UNIVERSITY OF NEBRASKA FOUNDATION
GENERAL DATA PROTECTION REGULATION (GDPR) DATA PRIVACY POLICY
Purpose of Policy
This policy is published for the benefit of University of Nebraska Foundation (UNF) donors and volunteers and University of Nebraska alumni who are citizens or residents of the European Union to explain what data is collected by UNF and how it is used. We are providing you with this information so you know what data we hold for you and why, and how we keep your data protected and in compliance with GDPR.
UNF
For purposes of this policy, UNF shall be used to refer to the University of Nebraska Foundation and all affiliated entities who have or will be granted access to the University of Nebraska Foundation’s database of donor, volunteer and alumni information.
Personal Data
For purposes of this notice, Personal Data is defined broadly as any information about you (the “data subject”) as an identified or identifiable natural person including your name, address, historical personal information, and virtually any other information that is or can be stored about you in UNF’s database.
Who is collecting your Personal Data?
UNF as the “Data Controller.”
What Personal Data is being collected?
UNF collects your contact details, your history with the University of Nebraska, biographical information, employment information (if available), matriculation information (if you attended the University of Nebraska), information about contacts with UNF or University of Nebraska staff, information on your interests that relate to events at or opportunities to support the University of Nebraska, and information related to your charitable donations to UNF.
How is my Personal Data being collected?
In most cases, UNF first acquires Personal Data from the University of Nebraska upon the graduation of classes from the different campuses. UNF also collects data that is shared by donors with UNF staff, data that is collected as gifts are made or received, data that may be collected during donor and other events, and data collected through purchased lists, data appends, wealth screenings and any publicly available sources.
What is the legal basis for processing your Personal Data?
Depending on the activity for which your Personal Data is used, UNF will rely on one of the following conditions for processing: a legitimate interest; a legal obligation; or your consent to process your Personal Data, as explained below.
“GDPR Article 6(1)(f) – Necessary for the purposes of legitimate interests pursued by the controller or third party, except where such interests are overridden by the interests, rights or freedoms of the data subject” UNF will hold Personal Data about your history attending the University of Nebraska in addition to all other Personal Data for the purpose of offering you a tailored opportunity to support the University of Nebraska in the specific ways that are or may be most important to you.
“GDPR Article 6(1)(c) -Processing is necessary for compliance with a legal obligation”
If you make or have made a charitable donation to UNF, we will process your name, address, and donation information under 6(1)(c) of the GDPR for the purpose of administering the charitable fund created with your donation.
“GDPR Article 6(1)(a) – Consent of the data subject”
If not relying upon another legal basis, UNF will only contact you about our events, services, and other fundraising activity if we have your express consent to do so. We may communicate with you by e-mail or traditional mail, unless you have asked us not to. To help us contact you in the best way possible, please make sure your preferences are up to date in our records.
Will your Personal Data be shared with any third parties?
Your Personal Data can only be accessed through the UNF database and therefore can only be seen by UNF personnel and those personnel of other entities which have access to UNF’s database. UNF will also share its database on a limited basis as appropriate with the university and other university-related entities such as campus alumni associations, Nebraska Medicine, which is the university’s clinical and hospital partner, and certain vendors.
How will your Personal Data be used?
UNF will use the Personal Data it has received from the University or that you have given us to contact you by mail, e-mail or telephone about relevant University activities or services you have opted in to receive. These may include:
• the sending of alumni publications
• the sending of UNF publications
• the promotion of benefits and services available to UNF donors
• notification of and distribution of information about events and reunions
• UNF fund raising and other supporter engagement programs
• volunteering opportunities
How secure is my Personal Data?
All personnel who have access to your Personal Data have received thorough training stressing the need to keep your Personal Data secure. Further, other university-related entities with which your Personal Data may be shared are strictly required to undertake data security measures which meet current professional standards.
How long will your Personal Data be stored?
UNF will keep your information only for as long as needed to provide you with the goods, services, or information you have required, to administer your charitable fund, to administer your relationship with us, to comply with the law, or to ensure we do not communicate with you after you have asked us not to. When we no longer need your Personal Data, we will always dispose of it securely.
What rights do you have as a data subject?
You have the following rights as a UNF donor and data subject:
• right of access to your own Personal Data.
• right of rectification (inaccurate Personal Data must be corrected)
• right to object to processing your Personal Data based on either public interests or legitimate interests
• right to object to direct marketing
• right not to be subject to automated processing
• right to be “forgotten” by UNF
• right to restrict processing (the right to have UNF restrict processing in certain situations)
• right of data portability
• right to object to processing for scientific, historical or statistical purposes
What rights do you have to raise a complaint?
You have the right to raise a complaint about any aspect of UNF’s processing of Personal Data by emailing GDPRPrivacy@nufoundation.org or writing to University of Nebraska Foundation, 1010 Lincoln Mall, suite 300, Lincoln Nebraska USA 68508.
What will UNF do in the event of a data breach?
In the event of a data breach, UNF is required to notify the appropriate “Data Protection Authority” within the European Union within 72 hours of the breach being discovered, unless it is demonstrably unlikely that the breach will result in a risk to you. UNF is also required to notify you if the breach is likely to result in high risk to you as an affected data subject. This risk is typically measured as the likelihood fraud will be committed with the leaked information or that publication of the information could cause extreme distress or embarrassment.
Who do I contact for more information or other requests?
Please direct all such inquiries or requests to GDPRPrivacy@nufoundation.org.
