The New School Student Privacy Notice
This privacy notice describes how The New School collects and processes personal data about you at The New School; how we use, store, transfer, and protect this personal data; and your rights in relation to this personal data. This notice applies to The New School, with global headquarters at 72 Fifth Avenue, New York, NY 10011 USA, as well as to its affiliated legal entities and branches (collectively “we,” “us,” or “our”):
- TNS Parsons (“Parsons Paris”) of 45 rue Saint-Roch, 75001 Paris, France is the European branch of Parsons School of Design. Parsons Paris works closely with our US-based operations and certain information is shared between entities, so for purposes of this privacy notice, both The New School and Parsons Paris are data controllers. For more information on how your information is shared with third parties, please refer to Section 3 of this notice.
This privacy notice applies to all personal data we collect or process about you (i) from the information you provide to us when you interact with us before applying (e.g., when you express your interest in studying at The New School); (ii) when you apply to study at The New School and complete enrollment forms or other admissions documentation; (iii) when you communicate with us by telephone, email, or via our website (e.g., in order to make inquiries or raise concerns); (iv) when you interact with us during your time as a student at The New School; and (v) from third parties (e.g., from recruitment organizations, government agencies in connection with financial aid or student visas, or from your previous or current school, university, or employer(s), who may provide records or a reference about you, or who may sponsor or pay for your studies). This notice will inform you of:
- Personal data we collect and use;
- How we use your personal data and the basis on which we use it;
- Who has access to your personal data;
- How your personal data is protected and stored;
- International transfer of your data;
- How to exercise your rights;
- How to contact us; and
- Changes to the privacy notice.
1. Personal data we collect and use
We collect and use certain personal data about you. Personal data is information about you through which you can be identified (including where you can be identified by combining the information with other information).
Note that we may be required by law to collect certain personal data about you, or as a consequence of our contractual relationship with you. Failure to provide this personal data may prevent or delay the fulfilment of these obligations. We will inform you at the time your personal data is collected whether certain data is compulsory and the consequences of the failure to provide such personal data.
1.1 Personal data we collect directly from you
We collect some personal data directly from you. Personal data that is collected directly from you includes the following:
a) Personal details, such as your name(s), date of birth, and place of birth;
b) Contact details, such as your phone number, personal email address, mailing address, and social media handles;
c) Demographic details, such as your age, marital status, languages spoken, national origin, and current nationality;
d) Citizenship status;
e) Military or veteran status;
f) Identification numbers, such as your Social Security number or other government-issued identification number;
g) Authenticating information, such as user names, passwords, and security questions and answers;
h) Passport and visa information;
i) Financial information, such as your bank account information related to direct deposits;
j) Information relating to financial aid, scholarships, and immigration status, such as information collected in connection with financial aid applications, financial aid and scholarship eligibility, immigration applications, and information about your or your family’s or your sponsor’s financial situation;
k) Information about your location while on break from your studies;
l) Information you submit in connection with your application for admission, including your personal essay, portfolio, academic transcript, test scores, disciplinary records, work history, and other information submitted with your résumé;
m) Information about your preferences;
n) Photographs for use in identification;
o) Your emergency contact details, such as names of your emergency contacts and their contact information;
p) Communications you send us, including your requests and information provided by you in the form of feedback or complaints about the program, housing, or other matters; and
q) Information about your family, including the names of relatives who have attended The New School and education information.
1.2 Personal data generated by us
In addition, the following categories of personal data about you may be generated by The New School in the course of our relationship with you:
a) Student identifiers, such as your student ID number, NetID (user name for university systems), and other internal identification numbers;
b) University email address;
c) Employment details if you are employed by The New School as a student, such as work-study or other employment details, including salary or pay information, performance evaluations, and job actions;
d) Travel information, including a log of travel excursions;
e) Information about your computer and other devices, including your IP address, MAC address, and information about your browser and operating system;
f) Records of emergency incidents;
g) Student and education information, including your academic transcript, attendance records, grades, recommendations or feedback from teachers, and current and prior course schedules;
h) Student conduct records;
i) Audio and visual information captured by lecture capture systems, videoconferencing systems, web-based meeting applications, and similar technologies;
j) Visual information captured by security cameras;
k) Information regarding financial aid and eligibility for financial aid and scholarships;
l) Federal immigration documents; and
m) Information regarding building and cafeteria access.
1.3 Personal data we obtain from other sources
The New School may also obtain the following categories of personal data about you from third parties:
a) Contact and demographic information, including publicly available information, which we collect from third parties who provide us information about prospective students who may be interested in attending The New School. We may also collect this contact information from students about their parents, family members, and legal guardians;
b) Feedback and information from your teachers, school faculty, and others;
c) Information about your or your family’s or your sponsor’s financial status and ability to pay tuition or school expenses;
d) Academic performance, test scores, student conduct (including complaints brought by you, about you, or to which you may be a witness), and attendance information from other institutions; and
e) Non-academic performance information and feedback from organizations with which you have participated.
1.4 Sensitive data we collect and use
Some of the categories of personal data that we collect are considered special categories of personal data under European Union law. In particular, we may process the following types of sensitive data:
a) Health and medical information, including your medical history, information about your health during your time studying with The New School, information about disabilities or related accommodations, information about allergies or dietary restrictions, and health insurance information;
b) Information about your racial or ethnic origin;
c) Information about your gender identity, sex assigned at birth, and preferred pronoun (if you choose to disclose it for purposes of matching with roommates) and information about the facts and circumstances surrounding instances or allegations of sexual misconduct (which may be collected in the context of investigations into or adjudications of allegations of sexual misconduct, assault, or unlawful activity); and
d) Information about criminal convictions.
2. How we use your personal data and the basis on which we use it
The New School uses your personal data in connection with your engagement with and your enrollment at The New School for the following purposes:
- Considering your applications for admission and financial aid. Our basis for doing so is the performance of the pre-contractual relations we have with you and to serve our legitimate interests in selecting a diverse and qualified student body;
- Contacting you about our academic programs, events, related opportunities, or other updates about The New School. This processing is necessary to serve our legitimate interests in marketing and student outreach. Where required by law, we will obtain your consent before sending you marketing communications.
- Communicating with applicants throughout the application process. This processing is necessary to serve our legitimate interests in responding to applicant requests and efficiently managing the application process.
- Carrying out our contractual obligations to you and exercising our rights in this respect, including provision of academic and support services, travel accommodations, insurance, housing, and related services associated with The New School academic program. Our basis for doing so is the performance of the contract we have with you.
- Identifying students, including for creating a student identification card that includes your photo. This processing is necessary to serve our legitimate interests in keeping our campus and associated facilities safe and secure.
- Supporting teaching, learning, and staff development using audio and/or video recording of lectures, presentations, or training events. Our bases for doing so are the performance of the contract we have with you and serving our legitimate interests in delivering educational services to students and enabling professional development for our faculty and staff;
- Responding to emergencies, such as contacting you or your family in the event of an incident. This processing is necessary to serve our legitimate interests in supporting the health and well-being of our students;
- Program development, travel planning, student development, tracking of academic progression, and commencement exercises. This processing is necessary to serve our legitimate interests in the efficient management and administration of our academic programs and extracurricular activities;
- Keeping our campus and associated facilities safe and secure. This processing is necessary to serve our legitimate interests in protecting our students, property, and facilities;
- Operating our information technology systems. This processing is necessary to serve our legitimate interests in supporting your use of the systems, understanding usage and performance of the systems, investigating information security or data integrity incidents, and providing evidence in disciplinary procedures;
- Maintaining our alumni records. This processing is necessary to serve our legitimate interests in fostering relationships with alumni, maintaining alumni networks, and supporting our fundraising efforts;
- Meeting the obligations of private organizations with oversight over The New School, such as accreditation organizations. This processing is necessary to serve our legitimate interests in maintaining accreditation;
- Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration; and
- Complying with legal obligations to which we are subject, including to defend your and our rights in legal proceedings and to cooperate with regulators, law enforcement, and governmental or other competent bodies. This processing is necessary to comply with legal obligations and to serve our legitimate interests in complying with the laws to which we are subject.
2.1 How we use sensitive data
- Health and medical information. To the extent we process health and medical information, we do so to support your health and wellbeing while attending The New School and to respond to medical and mental health issues and emergencies. In the case of information relating to disability or other accommodations, we process such data to provide learning assistance, mobility, and other necessary accommodations. Our basis for doing so is compliance with social obligations laws or where there is a substantial public interest in providing such services or accommodations. Additionally, in some contexts we may rely on your prior consent to process such data.
- Information revealing an individual’s racial or ethnic origin. To the extent we process information revealing racial or ethnic origin, such information is voluntarily disclosed during the application process for purposes of statistical reporting related to diversity. We rely on your prior consent for such processing.
- Information about an individual’s gender identity, sex assigned at birth, and preferred pronoun. To the extent we process information about an individual’s gender identity, sex assigned at birth, and preferred pronoun, such information is voluntarily disclosed to help facilitate matching with roommates for student housing purposes. Students are not required to provide such information, and where they do we rely on the student’s prior consent to process the information.
- Information about the facts and circumstances surrounding instances or allegations of sexual misconduct. To the extent we process such data, we do so only in the context of investigations into or adjudications of allegations of sexual misconduct, assault, or unlawful activity. Our basis for doing so is that the processing is necessary for the initiation, exercise, substantiation, or defense of legal claims and that processing of sensitive information in this context serves a substantial public interest. To the extent such investigations do not specifically involve special categories of data as defined by applicable law, our basis for processing is that it is necessary to serve our legitimate interests in complying with our legal obligations.
- Information about an individual’s criminal convictions. Where permissible under law, we may process this information in the context of the admissions process.
3. Who has access to your personal data
We treat your personal data with care and confidentiality. Your personal data will be available for the purposes mentioned above and only to employees on a need to know basis and to the extent reasonably necessary to perform their functions. We may share your personal data with third parties under the following circumstances:
- Service providers and business partners. We may share your personal data with our service providers and academic or business partners that perform services for us. For example, we may partner with other companies or entities to provide services for you in relation to our academic programs or affiliated study abroad programs (for example, our mobility program), such as learning management system providers, information technology providers, emergency service providers, study abroad providers or other foreign institutions involved in our study abroad programs, homestay facilitators, tour operators, or other academic institutions. We may also partner with companies or other employers to provide internship opportunities to interested students; The New School may transmit your personal data or provide a recommendation for you to these organizations.
- The New School’s global headquarters and branch campuses. The New School’s branch campuses are a part of The New School, whose global headquarters is located in the United States. The branch campuses work closely with our US-based operations and, from time to time, with each other. As a result, we may share certain personal data about you collected or used in the context of our academic programs with other New School personnel located at our main campus in the United States or other branch locations.
- Law enforcement agencies, courts, regulators, government authorities, or other third parties. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- Private organizations with oversight over The New School. We may share your personal data to the extent necessary to meet the obligations of private organizations with oversight over The New School, such as accreditation organizations.
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International transfer of your data” below for more information.
4. How your personal data is protected and stored
We implement physical, technical, and organizational measures designed to safeguard the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data.
We will retain your personal data for as long as we have a relationship with you (throughout the duration of your studies and in many cases afterwards, as part of the alumni community). Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to:
- Maintain academic records;
- Comply with record retention requirements under applicable law;
- Defend or bring any existing or potential legal claims; and
- Resolve or otherwise address any complaints or queries relating to our programs.
Please note that personal data about admitted students is retained beyond graduation (or after your studies otherwise end), and the data is added to our permanent alumni records.
5. International transfer of your data
Your personal data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal data under the data protection laws of your locale.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal data is adequately protected. For more information on the safeguards in place, please contact us at the details below.
6. How to exercise your rights
You have certain rights regarding your personal data. You have the right to access personal data The New School holds, and in some situations you have the right to have that personal data corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). You may also object to how The New School uses your personal data if the legal basis for processing that information is our legitimate interest.
Where we are using your personal data on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to register a complaint to the applicable supervisory data protection authority.
If you wish to exercise these rights, or to notify us of a change in your details, or if you have any questions on the content of this notice, please contact us at firstname.lastname@example.org.
7. How to contact us
If you have questions or concerns regarding the way in which your personal data has been used, please contact us at email@example.com or:
The New School
Office of Information Security and Privacy
71 Fifth Avenue, 9th Floor
New York, NY 10003 USA
Our representative in the European Union is TNS Parsons, of 45 rue Saint-Roch, 75001 Paris, France.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the applicable supervisory data protection authority:
- For Parsons Paris, the supervisory data protection authority is the Commission Nationale de l’Informatique et des Libertés – CNIL, 3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07, https://www.cnil.fr/.
8. Changes to the privacy notice
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.
Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will notify you of the changes and give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
REVISED JUNE 24, 2020
REVISED APRIL 3, 2020
ADOPTED SEPTEMBER 4, 2019