Global Affairs Statement of Privacy Practices – General Data Protection Regulation

UC Davis is committed to protecting personal privacy and the personal information collected via its departmental and official webpages. Please reference the Web Page Privacy Policy (PDF) or the UC Davis Privacy and Accessibility webpage for more information.
 

• Skip to: Transparency
• Your Data
• How We Use Data
• Recipients of Data
• Security
• Retention
• Transfer
• Automated Decisions
• Your Rights

1. Transparency Regarding the Use of Your Personal Data

As part of our commitment to protecting your privacy, this statement is designed to provide you with information regarding how Global Affairs, part of UC Davis, collects and processes the information you share when you interact with our website located at globalaffairs.ucdavis.edu and each of its associated domains, including but not limited to studyabroad.ucdavis.edu, siss.ucdavis.edu, confucius.ucdavis.edu, and blum.ucdavis.edu, and chile.ucdavis.edu (together, called the "Sites"); utilize our services; enter your information into forms; request to join an email list; or when you otherwise communicate or interact with Global Affairs services or any service on its associated domains (together, the “Services”). This statement is applicable to individuals using Services who are located in the European Economic Area (“EEA”). Global Affairs consists of many units at UC Davis, which may be found on our website. 

For purposes of the General Data Protection Regulation (“GDPR”), the data controller is the Regents of the University of California, with a location at Global Affairs, International Center, UC Davis, One Shields Avenue, Davis, CA 95616, United States.

2. Your Personal Data We Use

Information you provide directly to UC Davis Global Affairs

Global Affairs collects personal information about you called Personal Data. Your Personal Data is collected when you register or fill in a form related to Global Affairs Services or contact Global Affairs. This includes information you provide when you register to use Services, browse country profiles and partnerships/agreements sections, search global outreach efforts and funding opportunities, subscribe to newsletters and email lists, attend Global Affairs events, fill in online forms, contact us, request information, or otherwise provide information to Global Affairs.  Depending upon the specific Global Affairs Service you use, the information you give us may include: name, address and telephone number, email address,  international expertise and language skills, countries visited, connections to external institutions or programs, areas of specialization, studies or degrees pursued at external institutions, information entered during registration for services, events, or joining an email list,  as well as any information about you that is associated with, linked to, or could be linked to, any of the foregoing data.

Global Affairs also collects information from other UC Davis departments, such as information about grants and agreements of cooperation, collaborative and sponsored research programs and contracts, travel reports, students visiting or attending UC Davis, students studying abroad, international students and scholars studying, visiting or working at UC Davis, other academic and non-academic programs, and outreach programs.

Information from Other Sources: If you are a UC Davis Student, Global Affairs will also collect information from the UC Davis Student Information System, BANNER. Additionally, Global affairs obtains information from travel records, Study Abroad, Services for International Students and Scholars (SISS), and other programs associated with Global Affairs.

• Information you provide directly to UC Davis SISS

• SISS collects and processes Personal Data from you each time you visit our iGlobal website, communicate with our staff in person or electronically. SISS is known as a controller of the Personal Data you (data subject) provide us. SISS, its staff, affiliated university units and staff as well as other US secondary and higher education institutions, US Federal and State governmental agencies and their staff are known as processors of the Personal Data you provide us. Processing is necessary to the legitimate interests of an organization or a third-party affiliate.  It is required that you submit this data in order to study, visit or be employed at UC Davis or UC Davis Health System.  A UC Davis international student or scholar is any student, visiting researcher or employee who is not a Permanent Resident, US Citizen, Refugee/Asylee or in AB540/undocumented status.  The following types of Personal Data we collect or process from you, on behalf of a controller, may include but are not limited to: demographic, biographical, financial, gender, birthdate, email address, addresses, phone numbers, Student and Exchange Visitor Information System (SEVIS) ID, student ID, employee ID, emergency contact, driver’s license, major(s), field of study/research for employment, educational level, class standing, academic standing, academic transcripts, academic information, citizenship type, immigration status, residency for tax purposes, employment, employer, location of employment, internet browser, person(s) with your approval to share information, computer type, grades, minor(s), health, health insurance, passport information, US Port of Entry, disabilities, digital photo, travel, health insurance, English proficiency, UC Davis network ID, Student Support and Judicial Affairs (SSJA) correspondence, criminal record, athlete status and transfer student status.

  Information from Other Sources: SISS also obtains information from other sources and combines that information with information that you provide directly to SISS.  If you are a UC Davis international student, scholar, or employee, SISS may also collect or process your Personal Data from the Student and Exchange Visitor Information System (SEVIS), SEVIS OPT Portal,  Department of State (DOS), Department of Homeland Security (DHS) correspondence and databases, BANNER Student Information System, Department of Labor (DOL)/Foreign Labor Certification system, Export Control system governed by UC Davis Office of Research, UC Education Abroad Program online database, and OASIS academic database.  We receive criminal records from law enforcement and SSJA. The scope and types of data that SISS collects from other sources are the same as the list in the previous section under “Information you provide directly to UC Davis SISS.”

• Information you provide directly to UC Davis Study Abroad

• UC Davis Study Abroad collects or processes Personal Data from you each time you visit our Study Abroad websites, create a Study Abroad profile, complete an enrollment for a Study Abroad program, sign-up for emails, visit our office, or communicate with us in any other way or form. If you are not a UC Davis student, Study Abroad will collect all application information directly from you.  UC Davis Study Abroad and its staff is a controller of the Personal Data that you (data subject) provide us.

  UC Davis Study Abroad has affiliated partners and providers including outside vendors offering services related to Study Abroad and external institutions that are hosting Study Abroad programs.  These affiliated partners and providers are processors of the Personal Data you provide us. Personal data we collect or process from you, on behalf of a controller, may include but is not limited to: full name, student status, finances, financial aid status and other financial information, programs of interest, email address, phone numbers, college campus, student ID, birthdate, major(s), social security number, GPA, class standing, Educational Opportunity Program (EOP) eligibility, gender, transcripts, ethnicity, academic information, citizenship, residency, location, internet browser, authorized users, computer type, grades, minor(s), mailing addresses, gender identity, preferred gender pronouns, lived name, disciplinary clearance, health information, passport information, emergency contact information, driver’s license information, disabilities, t-shirt sizes, food allergies, dietary restrictions, non-food allergies, digital photo, transcript information, travel information, online usernames and passwords, student-athlete status, international student status, transfer student status, scholarship essays, and scholarship information.

  Information from Other Sources: UC Davis Study Abroad also obtains information about you from other sources and combines that information with information we collect from you directly. For example, if you are an UC Davis Student, we collect information about you when you enroll in UC Davis from the UC Davis Student Information System, BANNER. We may also collect information from the UCEAP database. We may also collect information about your visits to major and/or college advisors via the appointment scheduler OASIS, as well as your Student Affairs record. We may also check bill payment status through your Student Record, and/or our PCI-validated third party gateway TouchNet. The information we obtain from other sources includes your name, major(s), minor(s), birthdate, student ID, GPA, class standing, EOP eligibility, gender, transcripts, ethnicity, academic information, citizenship, residency, student affairs status, notes entered into your student record from various advisors on campus, transcripts, international student status, student-athlete status, and transfer student status, payment status, payment transaction ID as well as any information about you that is associated with or linked to, or could be linked to, any of the foregoing data.  

Log, Cookie and Device Data

Global Affairs also collects log data, which is information collected whenever you visit a website. This log data includes your Internet Protocol address, browser type and some settings, the date and time of your request, how you used the Service, and cookie data. UC Davis websites use “cookies” (small text files stored by your computer when you visit our website) or similar technologies. In addition to log and cookie data,  websites collect information about the device you are using to access the Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or Android phone. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider. Third party cookies are placed by other entities, such as Google Analytics, when you visit our website.

Global Affairs websites track analytics using Google Analytics, contain internal departmental forms and forms provided by Qualtrics, link to social media, email list signup, as well as embedded YouTube videos within some webpage content.

Global Affairs websites use Google Analytics to collect information such as site usage, page traffic, pages viewed, time spent on pages, links clicked, queries, general geographic locations of users, and other information about you and how you use and interact with Sites. More information on how Google uses your data may be found at:

• Google privacy policies
• Google partner sites 

Any Qualtrics forms that you fill out adds an additional cookie. More information may be found via Qualtrics:

• Qualtrics privacy statement

Global Affairs websites may contain links to other websites. We are not responsible for websites outside Global Affairs, the content found there, cookies entailed by using those external websites, and the privacy and security measures for handling your data on those websites.

Global Affairs websites contain links to social media sites, video players, and email sign-up. Some of these privacy policies include but are not limited to:

• Vimeo
• Google (covers YouTube)
• Twitter
• LinkedIn
• Facebook (privacy)
• Facebook (cookies)
• Endurance (Constant Contact email signup)

For more detailed information about how we use cookies, please contact the UC Privacy Official identified in section 10 of this documents.

Global Affairs uses services provided by QS Unisolution. Their cookie and privacy policies are compliant under GDPR. However, the Global Affairs privacy policy governs the use of your data through these services.

3. How We Use Your Personal Data and the Lawful Basis for Such Processing

We process data regarding international linkages/connections between UC Davis faculty, staff, and students with other countries and institutions as well as international students, faculty, staff, and other visitors who are involved with UC Davis through visits, academic and non-academic programs, collaborative research, agreements of cooperation, and other global engagement relationships.

Your data is processed through data centers hosted in Canada and housed in the cloud by QS-Unisolution. Their privacy policy may be found online.

Global Affairs processes your personal data for the following purposes:

• Providing newsletters and other information through email lists for people who sign-up at events or online (consent-based);
• Responding to requests for information (legitimate interest to inform interested parties about activities and opportunities, academic and non-academic programs, communication options and engagement with personnel);
• Providing summary information about UC Davis’s global connections with higher education and other institutions domestically and in other countries online, internally, and for people from Global Affairs traveling abroad (legitimate interest to inform potential collaborators, students and other interested parties about UC Davis’ research, academic programs, outreach and programs abroad);
• Providing searchable information on the website about programs in other countries, visits and visitors from other countries, or faculty, staff and students with connections to other countries and institutions (legitimate interest to provide information to those who might want to participate in or expand upon those connections);
• Providing information about faculty with global expertise (legitimate interest to provide information for prospective research collaborators and students and for maintaining an historical record);
• Providing information about collaborative research projects with other countries and institutions (legitimate interest for marketing purposes and for prospective students and scholars and for maintaining an historical record);
• Providing information about partner institutions, research collaborations, and other linkages with international institutions (legitimate interest for the information to be used for networking purposes by Global Affairs leaders when traveling overseas and for archival purposes);
• Providing information about learning opportunities and programs offered to international visitors (legitimate interest so the international visitors may find the programs that they are interested in);
• Providing you with information regarding UC Davis events and initiatives. We will only do this when it is in our legitimate interest;
• Providing informative summaries of UC Davis’ connections with specific countries (legitimate interest to provide information for prospective research collaborators and students and for maintaining an historical record);
• Providing trends, statistics, and summary data to be used for marketing and communications (legitimate interest).
• Processing and dealing with any complaints or inquiries made by you or legally on your behalf (legitimate interest as part of the services UC offers and as a legal requirement);
• UC may also be required to disclose your personal data to authorities who can request this information by law that is binding on UC.

We need your information to provide prospective students, scholars, and research collaborators information about faculty at UC Davis and their research programs throughout the world to encourage future scholarship and collaborations.

In certain instances, UC may be required to obtain your consent to collect and process your Personal Data for a specific purpose. This depends on the specific category of data collected and the intended use of the data.  In these instances, the UC Service will inform you of the specific category of personal data that will be collected and the intended purpose of the collection, and will request that you affirmatively indicate that you consent to the intended collection of your Personal Data for that purpose, prior to collecting the data. 

In these instances, if you do not consent to the collection and intended processing purpose, UC will refrain from collecting and processing your Personal Data.

• In addition, Services for International Students and Scholars (SISS), specifically, processes your Personal Data for the following purposes and to comply with immigration-based legal obligations:
• Processing is necessary to the legitimate interests of an organization or a third-party affiliate.
  
  Manage the submission, review, administration and approval of your information and requests through sunapsis (iGlobal), Department of Homeland Security’s Student and Exchange Visitor Information System (DHS SEVIS), US Department of Labor (DOL), US Department of State (DOS).
  
  Submit applications by paper to US Citizenship and Immigration Services (CIS).
  
  Provide proactive alerts and information regarding your immigration status and deadlines.
• In addition, Study Abroad, specifically, processes your Personal Data for the following purposes and basis: 
• Manage the marketing of programs related to you, your interests, and majors/college, which is consent-based lawful processing based on your consent given in the Study Abroad Horizons Database, field “Do you agree to the statement of consent?”
  
  Ensure study abroad eligibility, the submission and review of your enrollment into any Study Abroad program which is contract-based lawful processing based on your agreement to the field “Information Disclosure” in the participant contract of your Study Abroad program.
  
  Creating program email lists for your specific program, so that your Program Instructor can communicate with your entire class regarding assignments, trips, discussions and provide additional information about other research or scholarship opportunities that may be related to your program. The program listservs are a contract-based lawful processing based on your agreement to the field “Information Disclosure” in the participant contract of your Study Abroad program.
  
  Coordinate between Study Abroad and its affiliated partners for program purposes such as, but not limited to, advising, housing, flights, accommodations, courses, scholarship awards, financial aid packaging, emergency response, vacations away from program, and clearances to travel/study abroad, which is contract-based lawful processing.
  
  Analyze Study Abroad trends for research purposes, with all personal identifiers removed, which is considered lawful processing as it is a legitimate interest.

4. Recipients of Your Personal Data

 Global Affairs may share your personal data with the following recipients:

• Other UC locations or UC departments, as well as other US institutions of higher education: In order to provide you with a UC Service or where it is in UC’s legitimate interests. If you are a non-UC Davis student, Study Abroad may also share your Personal Data with your home campus for reporting purposes such as the annual Institute of International Education’s Open Doors report, or so your home campus can verify participation on a UC Davis Study Abroad Program. If you are an international student or scholar, refer to the earlier SISS section under Section 2 of this document.
• Service Providers: Vendors that need access to your personal data in order to provide Global Affairs’ Services. This includes QS Unisolution’s cloud-based services, which may reside in the EU, the UK, US and Canada and a data-processing center in Canada. This also includes Horizons by Symplicity’s cloud-based services, which may reside in the UK, US, Australia, and Canada. This also includes all Study Abroad affiliated partners, which are located in most countries across the world.
• UC Partners and Collaborators: When permitted by law, UC may share personal data with other academic research institutions in order to support Global Affairs’ mission of inspiring global curiosity, understanding, and engagement.  
• Public and Governmental Authorities: Entities that regulate or have jurisdiction over UC such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
• Corporate Transactions: A third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of UC’s business.

If your personal data is shared with a third party, UC will require that the third party use appropriate measures to protect the confidentiality and security of your personal data.

Information stored in Global Affairs’ MoveOn database is transferred through a data center in Canada and hosted in cloud-based services based in the European Union. These services have cookie and privacy policies that are compliant under GDPR (disclaimer and privacy policy). The Global Affairs privacy policy governs the use of your data through these services.

Information entered into forms on the Global Affairs and affiliated websites may be processed internally, through other UC Davis departments or divisions, or through Qualtrics as a service provider. The Qualtrics privacy policy may be found at online; however, the Global Affairs privacy policy governs the use of your data through these services.

When you sign up to join Global Affairs and affiliated general email lists, your data is processed through Constant Contact, Sympa, or other service providers. The Constant Contact privacy policy may be found online.

We may also need to share your personal data as required to respond to lawful requests and legal process; to protect our rights and property and those of our agents, customers and others, including to enforce our agreements and policies; and in an emergency, to protect UC and the safety of our students, faculty and staff or any third party.

• Services for International Students and Scholars (SISS)

• SISS processes your Personal Data in Davis and Sacramento, California. SISS may share your data for legal and business purposes. For legitimate university business purposes and to assist you with U.S. immigration benefits and maintaining your legal status, SISS shares information with affiliated UC Davis units and staff, other U.S. secondary and higher education schools, our partners including, but not limited to, DHS, DOS, Social Security Administration (SSA), DOL and California governmental agencies including California Department of Motor Vehicles (DMV). Upon request from US Federal Bureau of Investigation, DHS Immigration Customs Enforcement (ICE), U.S., State or Local law enforcement, in very rare cases, SISS may be required to release all of the information we have in our database as well as any hard copy file(s), electronic communications and documents to law enforcement officials.

  For marketing, communications and annual reports, SISS provides summary statistics to processors such as Institute for International Education (IIE), UC Davis units as well as other universities inside and outside of the United States. None of the information released contains sensitive data or personally identifiable information.

  Information in sunapsis (iGlobal is front facing website) is stored and hosted at UC Davis Information and Educational Technology (IET) Private Cloud Service hosted in a VMWare environment behind a firewall within the U.S. If you are in F-1 or J-1 SEVIS status, your data is sent to SEVIS system via a secure connection between sunapsis and SEVIS with a digital certificate. Your data is also provided to U.S. DOL, DOS and DHS. When technology does not allow for electronic transmission, SISS is required to send hard copy paper documents to government agencies; however, every effort is made to collect your information securely on campus via secure web forms and digital signatures and to send your information securely.

5. Security

UC takes appropriate physical, administrative and technical measures to protect personal data that are consistent with applicable privacy and data security laws and regulations. For more information about how UC protects data, refer to IS-3 Electronic Information Security.

If your personal data is shared with a third party, UC will require that the third party use appropriate measures to protect the confidentiality and security of your personal data.

6. Retaining and Deleting Your Personal Data

Global Affairs will only retain your personal data for the duration necessary for the data collection purposes identified above, unless there is a legal requirement to maintain it for a longer period. 

According to the Global Affairs data retention policy, we will retain your Personal Data for an indefinite period as a historical record for the purposes described above.

Global Affairs and all of its units will keep your Personal Data for an indefinite period so that we can continue to provide trends and statistics for campus, as well as create participant reports and verification papers. For trends, graphs, and statistics, your data will be anonymized for any statistics and graphs provided, and any Personal Data will be kept confidential. We will only process your data on an as-needed basis, as determined by data requests. For participant reports and verification papers, we will need to access your record to provide this information to our program partners and affiliates, and also to other units on campus such as program or major advisors.

SISS will hold Personal Data for an indefinite period so that we can continue to provide immigration benefits and comply with federal and state laws.

7.  International Transfer of Your Personal Data

In order to fulfill the intended processing purposes described above, your Personal Data will be transferred outside of the European Economic Area (EEA), specifically to the United States, which does not protect personal data in the same way that it is protected in the EEA. Your Personal Data will also be transferred to Canada, Australia and the UK. UC will undertake appropriate measures to ensure adequate protection of Personal Data, including utilizing appropriate physical, administrative, and technical safeguards to protect Personal Data , as well as executing standard contractual clauses approved by the European Commission or a supervisory authority under GDPR, or obtaining your consent, where appropriate.

Global Affairs utilizes QS Unisolution’s cloud-based services, which may reside in the EU, the UK, US and Canada and maintains a data-processing center in Canada.

SISS may share your data with embassies and consulates as needed to provide assistance with obtaining a US Visa to enter the United States.  In addition, we will share your information with other countries to assist with any immigration benefit including changing immigration status by consular processing.

8. Automated Decisions, Profiling and Behavioral Advertising

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved or that have similarly significant impact.

In certain instances, UC may be required to obtain your consent to make automated decisions. In these instances, UC will inform you of the automated decision-making, and will request that you affirmatively indicate that you consent to the intended use of your Personal Data for that purpose, prior to the automated decision-making. Where automated decisions are made, affected persons will be given an opportunity to express their views on the automated decision in question and instructions on how such persons can object to, or opt out of such processing.

We allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of UC’s Sites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and how you use and interact with UC’s Sites. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Sites and other websites and better understand your online activity.

9. Your Rights

As required by the General Data Protection Regulation and applicable EU Member State and EEA state law, if you are located in the European Economic Area, you have a right to:

• Access your personal data, as well as information relating to the recipients of your personal data, the purposes of processing your personal data, the duration for which the personal data will be stored, and the source of personal data that has not been provided by you; 
• Rectify or correct inaccurate or incomplete personal data concerning you, taking into account the purposes of the processing, and the right to have incomplete Personal Data completed;
• Move your personal data to another controller or processor. UC will facilitate the lawful transfer of your data to the extent possible;
• Have your personal data erased in certain circumstances;
• Restrict the processing of your personal data in certain circumstances;
• Object to the processing of Personal Data in certain circumstances;
• Withdraw your consent to the processing of your personal data, should UC ask for your consent for the processing of your personal data. The withdrawal does not affect the lawfulness of processing based on your consent, if required, before its withdrawal. 
• Know whether your personal data is being used for automated decision-making, including profiling. In those cases, UC will give you meaningful information about the logic involved, the significance and the envisaged consequences of such processing for your data, and the right to request human intervention;
• Lodge a complaint with a supervisory authority;

UC may be obligated to retain your personal data as required by U.S. federal or state law.

If you wish to exercise your rights, you can contact the UC Privacy Official identified below.

 You may choose not to visit or use UC Sites or participate in Global Affairs Services.  If you choose not to share your Personal Data with UC or UC-approved third parties for Global Affairs Services you will not receive event updates, nor will you be discoverable by potential research collaborators and prospective students looking at Global Affairs for this type of information.  You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent.  If you choose to reject cookies, some parts of the Sites may not function properly. 

10. Questions and Complaints; UC Privacy Official

If you have questions or complaints about our treatment of your Personal Data, or about our privacy practices more generally, please feel free to contact the UC Davis Privacy Official: privacy@ucdavis.edu.

Effective Date: This statement is effective as of June 3, 2019.