Privacy

“CGI”, Cummings Graduate Institute for Behavioral Health Studies, is defined as the entity that acts as the controller or processor of personal information, as explained in more detail in the sections below.

Purpose
The purpose of this policy is to secure and respect the privacy of all personal information and data collected from anyone CGI communicates with, including current students, applicants, prospective students, or previously associated students, non-students, and non-prospective students. CGI encourages you to periodically review this Privacy Policy because CGI may update it when applicable.

Responsibility
It is the responsibility of the Academic Departments, including but not limited to the Director and Assistant Director of the Doctor of Behavioral Program, Student Services and Communication Team, Finance Department and all Faculty to ensure all personal information and data is used appropriately.

Scope
The types of information we collect
CGI may collect the following types of personal and sensitive data:

• Full name
• Mailing/permanent address,
• Email address
• Telephone number
• Date of birth
• Social security number or other tax identification number (only for applicants to CGI’s academic programs)
• Information relating to education and employment history, the colleges or universities students have attended and places where students have worked, the courses students have completed, dates of study and degrees conferred, including Transcripts
• Billing & payment information (i.e. payment information, billing address, name)
• Racial or ethnic origin
• Gender
• Country of Citizenship
• Copy of government issued ID
• Military Affiliation

CGI  also collects information about the computers, mobile devices, or other devices used to access CGI’s technology network, such as IP address, unique device identifiers, browser types, browser languages, web pages requested, network software access, referring web pages, date, time, and duration of activity, passwords, and accounts accessed, volume of data storage and transfers, and locations of user devices when connected to CGI’s technology network. Logs of this information may be retained. CGI may contract with non-CGI service providers to help us better understand users. These non-CGI service providers are not permitted to use the information collected on CGI’s behalf except to help conduct and improve CGI’s services.

Cookies are small files that are stored on your computing devices. CGI uses cookies to understand and save preferences for future visits and compile aggregate data about network traffic and network interaction so that CGI can offer better network experiences and tools in the future. Cookies may be set by an organization other than CGI. These non-CGI cookies may, for example, originate from social media services such as YouTube and Facebook. Because the cookie policies of these services change over time, the user should review their policies by visiting the privacy policies of these services directly. Users may disable cookies through their individual browser options.

CGI uses information collected to provide services, in support of CGI’s Mission, to protect the security of CGI’s technology network, to support academic integrity, and to provide safety and security services to users, as well as to monitor, preserve, and enhance the use, functioning, and integrity of CGI’s technology network. CGI may also use information collected from the users for analysis and statistical purposes consistent with CGI’s Mission.

How CGI collects your information
CGI may collect personal data in a number of ways, for example:

• From the information provided to CGI when the user interacts with CGI before enrolling. For example, when the user expresses interest in studying at CGI.
• When the user subscribes to a CGI newsletter;
• When the user registers to attend a CGI professional development event or conference;
• When the user applies to study at CGI and completes an admission application;
• When the user completes other admissions processes and procedures;
• When the user communicates with CGI by telephone, email, or via our website. For example, in order to make an inquiry or raise concerns;
• In various other ways as the user interacts with us during their time as a student of CGI, for the various purposes set out below.
• From third parties. For example, from the user’s previous or current school, university, or employers who may provide a reference about the user or employer reimbursement/third party payments.
• The use of online surveys which may be conducted for the research purposes indicated in the survey.  Unless otherwise noted on the specified survey, answers are confidential and individual responses will not be shared with other parties. Aggregate data from surveys may be shared with external third parties.

How CGI uses information about its students

The purposes for which CGI may use personal data (including sensitive personal data) we collect during a student’s association with CGI, include:

• Recruitment and admissions;
• Academic matters, including:
  • the provision of CGI’s core teaching, learning and research services (e.g. registration, assessment, attendance, managing progress, academic misconduct investigations, certification, graduation);
  • maintaining student records;
  • assessing your eligibility for financial aid and scholarships, etc.
• Providing library, IT and information services;
• Non-academic matters in support of our core services, including:
  • providing student support services (e.g. Operations, Student Services, and Academic Departments);
  • monitoring equal opportunities;
  • safeguarding and promoting the welfare of students;
  • ensuring students’ safety and security;
  • managing student accommodation;
  • managing the use of social media;
• administering finance (e.g. fees, scholarships and tuition);
• other administrative purposes, including:
  • carrying out research and statistical analysis;
  • carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
  • providing operational information (e.g. providing IT support, information about building closures or access restrictions on campus, or safety advice);
  • promoting our services (e.g. providing information about student service);
  • preventing and detecting crime;
  • dealing with grievances and disciplinary actions;
  • Addressing and managing complaints and inquiries.

How CGI Protects Your Information
When you access your personal information, we use a secure server.  Industry standard encryption (TLS) is employed before any information you input is sent to us. Furthermore, all of the data we collect is protected against unauthorized access.  As effective as encryption technology is, however, no security system is completely impenetrable, so CGI cannot affirm absolute security of our systems, nor can we affirm that information you supply won’t be intercepted while being transmitted to us over the Internet.

Data retention

We may retain your in your personal data for a period of 10 years after your association with CGI  has come to an end. However, some information may be retained indefinitely by CGI in order to maintain the students academic record for archiving purposes.

Disclosure of Information

CGI does not disclose confidential information we collect online to individuals or entities not affiliated with CGI, except in the limited circumstances described below. Non-confidential information may be disclosed or distributed pursuant to federal laws, state laws, including Arizona’s public records laws, and ASU and Arizona Board of Regents (ABOR) policies. These laws and policies explain what information may be shared or disclosed. They also explain what information is protected as confidential.

Your rights
Under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99)  you have the following rights:

• Eligible students have the right to inspect and review the student’s education records maintained by the school. Schools are not required to provide copies of records unless, for reasons such as great distance, it is impossible for parents or eligible students to review the records. Schools may charge a fee for copies.
• Eligible students have the right to request that a school correct records which they believe to be inaccurate or misleading. If the school decides not to amend the record, the parent or eligible student then has the right to a formal hearing. After the hearing, if the school still decides not to amend the record, the parent or eligible student has the right to place a statement with the record setting forth his or her view about the contested information.
• Schools must have written permission from the eligible student in order to release any information from a student’s education record. However, FERPA allows schools to disclose those records, without consent, to the following parties or under the following conditions (34 CFR § 99.31):
  • School officials with legitimate educational interest;
  • Other schools to which a student is transferring;
  • Specified officials for audit or evaluation purposes;
  • Appropriate parties in connection with financial aid to a student;
  • Organizations conducting certain studies for or on behalf of the school;
  • Accrediting organizations;
  • To comply with a judicial order or lawfully issued subpoena;
  • Appropriate officials in cases of health and safety emergencies; and
  • State and local authorities, within a juvenile justice system, pursuant to specific State law.

Once the GDPR is enforce in May 2018, you will also have the following additional rights:

• to require us to correct the personal data we hold about you if it is incorrect;
• to require us to erase your personal data;
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have given your consent and you wish to withdraw it, please contact our Office of Operations using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

Changes to your personal data
Please tell us promptly about any changes to the information we hold about you. This is particularly important for your contact details. You may request changes by contacting the Office of Operations, compliance@cgi.edu or by telephone: (480) 285-1761.

Institute Officials
The Cummings Graduate Institution requires all “Institute Officials”, defined as: administrative staff, faculty, and any third parties under contract with the Institution, to undergo an annual Data Privacy Policy Training upon hire and annually to ensure compliance.

Action
Cummings Graduate Institute takes Data Privacy seriously. If an Institute Official is unable to abide by the Confidentiality of Student Records Policy, their supervisor will need to notify the Director of Operations and together the supervisor and Director of Operations will handle the manner according to the Employee Handbook.

If user data is compromised, Cummings Graduate Institute will notify the user immediately and take appropriate action to resolve the issue.

Enforcement
If the Data Privacy Policy is broken, the Director of Operations will report the case to the CEO of Cummings Graduate Institute, who will work the the Director of Operations to establish a case and take action on the issue.

Forms
CGI News and Events Subscription Form

Information Request Form