This is the Georgia Institute of Technology’s (Georgia Tech) Office of Development privacy and legal notice for compliance with the European Union General Data Protection Regulation (“EU GDPR”). For more information regarding the EU GDPR, please review Georgia Tech’s EU General Data Protection Regulation Compliance Policy.
Lawful Basis for Collecting and Processing of Personal Data
Georgia Tech is an institute of higher education involved in education, research, and community development. In order for Georgia Tech to communicate with alumni and other individuals who may have an interest in Georgia Tech, conduct fundraising and direct marketing for particular Georgia Tech initiatives or programs, and invite alumni and other individuals to Georgia Tech events (hereinafter, collectively, the “Programs and Activities”), it must collect, use, and process this personal data.
The lawful basis for the collection and processing of personal data by Georgia Tech’s Office of Development falls under the following categories:
- Processing is necessary for the purposes of the legitimate interests pursued by Georgia Tech or third parties in providing the Programs and Activities.
- The data subject has given consent to the processing of his or her special categories of sensitive personal data for one or more specific purposes.
Types of Personal Data collected and why
In order for Georgia Tech to provide the Programs and Activities, it needs to collect the following categories of personal data:
- Contact information including, without limitation, email address, physical address, phone number, and other location data
- Unique personal identifiers and biographical information (e.g. date of birth)
- Student information obtained from Georgia Tech records – degrees, majors, GT affiliations and clubs, awards, activities, and sports participation
- Employment information — company names and job titles
- Relationship information — spouse/partner’s name, children’s names, and familial relationships
- Activity information — event attendance, volunteer interests, committee participation, awards and honors
- Donor information — giving information regarding any donation which is made, including wealth assessment information and indicators of your interest in giving
The personal data collected by Georgia Tech’s Office of Development will be shared as follows:
Georgia Tech Unit
|Georgia Tech Academic Units||Communication, engagement, fundraising, and stewardship activities|
|Office of the President||Communication, engagement, fundraising, and stewardship activities|
|Office of the Provost||Communication, engagement, fundraising, and stewardship activities|
|Client Relationship Management platforms||Communication, online giving, alumni engagement, and donor prospect analytics|
|Georgia Tech Alumni Association||Communication, engagement, fundraising, and stewardship activities|
|Georgia Tech Foundation (GTF)||GTF maintains the database utilized for philanthropy and fundraising activities|
Georgia Tech is a unit of the Board of Regents of the University System of Georgia (the “BOR”), and data is shared with the BOR and its employees.
The Family Educational Rights and Privacy Act (FERPA) provides that “Directory Information” is information not generally considered harmful or an invasion of privacy if disclosed. Directory Information is considered public information, but the categories of information that comprise Directory Information also comprise “personal data” under the EU GDPR. Please review Georgia Tech's definition of Directory Information for further information, including how to prohibit the release of Directory Information.
Where Georgia Tech gets Personal Data and Special Categories of Sensitive Personal Data
Georgia Tech receives personal data and special categories of sensitive personal data from multiple sources. Most often, Georgia Tech 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 undergraduate admission to Georgia Tech through use of the Common App).
Individual Rights of the Data Subject under the EU GDPR
Individual data subjects covered by Georgia Tech’s EU General Data Protection Regulation Compliance Policy will be afforded certain individual rights.
Note: Exercising of these rights is a guarantee to be afforded a process and not the guarantee of an outcome.
Any data subject who wishes to exercise any of the above-mentioned rights may do so by filing such request with the Office of Enterprise Data Management at firstname.lastname@example.org
Security of Personal Data subject to the EU GDPR
All personal data and special categories of sensitive personal data collected or processed by Georgia Tech under the scope of the Georgia Tech EU General Data Protection Regulation Compliance Policy must comply with the security controls and systems and process requirements and standards of NIST Special Publication 800-171 as set forth in the Georgia Tech Controlled Unclassified Information Policy.
Georgia Open Records Act
As a state university, Georgia Tech is subject to the provisions of the Georgia Open Records Act (ORA). Except for those records that are exempt from disclosure under the ORA, the ORA provides that all citizens are entitled to view the records of state agencies on request and to make copies for a fee. The ORA requires that Georgia Tech produce public documents within three business days. For more information on Georgia Tech’s ORA compliance, please visit the Open Records Act page on the Legal Affairs website.
Georgia Tech follows the guidelines specified in the University System of Georgia Records Retention Schedules. Applicable record categories include:
- Administration (Financial Donor Records)
Georgia Tech’s Office of Development has a legitimate business need to permanently retain the data it collects as “the preservation of those historical records that document institution decision-making over time and that provide the history of the institution and the state.” See FAQ “What are the objectives of a records and information management program?” at https://www.usg.edu/records_management/faq/
If a data subject refuses to provide personal data that is required by Georgia Tech in connection with one of Georgia Tech’s lawful bases to collect such personal data, such refusal may make it impossible for Georgia Tech to provide education, employment, research, or other requested services.
If the EU GDPR applies to the collection of your personal data and you have specific questions regarding the collection and use of your personal data, please contact the Office of Enterprise Data Management at email@example.com.