Web Privacy

Sponsor: Information Technology Services
Contact: Chief Information Officer and Vice President for Information Technology Services
Category: Information Technology Services
Number: 1000.006
Effective Date: 06/14/2002
Implementation History: Approved: June 14, 2002 under the title “SUNY Empire State College Privacy Policy.” Revised: January 18, 2008 and title changed to “Web Privacy Policy."
Keywords: Web Privacy Policy

Purpose

This policy is consistent with the provisions of the Internet Security and Privacy Act, the Freedom of Information Law and the Personal Privacy Protection Law.

Definitions

The following definitions apply to, and appear in italics, in this policy:

Personal information: For purposes of this policy, "personal information" means any information concerning a natural person which, because of name, number, symbol, mark or other identifier, can be used to identify that natural person.

User: Shall have the meaning set forth in subdivision 8 of section 202 of the New York State Technology Law.

Statements

Empire State University is committed to protecting your privacy while making it easier and more efficient to interact with our university. You can navigate through much of the university's website without giving us any information about yourself. Sometimes we do need information to provide services that you request, and this commitment to privacy explains our online information practices.

We do not collect any personal information about you unless you provide that information voluntarily by sending an email, completing an online form or completing the online application.

This policy is consistent with the provisions of the Internet Security and Privacy Act, the Freedom of Information Law, and the Personal Privacy Protection Law.

Information Collected Automatically When You Visit this Website

When visiting this website, we automatically collect and store the following information about your visit:

User client hostname: the hostname or Internet Protocol address of the user requesting access to a college website.
HTTP header, "user agent": the type of browser, its version, and the operating system on which the browser is running.
HTTP header, "referrer": specifies the webpage from which the user accessed the current webpage
System date: date and time of the user's request.
Full request: exact request the user made.
Status: status code the server returned to the user.
Content length: content length, in bytes, of the document sent to the user.
Method: request method used.
Universal Resource Identifier (URI): location of a resource on the server.
Query string of the URI: anything after the question mark in a URI.
Protocol: transport protocol and the version used.
Processing time: time, in milliseconds, it took for the server to process the request.
Host header: hostname of the requested file, e.g., www.sunyempire.edu.
Cookies: name of any cookie used.

None of the above-mentioned information is deemed to constitute personal information by the Internet Security and Privacy Act.

In addition to the above-mentioned information, when you access a password-protected part of the website, your username is collected automatically.

All information that is collected automatically is used to improve our Web content, to investigate possible problems and in general to help us understand how you are interacting with our website. This information is collected for statistical analysis and to determine what information is of most and least interest to our users. The information is not collected for commercial purposes and the university does not sell or otherwise distribute the information collected from the website for commercial purposes.

Information Collected When You E-mail our Webmaster or Complete a Transaction

If you send an email to our Web manager, your email address and the contents of your message are collected. These are used to respond to you, to address issues you identify, to improve this website or to forward your message to someone who can help you. We do not disclose your email address to any person or organization outside the university.

If you voluntarily complete an online form, the personal information you provide will be retained in a way that is appropriate to complete your transaction. We do not knowingly collect personal information from children under the age of 13 or create profiles of children under the age of 13. Caution: if you submit personal information in an email, the information will be treated as though it was submitted by an adult, and may, unless exempted from access by federal or state law, be subject to public access.

Cookies

Cookies are simple text files stored on your Web browser to provide a means of distinguishing among users of this website. The use of cookies is a standard practice among Internet websites. To better serve you, we may use persistent and/or session cookies to enhance or customize your visit to this website. Persistent and session cookies that are created automatically on the device you use to access this website do not contain personal information and do not compromise your privacy or security. We may use the cookie feature to store a randomly generated identifying tag on the device you use to access this website. A session cookie is normally erased during operation of your browser or when your browser is closed. Some Web browsers retain session cookies by default; you can adjust your browser settings to ensure that session cookies are deleted. A persistent cookie remains on your computer until you decide to delete it. We use persistent cookies on some parts of our website to gather nonpersonal statistical data when you visit our website.
The software and hardware you use to access the website allows you to refuse new cookies or delete existing cookies. Refusing or deleting these cookies may limit your ability to take advantage of some features of this website.

Information and Choice

As noted above, Empire State University does not collect any personal information about you unless you provide that information voluntarily by sending an email, responding to a survey, or completing an online form. You may choose not to send us an email, respond to a survey, or complete an online form. While your choice not to participate in these activities may limit your ability to receive specific services or products through this website, it will not normally have an impact on your ability to take advantage of other features of the website, including browsing or downloading information.

Disclosure of Information Collected Through This Website

The collection of information through this website and the disclosure of that information are subject to the provisions of the Internet Security and Privacy Act. Empire State University will only collect personal information through this website or disclose personal information collected through this website if the user has consented to the collection or disclosure of such personal information. The voluntary disclosure of personal information to Empire State University by the user, whether solicited or unsolicited, constitutes consent to the collection and disclosure of the information by Empire State University for the purposes for which the user disclosed the information to Empire State University, as was reasonably ascertainable from the nature and terms of the disclosure.

However, Empire State University may collect or disclose personal information without consent if the collection or disclosure is: 1. necessary to perform the statutory duties of Empire State University, or necessary for Empire State University to operate a program authorized by law, or authorized by state or federal statute or regulation; 2. made pursuant to a court order or by law; 3. for the purpose of validating the identity of the user; or 4. of information to be used solely for statistical purposes that is in a form that cannot be used to identify any particular person.

Further, the disclosure of information, including personal information, collected through this website is subject to the provisions of the Freedom of Information Law and the Personal Privacy Protection Law.

Empire State University may disclose personal information to federal or state law enforcement authorities to enforce its rights against unauthorized access or attempted unauthorized access to Empire State University’s information technology assets.

Retention of Information Collected Through this Website

The information collected through this website is retained by Empire State University in accordance with the records retention and disposition requirements of the New York State Arts and Cultural Affairs Law. Information on the requirements of the Arts and Cultural Affairs Law may be found on the New York State Archives Managing Records web page. In general, the Internet services logs of Empire State University, comprising electronic files or automated logs created to monitor access and use of college services provided through this website, are retained in accordance with the records retention and disposition schedule established for the records of the Office of Educational Technology. Information, including personal information, that you submit in an email or when you complete a survey, registration form or order form is retained in accordance with the records retention and disposition schedule established for the records of the program unit to which you submitted the information. Information concerning these records retention and disposition schedules may be obtained through the Internet privacy policy contact listed in this policy.

Access to and Correction of Personal Information Collected Through this Website

Any user may submit a request to the Empire State University privacy compliance officer to determine whether personal information pertaining to that user has been collected through this website. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier generally known only to the user, or similar appropriate identification. The address of the privacy compliance officer is:
Privacy Compliance Officer
Empire State University
3 Union Avenue
Saratoga Springs, NY 12866
The privacy compliance officer shall, within five business days of the receipt of a proper request, provide access to the personal information; deny access in writing, explaining the reasons therefore; or acknowledge the receipt of the request in writing, stating the approximate date when the request will be granted or denied, which date shall not be more than 30 days from the date of the acknowledgment.
In the event that Empire State University has collected personal information pertaining to a user through the university website and that information is to be provided to the user pursuant to the user’s request, the privacy compliance officer shall inform the user of his or her right to request that the personal information be amended or corrected under the procedures set forth in section 95 of the Public Officers Law.

Confidentiality and Integrity of Personal Information Collected Through this Website

Empire State University is strongly committed to protecting personal information collected through this website against unauthorized access, use or disclosure. Consequently, Empire State University limits employee access to personal information collected through this website to only those employees who need access to the information in the performance of their official duties. Employees who have access to this information follow appropriate procedures in connection with any disclosures of personal information.

In addition, Empire State University has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, monitoring, auditing and encryption. These security procedures have been integrated into the design, implementation and day-to-day operations of this website as part of our continuing commitment to the security of electronic content as well as the electronic transmission of information.

For website security purposes and to maintain the availability of the website for all users, Empire State University employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage this website.

Disclaimer

The information provided in this privacy policy should not be construed as giving business, legal or other advice, or warranting as fail proof, the security of information provided through this website.

Contact Information

For questions regarding this Internet privacy policy, please email privacypolicy@sunyempire.edu
or write:
Privacy Compliance Officer
Empire State University
3 Union Avenue
Saratoga Springs, NY 12866

Applicable Legislation and Regulations