GDPR Privacy Policy
I. Policy Title: GDPR Privacy Policy
II. Who Does This Policy Affect?
All HFC faculty, staff, and students
III. Purpose
The European Union General Data Protection Regulations (“EU GDPR”) is a regulation governing the use of personal data. It imposes new obligations on entities that control or process personal data about people who are located in the European Union. This regulation applies both inside the European Union (“EU”) and outside of the EU and applies to data about anyone in the EU, regardless of whether they are a citizen or permanent resident of an EU country.
IV. Policy Statement
Henry Ford College is committed to safeguarding the privacy of “personal data” of present and future faculty, staff, and students.
This Privacy Policy outlines the collection, use, and disclosure of personal information provided to Henry Ford College by faculty, staff, and students.
Faculty, staff, and students who reside in EU countries and who apply, or may apply, to Henry Ford College will need to provide consent for collection and use of personal data. To provide consent, use the following consent form:
• Notice Regarding Protection of Personal Data and Request of Consent for Their Processing - Applicant Students Located in the European Union found at:
Faculty, staff, and students who participate in International Programs in EU countries will need to provide consent for collection and use of personal data. To provide consent, use the following consent form:
• Acknowledgement and Consent Regarding Protection of Personal Data for Study Abroad Students can be found at:
The Data Controller, under the GDPR law and with particular reference to the safety obligations related to automatic processing of student data, is Henry Ford College. All data is processed by Henry Ford College in its capacity as Data Controller with the supervision of Karen Sadanowicz Interim Registrar.
Use of Information
For purposes of this Privacy Policy, Sensitive Information is defined as race, ethnic origin, religious or philosophical beliefs, health data, sexual orientation, and criminal convictions.
Henry Ford College Departments supporting faculty, staff, and students collect and process Information and Sensitive Information from individuals who are faculty, staff, and students only as necessary in the exercise of the College’s legitimate interests, functions, and responsibilities as a higher education institution.
Information is collected from faculty, staff, and students and shared with internal and external parties to: register or enroll persons in the College, manage student accounts, provide academic advising, develop and deliver education programs, track academic progress, analyze and improve education programs, recruit students, make regulatory reports, audit, maintenance of accreditation, and other related College processes and functions. Henry Ford College Departments supporting faculty, staff, and students also use Information and Sensitive Information to conduct general demographic and statistical research to improve the College’s programs.
Sensitive Information is collected, processed, and shared internally and externally as necessary, applicable, and appropriate in order to: identify appropriate support services or activities, provide reasonable accommodations, enforce College policies, and comply with applicable laws. Information and Sensitive Information may be shared by the International Student Services Office with third parties who have entered into contracts with the College in order to perform functions on behalf of the College while sponsoring or hosting programs, subject to the obligation of confidentiality and safeguarding from unauthorized disclosure.
Third Party Use of Sensitive Information
Henry Ford College may disclose a faculty, staff, and student’s Sensitive Information and other Information as follows:
• Consent: Henry Ford College may disclose Sensitive Information and other Information if it has a student’s consent to do so.
• Emergency Circumstances: Henry Ford College may share a faculty, staff, and student’s Information and Sensitive Information when necessary to protect the faculty, staff, and student’s interests when the faculty, staff or student is physically or legally incapable of providing consent.
• Employment Necessity: Henry Ford College may share a faculty, staff, and student’s Sensitive Information when necessary for administering employment benefits, subject to the imposition of appropriate safeguards to prevent further unauthorized disclosure.
• Public Information: Henry Ford College may share a faculty, staff, and student’s Information and Sensitive Information if the faculty, staff , or student has manifestly made it public
• Archiving: Henry Ford College may share a faculty, staff, and student’s Information and Sensitive Information for archiving purposes in the public interest, for historical research, and for statistical purposes.
• Performance of a Contract: Henry Ford College may share a faculty, staff, and student’s Information when necessary to administer a contract the faculty, staff or student has with the College.
• Legal Obligation: Henry Ford College may share a faculty, staff, and student’s Information when the disclosure is required or permitted by international, federal, and state laws and regulations.
• Service Providers: Henry Ford College uses third parties who have entered into a contract with the College to support the administration of College operations and policies. In such cases, the College will share a faculty, staff or student’s Information with such third parties subject to the imposition of appropriate safeguards to prevent further unauthorized disclosure.
• College Affiliated Programs: Henry Ford College may share a faculty, staff, and student’s Information with parties that are affiliated with the College for the purpose of contacting the faculty, staff, and student about goods, services, or experiences that may be of interest to the faculty, staff, and student.
• De-Identified and Aggregate Information: Henry Ford College may use and disclosure Information in de-identified or aggregate form without limitation.
Security
Henry Ford College ensures that there are appropriate technical controls in place to protect your personal details. For example, College online forms are always encrypted and the College network is protected and routinely monitored. Henry Ford College undertakes regular reviews of who has access to information that it holds to ensure that your information is only accessible by relevant staff, volunteers and business partners.
Henry Ford College appoints an external party to undertake a screening of information, any such arrangements are subject to a formal agreement between the College and that firm has measures to protect the security of all data.
Individuals with questions about their personal data collected and processed by Henry Ford College’s Student Affairs Office should contact the Interim Registrar. Individuals with questions about their personal data collected and processed by Henry Ford College’s International Student Services Office should contact the Registrar.
Retention and Destruction of Faculty, Staff, and Student’s Information
A faculty, staff, and student’s Information will be retained by the College in accordance with applicable federal laws and the College’s Record Retention Policy. A faculty, staff, and student’s information will be destroyed upon the faculty, staff, and student’s 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 the faculty, staff, and student’s information given the level of sensitivity, value, and criticality to the College.
Faculty, Staff, and Student’s Rights
Faculty, staff, and students have the right to request access to, a copy of, rectification of, restriction in the use of, or erasure of Information in accordance with all applicable laws. The erasure of a faculty, staff, or student’s Information shall be subject to the retention periods of applicable federal law and the College’s Record Management and Retention Policy.
If the faculty, staff, and student has provided consent to the use of their Information, the faculty, staff, and student has the right to withdraw consent without affecting the lawfulness of the College’s use of the Information prior to receipt of the request. Students may exercise these rights by contacting the Interim Registrar khsadanowicz@hfcc.edu 313-845-9710.
Information created in the EU will be transferred out of the EU to the College. If faculty, staff, or a student feels the College has not complied with applicable foreign laws regulating such Information, they have the right to file a complaint with the appropriate supervisory authority in the EU.
V. Definitions
a. “Student” is any person who presently attends Henry Ford College or has attended Henry Ford College since May 2018.
b. “Personal data” is defined as any record created in the EU and transferred to Henry Ford College which is directly related to an identified or identifiable student, either directly or indirectly. Examples of “personal data” include, but are not limited to, directory information as defined in Henry Ford College’s FERPA Policy.
VI. Responsible Party for Policy Interpretation/Review
a. Registrar
b. VP of Student Affairs
c. VP of Human Resources
d. Directors of Institutional Technology
e. VP of Institutional Technology
VII. Related Documents
• Notice Regarding Protection of Personal Data and Request of Consent for Their Processing I-20 and DS-2019 Applicant Students Located in the European Union
• Notice Regarding Protection of Personal Data and Request of Consent for Their Processing - Applicant Students Located in the European Union
• Sample Letter regarding erasure of personal data
• Acknowledgement and Consent Regarding Protection of Personal Data for Study Abroad Students
VIII. Policy History:
a. Adopted by Board: October 17, 2022
This policy supersedes and replaces any and all policies related to this subject