, to help us provide tailored and relevant communications
We also record, where applicable, based on information you provide to us and, in some cases, publicly available information and information from third parties:
- financial information relating to you and your family, including:
- your history of donations made to ASU and the Arizona State University Foundation for a New American University (https://www.asufoundation.org)
- your philanthropy, including details of volunteer work and donations to other organizations
- your career highlights and other life achievements
- information about your areas of interest and extra-curricular activities
We augment the Personal Data we hold with data from third parties and publicly available data. We use targeted internet searches and may search websites such as the following (either directly or using search engines), where relevant to obtain and maintain the accuracy of the data listed above:
- Public sources:
- Wealth lists, including Forbes Magazine’s lists
- Epsilon (epsilon.com)
- EMSI (economicmodeling.com)
- Property websites
- Press sources
How ASU Uses Your Personal Data ASU uses your Personal Data for a number of interdependent purposes in support of alumni relations. These include:
- sending you publications (e.g., alumni magazines and updates about ASU)
- conducting surveys, including research on whether particular products and services may interest you
- providing services, including access to ASU facilities and alumni email accounts
- sending you details of volunteering opportunities
- inviting you to alumni and other ASU events
- promoting opportunities and services available to you (e.g., offers and opportunities available through ASU’s network of alumni groups)
- internal record keeping, including the management of any feedback or complaints
- administrative purposes (e.g., to administer an event you have registered for or attended)
Communications to you may be sent by mail, telephone or electronic means (principally by email), depending on the contact details we hold and your preferences about the types of communications you wish to receive.
If you have concerns or questions about any of these purposes, or how we communicate with you, please contact us using the details listed below.
We may use automated or manual analyses to link data together to help us to provide you with an improved experience, to send you relevant and timely communications, to identify volunteering opportunities or opportunities for providing support that may be of interest to you, and to avoid approaching you with opportunities that are not of interest. All of this enables ASU to support ASU alumni and to support ASU’s strategic research and teaching objectives. We always seek to ensure that any opportunities we present are aligned with your interests, based on the research we conduct.
We will always respect a request by you to stop processing your Personal Data. In addition, your EU GDPR statutory rights, which relate to your EU Personal Data, are described below.
When ASU Shares Your EU Personal Data with Others ASU shares EU Personal Data on a considered and confidential basis, where appropriate, with:
- affiliated organizations and individuals that support and provide services to alumni and supporters, such as:
- The Arizona State University Foundation for a New American University, and its affiliated entities
- volunteer partners closely related to ASU (e.g., alumni societies and alumni group representatives)
- third parties engaged by ASU to provide alumni services, such as:
- contractors that provide services to you on our behalf or provide services to us
- selected entities that provide ASU and ASU Alumni branded products and services
How ASU Protects Your EU Personal Data ASU does not disclose EU Personal Data to individuals or entities not affiliated with ASU, except in the limited circumstances described in ASU’s Privacy Statement.
ASU requires non-ASU entities and service providers to protect EU Personal Data on our behalf.
We do not permit third parties to sell any EU Personal Data we have shared with them.
We also facilitate communication between individual alumni, but in doing so we do not release personal contact details without prior permission.
Your Rights. You have certain rights regarding your EU Personal Data, subject to certain exclusions as described in the GDPR. Your rights include:
- The right to be informed of how your EU Personal Data are being used – this information is set forth in this Guidance and any documents linked to this Guidance
- The right of access to your EU Personal Data
- The right to have your inaccurate EU Personal Data rectified
- The right to have your EU Personal Data erased
- The right to restrict the Processing of your EU Personal Data pending its verification or correction
- The right to object to the Processing of your EU Personal Data
- The right to receive copies of your Personal Data
- The right to file a complaint with an EU Supervisory Authority
- The right to object to using your EU Personal Data for direct marketing, data mining, or research purposes where the research is not in the public interest
Where you exercise your right to erasure, we will continue to maintain a core set of Personal Data (name, subject(s), matriculation and graduation details, unique ASU identification number, and date of birth) to ensure we do not contact you inadvertently in the future, and to maintain your academic record for reference and archival purposes. We may also retain your Personal Data to meet our legal obligations.
Contact Information; Rights Requests; Questions: If you wish to exercise any of your rights, please contact ASU’s data protection team (firstname.lastname@example.org). If you have questions or need further assistance, please contact ASU’s Alumni Relations team by e-mail at email@example.com. You may also file a complaint concerning your EU Personal Data Processing with the EU Supervisory Authority in the applicable EU countries. The Supervisory Authority Contact Information for all EU Countries is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
If you have specific requests relating to how ASU Processes your EU Personal Data, we will endeavor to resolve these, but there may be circumstances where ASU cannot comply with specific requests.
We will publish on our website any changes we make to this Guidance.
Effective date: May 25, 2018