Dartmouth College, including the Office of Visa and Immigration Services (referred to in this Privacy Statement as “OVIS” or “we”) is committed to supporting the privacy of the Dartmouth community members we serve, including international undergraduate degree and non-degree students as well as international graduate students from the Geisel School of Medicine, the Tuck School of Business, the Thayer School of Engineering, and the Guarini School of Graduate and Advanced Studies. We also provide immigration advising and sponsorship assistance for international faculty, scholars, researchers and staff working at Dartmouth. This Privacy Statement explains how we handle and use the personal data we collect about individuals working with OVIS.
What personal data we collect
While specific information may vary for particular individuals, we may collect, use, store and transfer different kinds of personal data about you, including:
- Biographic, contact and demographic information – names, birth dates, home and school addresses, phone numbers, email addresses, and social media contact information, language, citizenship, passport information, government-issued immigration documents, marriage and birth certificates evidencing family relationships, sex/gender identity, and ethnicity/race (if provided).
- Education, employment and financial information, including degrees and transcripts, resume/CV, employer names, job titles, and industry/military service information, pay statements from Dartmouth or prior employer, financial documents as proof of funding, including bank account statements and funding/fellowship/scholarship certifications and letters.
- Information on participation in academic, extracurricular or other activities –sports teams, volunteer and academic interests, organization affiliations, awards and honors
- Analytical information – aggregated information related to web visitor activity, email interactions, and participation in OVIS-related activities.
How we collect personal data about you
We collect information about you from a variety of sources. A significant portion of the information we maintain is that which you have provided to us directly through iDartmouth, OVIS’s online intake system. For students, certain of your personal data may be transferred to OVIS through platforms like the Banner student system or the Human Resources Management System (HRMS). In addition, we may receive information about you through the department or Dartmouth school into which you are being hired or matriculating, either directly or through the iDartmouth intake system and the Sunapsis case management system.
We may also collect information about you from third party sources, including but not limited to other institutions/program sponsors in the event of a transfer to Dartmouth, and third parties providing financial support to students and scholars.
How we use your personal data
We use your personal data to enable us to provide services such as assistance in applying for a visa and admission to the U.S. to study or work at Dartmouth, , maintaining valid immigration status, and other immigration services. We may also use it for reporting purposes.
Additionally, we may use your personal data to:
- Keep you updated with information about upcoming deadlines and OVIS requirements
- Send you information about Dartmouth and OVIS-related activities
- Perform administrative tasks and for internal record keeping purposes.
- Create and analyze aggregated information for statistical research purposes in support of our educational mission.
We may contact you by telephone, email, or postal mail. If you have concerns about any of these purposes, or how we communicate with you, please contact OVIS at firstname.lastname@example.org.
When we share your personal data
To perform the functions listed above, it may be necessary to share your personal data with staff members at OVIS, other Dartmouth administrative staff members, faculty members or others who have a need to know in accordance with applicable law. Individuals performing functions for us are informed regarding appropriate handling of your personal data. Likewise, we may share your personal data with other Dartmouth offices or divisions (such as the applicable Dean’s office, Student Affairs or Registrar’s Office, as well as HR/Payroll or Financial Aid) and to third parties affiliated with Dartmouth or which are performing services under contract with us, including but not limited to outside immigration counsel, Travisa (outbound visa services) and Trustforte (academic evaluation/credentialing and translation service). Note that we submit documentation to the U.S. government for individuals seeking U.S. immigration benefits; these agencies include U.S. Department of Homeland Security, U.S. Department of State, and U.S. Department of Labor.
How your information is stored and secured
Dartmouth uses an array of administrative, technical and physical security measures to protect your personal data, including role-based access requirements and other safeguards. Please see the Dartmouth Information Security Policy for additional information.
How long we keep your personal data
Absent a reason to retain information for a longer period, OVIS retains personal data for a period of ten years after the closure of an individual’s file, which is typically when the individual is no longer under Dartmouth’s immigration sponsorship.
Information for Data Subjects Located in the European Economic Area (EEA)
Rights of Data Subjects
Dartmouth College will serve as the “controller” of personal data processed for the purposes outlined above under the EU General Data Protection Regulation 2016/679 (known as the “GDPR”). For data subjects located in the EEA, the GDPR may afford you rights in certain circumstances, including the right to be informed of how your personal data is used, the right of access to your personal data, the right to rectify or have your personal data erased where appropriate, the right to object to or restrict the processing of your personal data, and the right to object to communications, direct marketing, or profiling. Articles 12 through 23 of the GDPR provide further information about your rights as a data subject, to the extent applicable. You also have the right to lodge a complaint with your national or regional data protection authority. If you are interested in exercising these rights, we request an opportunity to discuss with you any concerns you may have about the processing of your personal data. Upon honoring a request to erase your information, we will maintain a core set of personal data to ensure we do not contact you inadvertently in the future, as well as any information necessary for Dartmouth College archival purposes. We may also need to retain some information for legal or compliance purposes including for purposes of establishing, defending against or exercising our rights with respect to an actual or threatened legal claim or enforcement action.
Legal Basis for Processing
OVIS will typically process personal data as necessary for the provision of services, or to take steps preparatory to the provision of services, to data subjects. This may not be the only lawful basis on which OVIS may process personal data; as such we may sometimes process data on an alternative legal basis, such as where a data subject has given us consent to do so or in the pursuit of the various legitimate interests set out above in this Privacy Statement. In the latter case, we will rely on these legitimate interests as the legal basis for processing where these interests are not overridden by the interests and rights or freedoms of the data subjects concerned.
Consent to Cross-Border Transfer
By providing information to Dartmouth, including without limitation to an employee representative of OVIS or through a third-party service provider, you consent to the transfer of your personal information outside of the EEA to the United States. You understand that the current laws and regulations of the United States may not provide the same level of protection as the data and privacy laws and regulations of the EEA.
We may change this Privacy Statement from time to time. If we make any significant changes in the way we treat your personal data, we will make this clear on the applicable Dartmouth website and/or by contacting you directly.
Last updated on September 21, 2018.