This Notice describes St. John’s University (“St. John’s”) practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of employees covered by the European Union’s General Data Protection Regulation. This Notice applies to the St. John’s location at 8000 Utopia Parkway, Queens, New York 11439 as well as to its affiliated campuses in Rome, Italy; Paris, France; Staten Island, New York, Hauppauge, New York, and New York, New York; and its global studies programs (such as the program affiliation with Mary Immaculate College in Limerick, Ireland) (collectively “St. John’s,” “us” or “our”) solely with respect to employees of St. John’s Global studies programs. All such employees (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.
“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
You can contact St. John’s Office of General Counsel with any questions about this notice, our data collection practices, or your rights:
St. John’s University
Attn: Joshua Hurwit, Associate General Counsel and Data Protection Officer
8000 Utopia Parkway
Queens, New York 11439
Via Marcantonio Colonna, 21A
Rome, Italy 00192
93 rue de Sevres
Paris, France 75006
This general notice may be supplemented by additional notices at the point of any data collection. If you have specific questions about any of the data processing activities described in this or any other notice, please contact the individual identified above.
We process the information we collect from you directly, either during our communications with you, when you apply for employment, when you sign up for employment benefits, or when you make use of St. John’s equipment and systems, facilities, programs, resources, and St. John’s services provided by third-party vendors. This includes information about your employment history with St. John’s, your job performance, compensation and benefits, and your dependents and emergency contacts.
In some cases, we may require certain information from you to provide you with a service or benefit. Failure to provide that information may mean we cannot provide you with a service or benefit.
In addition, we collect the following kinds of information about you from third parties:
We process your Personal Information to administer and manage St. John’s programs and services, administer, manage, and evaluate your employment with St. John’s, communicate with you regarding your employment, and provide you with access to St. John’s programs, services, and facilities. We also use data to make strategic decisions about St. John’s programs or course offerings, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We also use your data for purposes required by law, including complying with application retention requirements, and for the enforcement of St. John’s policies and applicable laws
We combine the data that we collect in order to provide these functions.
We have the following legal basis for processing the information you provide us in your application or that we collect about you during the application process.
We have a legitimate interest in hiring and retaining qualified employees, complying with laws and regulations that govern our conduct in the countries where we operate, and administering St. John’s and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes. You can obtain additional information about the legitimate interests we have in processing your information by contacting the Office of the General Counsel.
We may be required to process your Personal Information to fulfill our obligations pursuant to a contract of employment or an agreement to receive certain other benefits. You can obtain additional information regarding processing we do to enter into contracts with you by contacting the DPO.
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states.
You can obtain additional information about the processing we do to comply with applicable laws by contacting the Office of the General Counsel.
In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation, we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. For example, we are required to process sensitive data to comply with U.S. federal laws, New York State laws, and New York City laws and regulations.
You can obtain more information about these laws by contacting the Office of the General Counsel. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the Office of the General Counsel. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.
Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of conducting scientific, statistical, or historical research or for the purpose of creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.
Your Personal Information will be received and processed by St. John’s employees, students, and personnel, including third parties who provide services to St. John’s in connection with the purposes of processing described above, like payroll and benefits service providers, technology providers that support St. John’s systems and infrastructure, and other vendors acting on our behalf. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact the Office of the General Counsel to learn more about the categories of service providers to whom your data is disclosed.
We may also disclose your contact information at St. John’s in staff and faculty directories available to St. John’s students, employees, and the general public. You may request that your information be removed from this directory.
We may provide your information to other universities or entities to facilitate joint activities, including travel, collaborative events, professional affiliations, and research.
We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.
St. John’s is headquartered in the United States with global studies programs in the EU. We transfer your data to the countries where we operate global programs. St. John’s offers global studies programs in Rome, Italy; Paris, France; and Limerick, Ireland; as well as other locations in the European Union. If you apply for employment at one of our EU Global Sites, your data will be accessed by both our global headquarters in the United States and the applicable EU Global Site when we evaluate your application for employment.
St. John’s has executed Standard Contractual Clauses, as approved by the European Commission. These clauses permit St. John’s to transfer data from the EU to third countries, including the United States. If you would like to receive a copy of St. John’s Standard Contractual Clauses, you can contact the Office of General Counsel.
We keep data about employees for no less than 7 years. We may be required by law to retain your information for a longer period, for example if required to do so by U.S. authorities and/or U.S. law. If you have any questions, you may contact the Office of the General Counsel.
You have the right to the following information regarding St. John’s processing of your Personal Information:
This Data Privacy Notice is intended to provide this information. Any questions about these details may be directed to the Office of the General Counsel.
You also have the following additional rights with respect to your Personal Information:
Commission Nationale de l'Informatique et des Libertés - CNIL
8 rue Vivienne, CS 30223 F-75002 Paris, Cedex 02
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
Data Protection Commissioner
Lo-Call: 1890 25 22 31
Tel. +353 57 868 4800
Fax +353 57 868 4757
e-mail: [email protected]
Garante per la protezione dei dati personali
Piazza di Monte Citorio, 121 00186 Roma
Tel. +39 06 69677 1
Fax +39 06 69677 785
e-mail: [email protected]t