Touro University is committed to protecting the privacy of the personal information of its employees, potential employees, faculty, independent contractors, vendors, suppliers, students and other stakeholders. We value the trust of those we deal with, and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you share with us.
The following privacy guidelines applies to all Touro University activities including, but not limited to, the Touro website (Site). Touro University respects your right to privacy. We invite you to participate in Touro activities and visit our site to search or browse the site without revealing who you are or registering with us. However, if you choose to give us personal information that we may need, it is our intent to let you know how we will use such information.
If you tell us that you do not wish to have this information used as a basis for further contact with you, we will endeavor to respect your wishes. You may only supply personal information to our website if you are submitting directly through a legitimate Touro source or utilizing a secure and encrypted internet connection. Touro University accepts no liability for information supplied to unofficial channels or via an unsecure or unsecure wireless connection.
Registration is not required for Touro to collect data. However, Touro will endeavor to only collect data where necessary and will also attempt to ensure that sensitive personally identifiable information is only collected on sections of the web site which do require a password, some examples include the intranet subsites.
Collection of IP addresses and the use of "Cookies"
When you visit our Site, some information such as your Internet protocol address, Internet service provider, operating system, the Site from which you arrived, and the time and date of your visit may be collected automatically as part of the software operation of this Site. This intake of information is not personally identifiable. Touro University uses this information solely for internal marketing purposes, for example, to see what pages are most frequently visited in order to improve the Site. After it is used for internal marketing purposes, this information is discarded.
We also collect information through the use of a technology called "cookies." A cookie is a small file that a website can send to your browser, which is then stored on your system by your browser. The use of cookie technology on Touro University is solely for internal marketing purposes. If you are uncomfortable accepting cookies from our Site or any other, you can set your browser to notify you when a Site attempts to send you a cookie, giving you the opportunity to decide for yourself whether or not to accept the cookie. You can also set your browser to turn off cookies.
Users Located in the European Economic Area
The Site provides a capability for users to submit their resumes to Touro University via email. Any resume so received by Touro University will be held in confidence and used only for the purpose of considering the submitting party for employment. Such information is not shared with third parties external to Touro University domestic and international branches. Remember, resume submission should be conducted with a secure and encrypted internet connection only.
Children's usage of the Site
This Site is intended for adult use only. It is not intended for children, and we ask that minors not submit any personal information to us.
Nature of Data on the Internet
It is Touro University's intent to guard any personal information that is in its possession, and Touro University will continue to take steps to maintain the security of such data. However, as a multi-national institution, the data we collect from you may be internationally distributed throughout Touro University and the open nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. Therefore, in submitting personal information to Touro from an unsecured and unencrypted connection, you assume the risk of a third party obtaining that information. Please do not supply Touro University with personal information in such a manner.
Any time Touro University collects information, it is Touro University's intent to inform you of why this information is being requested and how it is going to be used. We may collect personal information from you including phone, electronic mail address, and other information you choose to provide at various times, for example, when you complete an online form or request.
Touro University uses the personal information we collect to process your requests, inform you of educational opportunities that we believe you might find interesting, and to understand your needs so that we can provide you with the highest quality education and service. Touro University intends to protect and secure the personal information that you submit. Touro University will not sell, distribute, or give your personal information to any third party without your knowledge and consent. Touro University shall not be liable for any personal information that you submit to external vendors or to any web site linked to this Site.
Defining Personal Information
Personal information is any information that can be used to distinguish, identify or contact a specific individual. This information can include an individual’s opinions or beliefs, as well as facts about, or related to, the individual. Exceptions include business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories - these are not considered personal information. Where an individual uses his or her home contact information as business contact information as well, we consider that the contact information provided is business contact information, and is not therefore subject to protection as personal information.
Various jurisdictions have different laws regarding privacy. This policy contains ten (10) principles that we have found form the backbone of much privacy legislation. Using each of the ten principles, Touro University has developed the following practice:
Touro University is responsible for all personal information under its control and remains responsible when personal information is processed by third parties on their behalf.
- The Chief Information Security Officer (CISO) for Touro University is Patricia Ciuffo. This is communicated both internally and externally for public knowledge. The CISO is responsible for understanding the broad impact of privacy, for the implementation of policies and procedures, and handling any complaints.
- Touro University is responsible for personal information in its possession or custody, including information that has been received by a third party and requiring their adherence to privacy legislation.
(2) IDENTIFYING PURPOSES
Touro University will identify the purposes for which personal information is collected, at or before the time the information is collected.
- The primary purposes for the collection of personal information is to deliver services and to keep individuals informed and up-to-date on the activities of Touro University, including programs, services, special events, projects, employment opportunities, solicitations and more through periodic contacts.
- When personal information that has been collected is to be used for a purpose not initially identified, the new purpose shall be identified prior to use.
- Personal information may be supplied in connection with a job application or educational inquiry, whether advertised on this website or otherwise, you may provide us with information about yourself, such as a resume or curriculum vitae. We may use this information throughout Touro University and its related entities for the purpose of employment consideration or your educational inquiry. Except where you tell us not to, we will keep the information for future consideration.
- If you request something from our website, for example, course materials, educational information, a callback, or specific marketing materials, we will use the information you provide to fulfill your request. To help us do this, we may share information, with others, for instance, other parts of Touro University, Touro University's Educational Partners, financial institutions, shipping companies, postal or government authorities (for example, immigration or customs authorities) involved in fulfillment. In connection with a transaction we may also contact you as part of our customer satisfaction surveys or for market research purposes.
- The information you provide to Touro University may also be used by Touro University and selected third parties for marketing purposes. We will offer you the opportunity to choose whether or not to opt-out of having your information used in this way.
- If you represent a Touro University Educational Partner, you may visit a Touro University website intended specifically for Touro University Educational Partners. We may use information provided on that site to administer and develop our relationship with you, the partner you represent, and other partners generally. For instance, this may involve using your information to send you details of Touro University partner or alliance programs. It may also include sharing certain information with other Business Partners (subject to any confidentiality obligations that may exist), or Touro University students or prospects. In connection with a particular transaction or program, we may also contact you as part of student satisfaction surveys or for market research purposes.
- If you represent a Touro University supplier, vendor or consultant, you may visit a Touro University website intended specifically for use by you. We may use the information provided on that site in connection with entering into or performing a transaction with you. For example, this may include sharing information with other parts of Touro University, Touro University's partners, shipping companies, financial institutions, postal or government authorities involved in fulfillment. It may also be used to administer and develop our relationship with you, the entity or consultants you represent and/or other Touro University vendors and suppliers generally.
Knowledge and consent by the individual for the collection, use and disclosure of personal information will be obtained by Touro University. Indeed, your submission of your personal information over a secure and encrypted internet connection is tacit consent to collection, use and disclosure of personal information obtained by Touro University.
- As you can readily discern, this consent is stated in such a manner that individuals supplying personal information can reasonably understand how the information will be used or disclosed.
(4) LIMITING COLLECTION
The collection of personal information shall be limited to that which is necessary for the purposes identified by Touro University. All personal information shall be collected by fair and lawful means.
- Touro University does not collect personal information indiscriminately. Both the amount and type of information collected is limited to that which is necessary to fulfill the purposes identified.
- Any new purposes for the use of an individual’s personal information will require the individual’s consent.
- We will only collect personal information by fair and lawful means and we will never collect information by misleading or deceiving individuals about the purpose for which information is being collected. Thus we require and obtain your consent with respect to collection, use or disclosure and never will we obtain such consent through deception.
(4) LIMITING USE, DISCLOSURE AND RETENTION
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
- Personal information will be stored in confidence and accessed only by authorized Touro University employees, faculty and agents or consultants retained by Touro University.
- Personal information will be retained only as long as necessary for the fulfillment of those purposes. Personal information that is no longer required will be destroyed, erased or made anonymous in accordance with current Touro University Document/Records Retention Policy.
By supplying your personal information you affirm that such information is accurate, complete and up-to-date as is necessary for the purposes for which it is used by Touro University, taking into account its use and the interests of the individuals.
- Personal information shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information be used to make a decision about the individual.
- Touro University will update an individual’s personal information only when necessary to fulfill the specific purposes for which it was collected.
Touro University will take steps to protect personal information from theft and loss, as well as unauthorized access, disclosure, copying, use or modification. The methods of protection include:
- Physical measures (locked filing cabinets, restricted access to files and offices);
- Technological measures (passwords, encryptions, firewalls, and audits);
- Organizational measures (clearances, “need-to-know” access, etc.); and
- Staff training that includes the sharing of all Touro University privacy policies and procedures.
Touro University will make readily available to individuals specific information about Touro University's policies and practices relating to the management of personal information. Touro University will make these policies and practices understandable and easily available through a variety of forms, including this very posting. Information about these policies and practices may be made available in person, in writing, by telephone, in publications and, as you can see, on the Touro University website. The information made available will include:
- the name or title and business address of the person who is accountable for Touro University's privacy policies and practices and to whom complaints or inquiries can be forwarded;
- the means of gaining access to personal information held by Touro University;
- a description of the type of personal information held by Touro University, including a general description of its use and disclosure.
(8) INDIVIDUAL ACCESS
Upon request by an individual, Touro University shall inform the individual of the existence, use and/or disclosure of his or her personal information and be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Individuals have the right to be given access to their personal information (except where it contains references to other individuals or if it cannot be disclosed for legal, security or commercial proprietary reasons). Touro University will advise the individual of the reason for denying the access request.
- Touro University will respond to an individual’s request within a reasonable time and at minimal or no cost to the individual related to retrieval, photocopying and delivery.
- In providing an account of third parties to which it has disclosed personal information about an individual, Touro University will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, Touro University will provide a list of organizations to which it may have disclosed information about the individual.
(9) Key Requirements for Data Protection Framework (DPF)
Touro shall comply with the following in adhering to the Data Protection Framework (DPF) program:
- Informing individuals about data processing
- A participating organization must inform individuals of their rights to access their personal data, the requirement to disclose personal information in response to lawful request by public authorities, which enforcement authority has jurisdiction over the participating organization’s compliance with the DPF Principles, and the participating organization’s liability in cases of onward transfer of data to third parties.
- Providing free and accessible dispute resolution
- Individuals may bring a complaint directly to a participating organization, and the participant must respond to the individual within 45 days.
- Participating organizations must provide, at no cost to the individual, an independent recourse mechanism by which each individual’s complaints and disputes can be investigated and expeditiously resolved.
- If an individual submits a complaint to a data protection authority (DPA) in the European Union / European Economic Area, the United Kingdom (and/or, as applicable, Gibraltar) or Switzerland, the U.S. Department of Commerce’s International Trade Administration (ITA) has committed to receive, review and undertake best efforts to facilitate resolution of the complaint and to respond to the DPA within 90 days.
- Participating organizations must also commit to binding arbitration at the request of the individual to address any complaint that has not been resolved by other recourse and enforcement mechanisms.
- Cooperating with the U.S. Department of Commerce
- Participating organizations must respond promptly to inquiries and requests by the ITA for information relating to the EU-U.S Data Privacy Framework (EU-U.S. DPF) and, as applicable the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
- Maintaining data integrity and purpose limitation
- Participating organizations must limit personal information to the information relevant for the purposes of processing.
- Participating organizations must comply with the data retention provision.
- Ensuring accountability for data transferred to third parties
To transfer personal information to a third party acting as a controller, a participating organization must:
- Comply with the Notice and Choice Principles; and
- Enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the DPF Principles and will notify the organization if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.
- Transfer such data only for limited and specified purposes;
- Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the DPF Principles;
- Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the DPF Principles;
- Require the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles;
- Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and
- Provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the U.S. Department of Commerce upon request.
- Transparency related to enforcement actions
- Participating organizations must make public any relevant DPF-related sections of any compliance or assessment report submitted to the Federal Trade Commission (FTC) or the U.S. Department of Transportation if the organization becomes subject to an FTC or court order based on non-compliance.
- Ensuring commitments are kept as long as data is held
- If an organization leaves the relevant part(s) of the DPF program, it must annually affirm to the ITA its commitment to apply the DPF Principles to information received under the relevant part(s) of the DPF program if it chooses to keep such data; otherwise, it must provide “adequate” protection for the information by another authorized means.
(10) CHALLENGING COMPLIANCE
An individual can challenge Touro University's compliance with the above principles through the Chief Information Security Officer.
- Touro University has put these procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures is accessible and simple to use. To initiate a complaint all an individual must do is notify Chief Information Security Officer and provide information and assistance to allow Touro University to properly investigate the claim.
- Touro University shall investigate all complaints. If a complaint is found to be justified, Touro University will take appropriate measure, including, if necessary, amending its policies and procedures.
- by email at firstname.lastname@example.org
- by phone at 646.565.6000 x55127
- or by mail at: 50 W. 47th Street, 14th Floor New York, New York 10036
By submitting any information to Touro University, including but not limited to, using or viewing the Touro website, the individual agrees to submit all controversies, claims, and disputes that may arise between the individual and Touro University to expedited binding arbitration. INDIVIDUAL APPRECIATES AND UNDERSTANDS THAT OTHER OPTIONS SUCH AS FEDERAL AND STATE ADMINISTRATIVE AND JUDICIAL REMEDIES MAY EXIST; THAT BY CONSENT THOSE REMEDIES ARE FOREVER PRECLUDED; AND THAT REGARDLESS OF THE NATURE OF THE COMPLAINT, INDIVIDUAL KNOWS THAT THE COMPLAINT CAN ONLY BE RESOLVED THROUGH ARBITRATION. INDIVIDUAL CONSENTS AND AGREES, CLEARLY AND UNAMBIGUOUSLY, TO ARBITRATE ANY AND ALL DISPUTED CLAIMS AND BY VIEWING AND USING THIS SITE THE INDIVIDUAL IS ACCEPTING THIS ARBITRATION PROVISION. INDIVIDUAL WAIVES THE RIGHT TO A TRIAL BY JURY. INDIVIDUAL KNOWINGLY AND VOLUNATRILY AND WITHOUT DURESS OR COERCION CONSENTS TO THIS ARBITRATION REQUIREMENT. This consent to binding arbitration covers and includes any dispute, controversy or claim arising out of or relating to this policy. The ADR Organization and a single arbitrator shall be chosen by Touro in its sole and absolute discretion. The arbitration will take place in New York, New York with the cost of the arbitration shall be split equally between the parties, with each party responsible for their own attorney fees. The removal of a matter from mediation to binding arbitration shall be triggered, and the time therefore shall commence, on the earliest date of (a) the date when the mediation ended without fully resolving the dispute at issue, or (b) the date on which either party gives written notice to the other of impasse. The laws of New York State shall apply without regard to its conflict of law provisions.