Privacy Policy

Privacy Notice for Mills College

Mills College is committed to safeguarding the privacy of personal information. As used here, “personal information” includes Personally Identifiable Information, Sensitive Personal Information, and Personal Data and is collectively referred to here as “PI”. This Privacy Notice outlines the collection, use, and disclosure of PI provided to Mills College by students, employees, and applicants for employment. When information is submitted to Mills College, or you use Mills College's websites and other services, you consent to the collection, use, and disclosure of that information as described in this Privacy Notice.

Mills College Use of Information

Mills College collects and processes PI from individuals who are students only as necessary in the exercise of Mills College’s legitimate interests, functions, and responsibilities as an institution of higher education. Mills College also collects and processes PI from individuals who are research subjects in the exercise of scientific, historical research, or statistical purposes. Additionally, Mills College collects and processes PI from individuals who are applicants for faculty and staff positions in order to enter into or administer a contract for employment with Mills College. PI is collected from students and shared with internal and external parties to register or enroll persons in Mills College, provide and administer housing to students, manage a student account, provide academic advising, develop and deliver education programs, track academic progress, analyze and improve education programs, recruitment, regulatory reporting, auditing, maintenance of accreditation, and other related Mills College processes and functions. Mills College also uses PI to conduct general demographic and statistical research to improve Mills College programs. Sensitive PI is collected, processed, and shared internally and externally, as necessary, applicable and appropriate, to identify appropriate support services or activities, provide reasonable accommodations, enforce Mills College policies, or comply with applicable laws. Finally, PI may be shared by Mills College with third parties who have entered into contracts with Mills College to perform functions on behalf of Mills College, subject to the obligation of confidentiality and safeguarding from unauthorized disclosure.

For purposes of this Privacy Notice, Sensitive Personal Information is defined as race, ethnic origin, religious or philosophical beliefs, health data, sexual orientation, and criminal convictions.

For purposes of this Privacy Notice, Personally Identifiable Information refers to any information that can be used to distinguish or trace an individual's identity, such as name, social security number, date and place of birth, mother's maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.

For purposes of this Privacy Notice, Personal Data means information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural, or social identity.

Third-Party Use of Sensitive Information

We may disclose your PI as follows:

  • Consent: We may disclose PI if we have your consent to do so.
  • Emergency Circumstances: We may share your PI when necessary to protect your interests, and you are physically or legally incapable of providing consent.
  • Employment Necessity: We may share your Sensitive PI when necessary for administering employment or social security benefits in accordance with applicable law or any applicable collective bargaining agreement, subject to the imposition of appropriate safeguards to prevent further unauthorized disclosure.
  • Charitable Organizations: We may share your PI with the Alumnae Association of Mills College and other not-for-profit organizations in connection with charitable giving subject to the imposition of appropriate safeguards to prevent further unauthorized disclosure.
  • Public Information: We may share your PI if you have manifestly made it public.
  • Archiving: We may share your PI for archiving purposes in the public interest, and for historical research, and statistical purposes.
  • Performance of a Contract: We may share your PI when necessary to administer a contract you have with Mills College.
  • Legal Obligation: We may share your PI when the disclosure is required or permitted by international, federal, and state laws and regulations.
  • Service Providers: We use third parties who have entered into a contract with Mills College to support the administration of Mills College operations and policies. In such cases, we share your PI with such third parties subject to the imposition of appropriate safeguards to prevent further unauthorized disclosure.
  • Mills College Affiliated Programs: We may share your PI with parties that are affiliated with Mills College for the purpose of contacting you about goods, services, charitable giving, or experiences that may be of interest to you.
  • De-Identified and Aggregate Information: We may use and disclose PI in de-identified or aggregate form without limitation.

Security

We implement appropriate technical and organizational security measures to protect your information when you transmit it to us and when we store it on our information technology systems.

Retention and Destruction of Your Information

Your information will be retained by Mills College in accordance with applicable state and federal laws. Your information will be destroyed upon your request unless applicable law requires destruction after the expiration of an applicable retention period. The manner of destruction shall be appropriate to preserve and ensure the confidentiality of your information given the level of sensitivity, value, and criticality to the Mills College.

Your Rights

You have the right to request access to, a copy of, rectification, restriction in the use of, or erasure of your information in accordance with all applicable laws. The erasure of your information shall be subject to the retention periods and in accordance with applicable state and federal laws. If you have provided consent to the use of your information, you have the right to withdraw consent without affecting the lawfulness of Mills College’s use of the information prior to receipt of your request.

Students may exercise these rights by contacting the Mills College Registrar at registrar@mills.edu. Applicants for employment as faculty may exercise these rights by contacting the Office of the Provost at provost@mills.edu. Applicants for employment as staff may exercise these rights by contacting Mills College Employee Services at employeeservices@mills.edu.

Information created in the European Union will be transferred out of the European Union to Mills College. If you feel Mills College has not complied with applicable foreign laws regulating such information, you have the right to file a complaint with the appropriate supervisory authority in the European Union.

Updates to This Policy

We may update or change this policy at any time. Your continued use of Mills College’s website and third-party applications after any such change indicates your acceptance of these changes.

May 25, 2018