Effective May 25, 2018
Information Berklee Collects from You
(Including Personal Information)
Berklee is an institute of higher education involved in education and community development. In order for Berklee to educate its students both in class and online and provide community services, it is essential, necessary, and Berklee has lawful bases to collect; process; use; and maintain data of its students, employees, applicants, and others involved in its educational and community programs. The lawful bases include, without limitation; admission; registration; delivery of classroom, online, and study abroad education, grades, communications, employment, development, program analysis for improvements, and records retention. Examples of data that Berklee may need to collect in connection with the lawful bases are: name; email address; IP address; physical address or other location identifier, and photos, as well as some sensitive personal data obtained with prior consent.
Most of Berklee's collection and processing of personal data will fall under the following categories:
- Processing is necessary for the purposes of the legitimate interests pursued by Berklee or third parties in providing education, employment, development, and community programs.
- Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Processing is necessary for compliance with a legal obligation to which Berklee is subject.
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Types of Personal Data Collected, and Why
Berklee collects a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often the data is used for academic admissions, enrollment, educational programs, job hiring, provision of medical services participation in research, development, and community outreach. Data typically includes name, address, transcripts, work history, information for payroll, research subject information, medical and health information (for student health services, or travel), and donations. If you have specific questions regarding the collection and use of your personal data, please contact our data privacy officers at firstname.lastname@example.org.
If a data subject refuses to provide personal data that is required by Berklee in connection with one of Berklee’s lawful bases to collect such personal data, such refusal may make it impossible for Berklee to provide education, employment, research or other requested services.
Where Berklee Gets Personal and Sensitive Personal Data
Berklee receives personal and sensitive personal data from multiple sources. Most often, Berklee gets this data directly from the data subject or under the direction of the data subject who has provided it to a third party (for example, application for admission to Berklee through use of the Application Portal).
Tools may be used to monitor the effectiveness of our communications with you, including email tracking, which records when an email sent from Berklee is opened and/or how many links are clicked within the message. The data from such tracking is used in an anonymized and aggregated form. In addition, we may collect other non-personal data such as IP addresses and web pages accessed on our websites.
Cookies and Tracking Technologies
Berklee may use "cookies," small files that are stored on your computer (unless you block them), to maintain a user's identity between web sessions. Cookies are stored on your hard drive and may be later accessed by the website to track prior usage. We may contract with third-party service providers to assist us in collecting and assessing cookies. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. You may disable cookies through your individual browser options.
Berklee uses Google Analytics, a web analytics service provided by Google, Inc. to gather statistics on website usage, such as how often each page has been visited. Many websites use these statistics to monitor and improve their services. Information collected and processed by Google Analytics includes the user's IP address, network location, and geographic location. Google Analytics acquires this information by installing a cookie on your computer. Berklee does not share any information it collects with Google, and Google Analytics does not collect any personal information such as names, contact information, social security numbers, or financial information. If you choose, you can opt out by turning off cookies through your individual browser options.
For more information on Google Analytics, please visit Google's “How Google uses information from sites or apps that use our services” page, located at google.com/policies/privacy/partners/.
Links to Other Websites
Berklee may include links to other internet sites as a convenience to users of its website. Users' access and use of such websites, including information, material, products, and services therein, are solely at the users' own risk. Berklee is not responsible for the privacy practices or the content of such other internet sites.
How to Manage Your Personal Information
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data.
- require Berklee to change incorrect or incomplete data.
- require Berklee to delete or stop processing your data, for example, where the data is no longer necessary for the purposes of processing.
- object to the processing of your data in certain circumstances, for example, where the school is relying on its legitimate interests as the legal ground for processing, or for direct marketing purposes.
- ask Berklee to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the school's legitimate grounds for processing data.
- withdraw your consent at any time, where we have requested and obtained your consent.
Where our lawful basis is consent or performance of a contract, we will allow portability of your data. If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the personal information that Berklee maintains about you, please contact us at email@example.com.
Storage and Security
Your personal data is held within our systems or the third-party service providers that provide Berklee and its community with various applications and services. The systems are accessed by the employees who have a relevant interest in the service or data to perform the services described above.
Berklee maintains and uses reasonable administrative, organizational, technical, and physical safeguards to protect your information from loss, destruction, misuse, unauthorized access, or disclosure as required by applicable law. This includes relationships with third-party providers. These technologies help ensure that your data is safe, secure, and only available to you and the authorized personnel at Berklee.
Your information will be retained by Berklee in accordance with applicable federal laws. Your information will be destroyed upon your 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 your information given the level of sensitivity, value, and criticality to Berklee.
The data controller is the Berklee College of Music, Inc. (Berklee).
Data protection officers
Our data protection officers team is responsible for advising Berklee on compliance with data protection legislation and monitoring its performance against it. If you have any questions or concerns regarding the way in which Berklee is processing your personal data, please contact our data protection officers team at firstname.lastname@example.org.