This Notice describes St. John’s University (“St. John’s”) practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation about students enrolled at St. John’s or accessing services provided at a St. John’s location. 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, and New York, New York, and global studies programs (such as the program affiliation with Mary Immaculate College in Limerick, Ireland (collectively “St. John’s,” “us” or “our”). Global studies programs refers to any St. John’s sponsored student international travel programs (including global programs that do not include an academic/study component). All students (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
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, including during our communications with you, when you sign up for classes or other services, when you make use of St. John’s equipment, facilities, and resources, when you take classes, when you apply for financial aid, when you make use of the Student Health Center, when you utilize services of third-party vendors that contract with St. John’s such as the St. John’s University Rome Campus, the St. John’s Paris Association, Mary Immaculate College, health insurers, hotels, travel agents and tour providers, and when you respond to communications that emanate from St. John’s and/or third-party vendors that contract with St. John’s. This includes information about you created by our faculty and staff, like your grades, scores, records of attendance and participation, and recorded observations about you. It also includes information about your payments made to us for tuition and other expenses.
In some cases, certain information will be required in order for St. John’s to enroll you in a program or class, determine your eligibility for financial aid or use of a resource, or otherwise provide you with the service you are requesting. We will mark that information as “Required” or “Mandatory.” Failure to provide required or mandatory information may result in your being denied enrollment, eligibility, or other services that St. John’s offers.
In addition, we collect the following kinds of information about you from third parties:
We process your Personal Information to operate St. John’s and the programs you are enrolled in, to provide you with financial aid, to provide you with additional related services (like housing, internet access, and health services through the Student Health Center and other programs). We also use this data to:
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 or that we collect about you.
We have a legitimate interest in retaining and educating qualified students, 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 General Counsel.
During the period of your enrollment, we may also be required to process your Personal Information to complete a contract that you have entered into with us, including to be admitted to a program, or receive financial aid, housing, or another service from us. You can obtain additional information regarding processing we do to enter into contracts with you by contacting the Office of General Counsel.
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 St. John’s Office of General Counsel.
In the case of Sensitive Personal Information (which includes information about your health, race, ethnicity, national origin, criminal convictions, religious or philosophical beliefs, sexual orientation, and trade union membership), 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: Federal financial aid laws, federal and state tax laws, federal and state education laws, and federal and state anti-discrimination laws.
You can obtain more information about these laws by contacting the Office of 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 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 purposes 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 and personnel, including third parties who provide services to St. John’s in connection with the purposes of processing described above. 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 General Counsel to learn more about the categories of service providers to whom your data is disclosed.
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 United States and to the countries where we operate global studies 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 to one of our global studies programs your data will be sent to our US campuses in New York and the applicable global studies program location(s) to facilitate your enrollment in the program and provide related services to you before, during and after the program.
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 prospective student applicants for no less than 7 years, and data about actual applicants for no less than 7 years. If you are accepted to and enroll at St. John’s, then we retain your data throughout your period of enrollment and for a period of no less than 30 years thereafter. We may be required by law to retain your information for a longer period, for example, in order to comply with a subpoena. If you have any questions, you may contact the Office of General Counsel.
You have the right to the following information regarding St. John’s processing of your Personal Information:
This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the Office of General Counsel.
You also have the following additional rights with respect to your Personal Information: