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FERPA, GDPR, GLB, and HIPAA

The Family Educational Rights and Privacy Act (“FERPA”), General Data Protection Regulation (“GDPR”), Gramm-Leach-Bliley Act (“GLB”), Health Insurance Portability and Accountability Act (“HIPAA”), as well as other privacy laws that may be applicable, require JCCC to protect the privacy of certain personal information. It is the intent of JCCC to comply with all applicable provisions of these laws. These sections should be read in conjunction with JCCC’s Privacy Statement and this website’s Terms of Use.

FERPA - student rights with respect to their educational records

GDPR - Privacy rights applicable to users in the European Union

GLB - financial information security and confidentiality

HIPAA - protects individually identifiable health information (IIHI)

Related Webpages

Computer Security - information for protecting electronic data

Password Protection - user name and password security

Photography and Recording of JCCC Activities – capture and use of photographs/recordings by JCCC

Terms of Use — general terms relating to the use of this website

Privacy Statement

JCCC is a U.S.-based institution of higher learning offering credit and non-credit programs, curriculum content and services in a traditional campus setting and through our website (collectively, the “Services”). This Privacy Statement describes the types of personal data that JCCC collects through this website (the “Site”), how this data is used and shared, and users’ choices concerning these data practices. Personal data means any information about a user from which that user can be identified (“Personal Data”). This Privacy Statement does not apply any third-party sites not operated or controlled by JCCC, even if such sites are linked to this Site.

By providing JCCC with Personal Data or using JCCC’s Services, users agree to the data protection practices described in this Privacy Statement. If a user does not agree to this Privacy Statement, such user should not access or use JCCC’s Services. For more information about this Privacy Statement, and rights under applicable law, please contact JCCC at privacy@jccc.edu.

Additional or different practices may apply to data collected from participants in JCCC-involved research studies or surveys governed by JCCC’s Institutional Review Board. Participants in research studies will be provided with an informed consent form, which may describe the additional or different data practices that will apply to the study and which may supersede the practices set out in this Privacy Statement.

  1. COLLECTION OF PERSONAL INFORMATION FROM SITE USERS

    JCCC automatically collects and/or tracks (a) the home server domain names, email addresses, type of end user device, and type of Web browser of users to JCCC's this Site, (b) the email addresses of users that communicate with JCCC via email, post messages to JCCC's bulletin boards, or post messages to JCCCs chat groups, (c) information knowingly provided by the user in online registration forms, and (d) user-specific information on what pages users access.

    JCCC and affiliated third parties may place Internet cookies and other technologies (i.e. tracking pixels, web beacons, etc.) on users' hard drives. These technologies can save the users' name, password, user name, screen preferences, the pages of this Site viewed by the user, and the advertisements viewed or clicked by the user. When the user revisits this Site, JCCC and affiliated third parties will recognize the user by the Internet cookie and customize the user's experience accordingly. Internet cookies and other tracking technologies are stored on the user's hard drive and are not stored, in any form, by JCCC. However, JCCC may not have access or control over cookies and other features used by third parties, and the information practices of those third parties are not covered by this Privacy Statement. Users may decline the Internet cookie by using the appropriate feature of their Web client software, if available.

    Depending on the Services utilized, JCCC may collect Personal Data that is voluntarily provided when inquiring about admission to JCCC or financial aid, enrolling in one of JCCC’s programs or courses, applying or being hired to work at JCCC or participating in fundraising or community activities. This data may include:

    • Name, title, age and date of birth
    • Part or all of Social Security Number, Tax Identification Number, Visa information, or other identification information as required by law for applicants for admission and financial aid, employees or for validation purposes
    • Student or Employee I.D. Number
    • Contact information including address, city, state, postal code, country of residence and citizenship, email address, home, cellular and other contact telephone number(s)
    • Emergency contact information (names, phone numbers and email addresses)
    • Academic credentials and records
    • Photographs, video images, and likeness
    • Records of communications between the user and JCCC
    • Other information pertinent to specific interests and activities at JCCC

    JCCC may collect other information to maintain or manage JCCC systems, diagnose problems, assist with a help request, or inform investigations. JCCC also collects information users choose to provide to JCCC when any “free text” box is completed in its forms.

    Unless specifically requested and express consent obtained, JCCC asks that users not provide any sensitive information, such as racial or ethnic origin, political opinions, religion, or criminal background.

  2. USE OF PERSONAL DATA COLLECTED

    Personal data collected by JCCC will be used by JCCC for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of users' behavior, for product/services development, for content improvement, to inform advertisers as to how many users have seen or clicked on their advertisements, and to customize content and layout of JCCC's Site. Data on users' home servers is aggregated for internal review and then discarded. Names, postal and email addresses, and phone numbers collected may be added to JCCC's databases and used for future calls and mailings regarding Site updates, new classes or services and upcoming events.

    The certain privacy laws require that JCCC set out the lawful grounds it relies on to collect, use, disclose and otherwise process Personal Data. To the extent such laws apply, in general, JCCC’s lawful basis to collect, use, disclose, maintain and otherwise process Personal Data is to provide or prepare to provide Services to users. Depending on the Services utilized, examples of JCCC’s specific, lawful purpose(s) may include:

    • To process applications for admission to JCCC, employment and enrollment in courses and programs
    • To fulfill public safety obligations to our faculty, staff and students
    • To deliver and administer students’ education, record the details of studies (including any placements with external organizations for internships or coursework taken at another institution), and determine/confirm academic achievements (e.g. results, prizes)
    • To provide facilities and resources (e.g. IT, sport, libraries, accommodation, career counseling)
    • To operate security, governance, disciplinary (including plagiarism and academic misconduct), complaint, audit and quality assurance processes and arrangements
    • To support training, medical, safety, welfare and religious requirements
    • To compile statistics and conduct research for internal and statutory reporting purposes
    • To fulfill and monitor JCCC responsibilities under EEO, immigration and public safety legislation
    • To administer HR-related processes, including those relating to payroll, benefits administration, performance/absence management, disciplinary issues and complaints/grievances
    • To notify JCCC-designated emergency contact(s) of an emergency or crisis that may the University community
    • To prevent fraud or criminal activity, misuses of JCCC Services, and ensure the security of JCCC IT systems, architecture and networks
    • To (a) comply with legal and contractual obligations and legal process, (b) respond to requests from public and government authorities; (c) enforce JCCC terms and conditions; (d) protect JCCC operations; (e) protect rights, privacy, safety or property, and/or that of JCCC or others; and (f) allow JCCC to pursue available remedies or limit the damages that it may sustain
    • To perform tasks in the public interest to promote access to higher education and to inform prospective students, parents and the public of the educational opportunities at JCCC

  3. SHARING AND DISCLOSURE OF PERSONAL DATA

    JCCC may share Personal Data outside JCCC in the following circumstances:

    • Vendors and Service Providers: To assist JCCC in business operations needs and to perform certain services, Personal Data may be shared with third-party providers of hosting, email communication and support services, analytics, marketing, advertising, employee background checks, administrative and technical services (including Amazon Web Services and Google in the United States, both certified to the Privacy Shield), providers of recruitment models, providers of degree verification services and electronic transcript for delivery. Following JCCC’s instructions, these parties may access, process or store Personal Data while performing their duties for JCCC. They are contractually prohibited from using or sharing Personal Data provided by JCCC for any purpose other than providing their services.
    • If required to do so by law pursuant to valid legal process, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend rights or property of JCCC or others (iii) act in urgent circumstances to protect personal or public safety, or (iv) protect JCCC against legal liability.

    JCCC may share Personal Data within JCCC in the following circumstances:

    • For the purposes described in this Privacy Statement, notably for delivery, personalization, and improvement of Services at JCCC.
    • To satisfy local, state and federal laws and regulations or in furtherance of JCCC’s legitimate interests in providing and improving Services.
    • To further the advancement of knowledge through research and academic pursuits and providing employment opportunities.

  4. CHOICES RELATED TO PRIVACY

    Promotional Email:

    Individuals may opt out of receiving such communications by following the instructions contained in each promotional email. In addition, if at any time an individual does not wish to receive future marketing communications, please contact JCCC Strategic Communications, Marketing at optout@jccc.edu.

    Cookies:

    Most web browsers include a “help” section on the toolbar. Please refer to this section in your web browser for information on how to get notified when you receive a new cookie and how to turn cookies off. Please note that if a user rejects, turns off or blocks cookies, some parts of this Site may not function correctly. Also, blocking cookies will not stop third parties from collecting IP address, data stored in “Flash” cookies, and certain other types of technical information that may uniquely identify users’ browsers.

    Digital Marketing:

    Users can control whether companies serve on-line behavioral advertising by visiting the Digital Advertising Alliance website and using its opt-out: https://www.aboutads.info/choices/. The DAA opt-out requires that cookies not be blocked in a user’s browser. If located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool.

    As an alternative to the DAA opt–out, users can also elect to block browser cookies from first parties (such as those from the JCCC Site) and browser cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software. Note that some third parties involved in advertising operations may maintain their own proprietary consumer databases that allow them to personally identify or track website users. Other third parties have proprietary technologies to determine what additional devices users may use, where they can display relevant advertisements.

  5. SECURITY

    JCCC takes reasonable administrative and technical steps to protect data, including Personal Data, from loss, misuse and unauthorized access as provided in JCCC’s Data Classification and Security Policy 530.00 and Data Classification and Security Operating Procedure 530.01.

  6. RETENTION

    JCCC will retain Personal Data as needed pursuant to the legitimate purpose(s) identified in this Privacy Statement, its Records Retention Policy 219.00 and Records Retention Operating Procedure 219.01, and applicable law.

  7. CHANGES TO PRIVACY STATEMENT AND RIGHT TO CONTACT USER

    JCCC reserves the right to change these Terms of Use and this Privacy Statement at any time by notifying users of the new or revised Privacy Statement. As allowed by law, JCCC reserves the right to contact Site users regarding account status and changes to these Terms of Use, this Privacy Statement, other JCCC privacy policies and procedures or any other policies or agreements relevant to Site users.

  8. USERS LOCATED IN THE EUROPEAN UNION

    Users located in the European Union are also directed to the Supplemental Statement for Users in the European Union, which set out specific rights related to Personal Data and should be read together with this Privacy Statement and JCCC’s Terms of Use.

Supplemental Statement for Users in the European Union

In addition JCCC’s Privacy Statement describing what Personal Data JCCC collects from users and why and how this data is used, this Supplemental Statement describes additional rights provided to users of the Site from locations in the European Union (“EU”) (for these purposes, reference to the European Union or EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway) (“EU Users”) and should be read together with JCCC’s Privacy Statement and Terms of Use.

  1. RIGHTS OF EU USERS

    Subject to EU law, and specifically the General Data Protection Regulation (“GDPR”), EU Users may have the following rights in relation to Personal Data:

    • Right of access: If requested, JCCC will confirm whether it processes an EU User’s Personal Data and, if so, provide a copy of that Personal Data along with certain other details. If additional copies are required, JCCC may charge a reasonable fee.
    • Right to rectification: If Personal Data is inaccurate or incomplete, EU Users may ask that JCCC correct or complete it. If JCCC shared such Personal Data with others, and if requested, where possible and lawful to do so, JCCC will also tell EU Users with whom it shared such Personal Data so EU Users can contact them directly.
    • Right to erasure: EU Users may request erasure of Personal Data in some circumstances, such as where JCCC no longer needs it or if an EU User withdraws consent. If JCCC shared such Personal Data with others, JCCC will alert them to the need for erasure where possible. If requested, and where possible and lawful to do so, JCCC will also tell EU Users with whom it shared such Personal Data with so EU Users can contact them directly.
    • Right to restrict processing: EU Users may request to restrict or ‘block’ the processing of their Personal Data in certain circumstances, such as where an EU User contests the accuracy of the data or objects to JCCC processing it. JCCC will inform such EU User before any restriction on processing is lifted. If JCCC shared such Personal Data with others, JCCC will tell them about the restriction where possible. If requested, and where possible and lawful to do so, JCCC will also tell EU Users with whom it shared such Personal Data so EU Users can contact them directly.
    • Right to data portability: EU Users have the right to obtain their own Personal Data from JCCC. JCCC will provide Personal Data in a structured, commonly used and machine-readable format.
    • Right to object: EU Users may request that JCCC stop processing their Personal Data.
    • Rights in relation to automated decision-making: EU Users have the right to be free from decisions based solely on automated processing of their Personal Data, unless this is necessary in relation to a contract or EU Users provide explicit consent to this use.
    • Right to withdraw consent: EU Users have the right to withdraw that consent at any time, but this will not affect any processing of data that has already occurred.
    • Right to lodge a complaint with the data protection authority: If EU Users have a concern about JCCC’s privacy practices, including the handling of their Personal Data, EU Users can report it to the data protection authority that is authorized to hear those concerns.

    2. RIGHTS REQUEST

    EU Users may request access to and removal of information and records pertaining to such EU Users stored in JCCC systems. EU Users may exercise these rights by contacting JCCC at privacy@jccc.edu.

    JCCC requires that such requests be made in writing and include the following information:

    • EU User’s name and role (e.g., applicant, student, or employee);
    • contact information, including email and postal addresses;
    • the item(s) of information EU User wishes to access or remove, including if known, the URL or the location of data to be removed; and
    • the reason for requesting access to, or removal of, the information.

    There are some instances where JCCC may deny a request to remove information. For example, JCCC may decline to remove the following types of information, including, but not limited to:

    • information required to be maintained by JCCC as part of student or employment records, or pursuant to local, state or Federal law or regulation, or in performance of contractual obligations
    • information compiled in reasonable anticipation of, or for use in a civil, criminal or administrative action or proceeding

    If a request is denied, JCCC will send a written explanation explaining the reason for the denial and a notification of the EU User’s right to file a written statement of disagreement. JCCC may also provide a right to have the denial reviewed. If JCCC is unable to act within the time under applicable law, JCCC will provide notification of the delay and the date by which JCCC will complete action on the request.

    Exercising these rights is a guarantee to be afforded a process and not the guarantee of an outcome.