J2: Internet Privacy

Responsibility for Maintenance: Information Technology Services; Marketing & New Media

Date of most recent changes:  July 10, 2018

I. Policy Statement 

The Onondaga Community College websites are designed to make it easier and more efficient for individuals and businesses to interact with Onondaga Community College. The College recognizes that it is critical for individuals and businesses to be confident that their privacy is protected when they visit Onondaga Community College websites. Consistent with the provisions of the Internet Security and Privacy Act, the Freedom of Information Law, and the Personal Privacy Protection Law, this policy describes Onondaga Community College's privacy practices regarding information collected from users of the websites. This policy describes what information is collected and how that information is used. Because this privacy policy only applies to the College websites, you should examine the privacy policy of any website, including other state agency websites, that you access using our websites. Onondaga Community College does not collect any personal information about you, unless you provide that information voluntarily by sending an e-mail, responding to a survey, or completing an on-line transaction.

II. Reason for Policy 

Onondaga Community College is required to disclose its privacy practices regarding information collected from users of its website.

III. Applicability of the Policy 

This policy applies to Onondaga Community College and individuals and businesses that interact with Onondaga Community College via its website.

IV. Contacts 

V. Definitions 

VI. Procedures 

Information Collected Automatically When You Visit a Website
When visiting websites, Onondaga Community College automatically collects and stores information about your visit such as the website request, the host name or Internet Protocol address of the user requesting access, the operating system and web browser used by the requester and the date and time of the request. None of the information collected is deemed to constitute personal information.

The information that is collected automatically is aggregated and used for statistical analysis, to determine what information is of most and least interest to our users, and to improve the utility of the material available on the website. 

Cookies
Cookies are simple text files stored on your computer to provide a means of distinguishing among users of the websites. The use of cookies is a standard practice among Internet websites. To better serve you, we may use "session cookies" to enhance or customize your visit to the websites. Session cookies, which can be created automatically on the device you use to access this state agency website, do not contain personal information and do not compromise your privacy or security. We may use the cookie feature to store a randomly generated identifying tag on the device you use to access the website. A session cookie is erased during operation of your browser or when your browser is closed. The web browser software you use to access the website allows you to refuse new cookies or delete existing cookies. Refusing or deleting these cookies may limit your ability to take advantage of some features of the website.  

Onondaga Community College also uses 3rd party vendor re-marketing tracking cookies, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN). As always, we respect your privacy and are not collecting any identifiable information through the use of Google's or any other 3rd party re-marketing system.

The third party vendors, including Google whose services we use, will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to continue to make prospective students aware of their education options at Onondaga Community College. If you would like to opt out of the third party vendor's use of cookies, you can use the Network Advertising Initiative opt-out page available at http://optout.networkadvertising.org. 

Information Collected When You E-mail via a Website or Complete a Transaction
During your visit to one of the College websites you may send an e-mail to Onondaga Community College. Your e-mail address and the contents of your message will be collected and used to respond to you, to address issues you identify, to improve the websites, or to forward your message to another State agency for appropriate action. Your e-mail address is not collected for commercial purposes and Onondaga Community College is not authorized to sell or otherwise disclose your e-mail address for commercial purposes.

During your visit to a College website you may complete a transaction such as a survey, registration, or order form. The information, including personal information, volunteered by you in completing the transaction is used by Onondaga Community College to operate Onondaga Community College programs, which include the provision of goods, services, and information. The information collected by Onondaga Community College may be disclosed by Onondaga Community College for those purposes that may be ascertained reasonably from the nature and terms of the transaction in which the information was submitted. The College uses a secure protocol to protect the transmission of highly sensitive personal information, such as social security number, when requested on a form or registration.

Onondaga Community College does not knowingly collect personal information from children or create profiles of children through the websites. Users are cautioned, however, that the collection of personal information submitted in an e-mail will be treated as though it was submitted by an adult, and may, unless exempted from access by federal or State law, be subject to public access. Parents and teachers are strongly encouraged to be involved in children's Internet activities and to provide guidance whenever children are asked to provide personal information on-line.

Information and Choice
As noted above, Onondaga Community College does not collect any personal information about you unless you provide that information voluntarily by sending an e-mail, responding to a survey, or completing an on-line form. You may choose not to send us an e-mail, respond to a survey, or complete an on-line form. While your choice not to participate in these activities may limit your ability to receive specific services or products through the website, it will not normally have an impact on your ability to take advantage of other features of the website, including browsing or downloading information.  

Disclosure of Information Collected through the Websites
The collection of information through the websites and the disclosure of that information are subject to the provisions of the Internet Security and Privacy Act, New York State Technology Law, Article 2. Onondaga Community College will only collect personal information through the website or disclose personal information collected through the website if the user has consented to the collection or disclosure of such personal information. The voluntary disclosure of personal information to Onondaga Community College by the user, whether solicited or unsolicited, constitutes consent to the collection and disclosure of the information by Onondaga Community College for the purposes for which the user disclosed the information to Onondaga Community College, as was reasonably ascertainable from the nature and terms of the disclosure.   

However, Onondaga Community College may collect or disclose personal information without consent if the collection or disclosure is: (1) necessary to perform the statutory duties of Onondaga Community College, or necessary for Onondaga Community College to operate a program authorized by law, or authorized by state or federal statute or regulation; (2) made pursuant to a court order or by law; (3) for the purpose of validating the identity of the user; or (4) of information to be used solely for statistical purposes that is in a form that cannot be used to identify any particular person.  

Further, the disclosure of information, including personal information, collected through the website is subject to the provisions of the Freedom of Information Law (New York Public Officers Law, Article 6) and the Personal Privacy Protection Law (New York Public Officers Law, Article 6A). Onondaga Community College may disclose personal information to federal or state law enforcement authorities to enforce its rights against unauthorized access or attempted unauthorized access to Onondaga Community College's information technology assets.  

Retention of Information Collected through the Websites
Information collected through a website is retained by Onondaga Community College in accordance with the records retention and disposition requirements of the New York State Arts & Cultural Affairs Law. Information on the requirements of this law may be found at https://www.nysenate.gov/legislation/laws/ACA/57.25. In general, the Internet services logs of Onondaga Community College, comprising electronic files or automated logs created to monitor access and use of Agency services provided through the websites, are retained for 60 days and then destroyed. Information, including personal information, that you submit in an e-mail or when you complete a survey, registration form, or order form is retained in accordance with the records retention and disposition schedule established for the records of the program unit to which you submitted the information. Information concerning these records retention and disposition schedules may be obtained through the Internet privacy policy contact listed in this policy.  

Access to and Correction of Personal Information Collected Through a Website
Any user may submit a request to the appropriate Onondaga Community College privacy compliance contact to determine whether personal information pertaining to that user has been collected through a website. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier generally known only to the user, or similar appropriate identification.  

The addresses of the privacy compliance contacts are as follows: 

• For student related requests: Brian Wetherby, Director, Marketing & New Media, Onondaga Community College, 4585 West Seneca Turnpike, Syracuse, NY 13215-4585.
• For all other requests: Steve Wiley, Assistant Vice President, Information Technology Services, Onondaga Community College, 4585 West Seneca Turnpike, Syracuse, NY 13215-4585.

The appropriate privacy compliance officer shall, within five (5) business days of the receipt of a proper request, provide access to the personal information; deny access in writing, explaining the reasons; or acknowledge the receipt of the request in writing, stating the approximate date when the request will be granted or denied, which date shall not be more than thirty (30) days from the date of the acknowledgment. In the event that Onondaga Community College has collected personal information pertaining to a user through the state agency website and that information is to be provided to the user pursuant to the user's request, the privacy compliance officer shall inform the user of his or her right to request that the personal information be amended or corrected under the procedures set forth in section 95 of the Public Officers Law.

Confidentiality and Integrity of Personal Information Collected Through a Website
Onondaga Community College is strongly committed to protecting personal information collected through the websites against unauthorized access, use or disclosure. Consequently, Onondaga Community College limits employee access to personal information collected through a website to only those employees who need access to the information in the performance of their official duties. Employees who have access to this information follow appropriate procedures in connection with any disclosures of personal information. In addition, Onondaga Community College has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, monitoring, auditing, and encryption. These security procedures have been integrated into the design, implementation, and day-to-day operations of the websites as part of our continuing commitment to the security of electronic content as well as the electronic transmission of information. For website security purposes and to maintain the availability of the website for all users, OCC employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage the websites.  

Disclaimer
Information provided in this privacy policy should not be construed as giving business, legal, or other advice, or warranting as fail proof, the security of information provided through the websites.

Approved by OCC Board of Trustees April 3, 2006

Updated and approved by the President January 6, 2010

Updated and approved by the President July 10, 2018

Updated and approved by the President June 21, 2021