Data Privacy Notice
Effective as of 8 OCTOBER 2021
This privacy notice describes how Columbia University, 475 Riverside Drive, Suite 306, New York, NY 10034 USA (“we”, “us”, or “Columbia”), collects and processes personal information about you in connection with the Atlantic Fellows for Racial Equity programme (“AFRE”) collected through racialequity.atlanticfellows.org and all other AFRE digital properties that link to this notice, including AFRE websites, mobile applications, and digital communications (the “Services”). It also describes how we use, store, transfer and protect this personal information, as well as your rights in relation to this personal information.
Please note that AFRE is a programme of Columbia University in the City of New York, USA, which is implemented through a partnership between Columbia University and the Nelson Mandela Foundation, South Africa. It is part of a global network of Atlantic Fellows programmes that is coordinated by the Atlantic Institute, based at the Rhodes Trust in Oxford, UK.
This notice will inform you of:
How to contact us; and
1. Personal information we collect and use
When you use the Services (such as by visiting our websites), we collect and use certain personal information about you. Personal information is information about you through which you can be identified, including where you can be identified by combining the information with other information.
We collect personal information about you in different ways, including from you directly (e.g., when you contact us by email or request information through our website) and automatically when you access or use the Services (e.g., data collected from cookies and similar technologies as described below).
Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. For example, in order to subscribe to our email newsletter, we ask you to provide contact information (e.g., name, email address). If the information requested is marked as “optional,” you are not required to provide that information in order to subscribe to the newsletter. However, if you do not provide required information (such as your email address), we are unable to fulfil your email subscription request.
1.1. Personal information we collect directly from you
The categories of personal information that we collect directly from you include the following:
a) Personal details (e.g., first and last name, country of residence, country of origin).
b) Contact details (e.g., email address, phone number, mailing address).
c) Demographic information (e.g., gender, race and age).
d) Communications (e.g., when you submit questions or comments via our webform, send us an email, participate in polls or surveys).
e) Employment information (e.g., area of work).
f) Information about your preferences (e.g., communication preferences, email subscriptions).
g) Other information you submit to us (e.g., additional information submitted in connection with program applications, fund award applications, video selfies).
1.2. Personal information we automatically collect about your use of the Services
The following are examples of other categories of information that we automatically collect from you over time and across different websites when you use the Services, including through the use of “cookies”, which are small text files that the Services save on your computer using your web browser and access when you return:
(a) Technical data collected from your computer or mobile device (e.g., your IP address, browser type, operating system).
(b) Information about your usage of our Services (e.g., the pages you visit when using the Services, the search terms you enter on the Services, how often you use the Services, the pages you access before and after accessing the Services).
(c) Data that we generate about you as a result of your use of the Services (e.g., our understanding of your interests as a result of your use of the Services, whether you are a regular or occasional user of the Services).
For more information about cookies and how we use them on our websites, please refer to our Cookies Policy here/on page 6 of this document.
1.3. Sensitive information we collect and use
We collect the following information that may be considered sensitive in some jurisdictions:
(a) Information about your racial or ethnic origin.
2. How we use your personal information
We use your personal information for the following purposes:
Operating the Services: We process your personal information to provide the Services you have requested. This is so we can comply with our contractual obligations to you.
Considering your application: When you submit an application through the Services, we process your personal information to inform our decision-making process. Our basis for doing so is the performance of the pre-contractual relations we have with you and to serve our legitimate interests in finding diverse and qualified candidates for the programme.
Improving our Services: We analyse information about how you use our Services to provide an improved experience for users of our Services, including site testing and analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.
Communicating with you: We use your personal information when we communicate with you, for example, if you submit a comment or request through our webform; to communicate with you about an application you submit; or for sending you AFRE newsletters and publications. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Services. Where required by law we will obtain your consent before sending you marketing communications.
Marketing: we use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. Where necessary, we will obtain your consent before sending such marketing messages.
Exercising our rights: we use your personal information to exercise our legal rights where it is necessary to do so, for example, to detect, prevent and respond to claims of fraud, intellectual property infringement claims or violations of law or our standards of conduct, university policies, or our terms of use.
Complying with our obligations: we process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, as required by law.
Customizing your experience: when you use the Services, we use your personal information to improve your experience of the Services, such as by providing interactive or personalised elements on the Services and providing you with content based on your interests. It is in our legitimate interests to provide you with a customized experience.
For purposes of programme planning and development. This processing is necessary to serve our legitimate interests in the efficient management and administration of our academic programmes and extracurricular activities.
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.
We may also anonymise your personal information in such a way that you may not reasonably be re-identified by us or any other party, and we may use this anonymised information for any purpose.
2.1 How we use sensitive information
Information about your racial or ethnic origin. To the extent we process information revealing an individual’s racial or ethnic origin, such information is voluntarily disclosed during the application process and in response to surveys and is used for purposes of statistical reporting related to diversity.
3. Who has access to your information
We may share your personal information with the following parties:
The Atlantic Institute and the Nelson Mandela Foundation: We share your personal information with our partners in connection with the Atlantic Fellows program.
Service providers: We share your personal information with our service providers that perform marketing services and other business operations for us for the purposes set forth above. For example, we partner with companies to send newsletters, support email and messaging services, and analyse information.
Law enforcement agencies, courts, regulators, government authorities or other third parties. We may share your personal information 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.
4. How to exercise your rights
Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest.
Where you have provided consent and where applicable under local law, you have the right to withdraw any consent you have given at any time. You also have the right to register a complaint to the appropriate data protection authority, where applicable.
Please note that we may require additional information from you in order to honour your requests.
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 here.
5. How your personal information is protected and stored
We implement technical and organisational measures designed to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information.
We will retain your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
· Maintain our records (including academic records, if applicable).
· Comply with record retentions requirements under applicable law.
· Defend or bring any existing or potential legal claims.
· Resolve or otherwise address any complaints or queries relating to our programs.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the information.
6. International transfer of your information
Your personal information may be transferred to, stored, and processed in a country (such as the United States) that is not regarded as ensuring an adequate level of protection for personal information under the laws of your country.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us as described below.
7. How to contact us
If you have questions or concerns regarding the way in which your personal information has been used, please contact us here.
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 (where applicable) to make a complaint to the appropriate data protection authority.
You may contact the South Africa Information Regulator by mail at JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 or by email at inforeg@justice.gov.za (for general inquiries) or POPIAComplaints.IR@justice.gov.za (for data protection complaints).
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.
If we change this privacy notice, we will notify you of the changes. Where changes to this policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
Cookies Policy Statement
AFRE automatically collects anonymous information (such as your domain name and your computer’s IP address) using “cookies”, “web beacons” and other tracking mechanisms. This information is collected to help us tailor the website to visitor interests and concerns.
We also may use “web beacons” from third parties to help us compile aggregated statistics regarding the operations of our site. We may use similar technologies in our email communications to let us know which emails and links have been opened by recipients.
Our website is functional without the retention of cookies. You may elect to block cookies from this site through your browser settings or by electing to “decline” our website’s cookies.
CONTACT
If you have questions or comments about our privacy policy or practices, please contact AFRE.
Approved by Office of General Counsel, Columbia University.