IIE Program Privacy Statement
Audience: applicants, participants and alumni of programs managed by the Institute of International Education (IIE)
Last Updated: March 10, 2020
Our commitment to your privacy
The Institute of International Education (“IIE”) is committed to protecting and respecting your privacy, which includes stewarding your personal information in a secure and transparent manner.
Please read the following statement carefully as it details the ways in which we may process your personal data. Please note that the types of data that we process and how they are handled, as outlined below, may vary both from program to program and by your role as an applicant, participant or alumnus of a particular program.
Our Program Privacy Statement is also available in Spanish, Arabic, French, Mandarin Chinese and Portuguese for your convenience.
IIE’s mission is to help people and organizations leverage the power of international education to thrive in today’s interconnected world. One of the means by which we do this is through the management of international educational programs that promote global understanding through shared knowledge.
In most cases, IIE is contracted by a sponsoring organization to carry out the management of a program. In these cases, the sponsoring organization usually funds and sets the high-level directive, goals and purpose of the program. IIE usually manages some or all daily operations of the program under the general direction of the sponsoring organization. The sponsoring organization may also carry out its own data processing. It is in this context that IIE usually processes personal data. Notable examples of programs include the Fulbright program, the Gilman program and the Boren program.
In some cases, IIE creates, designs and/or funds its own programs. In these cases, IIE may fund and/or set the high-level directive for how the programs are executed. The most notable examples of these are the Scholar Rescue Fund, the Artist Protection Fund and the Student Emergency Initiatives.
Throughout the lifecycle of a particular program, and depending on your status as an applicant, participant or alumnus, we may process the following types of information:
- Identifying and contact information such as your contact details, age, gender, citizenship information, marital status, username, government-issued identification (passport/ID) and picture;
- Academic and professional information such as your academic history, job titles, salary, work history, school attended, employee files, employment history, evaluations, professional references, interviews and certifications;
- Family information such as your family structure, siblings, details of dependents, marriages and relationships;
- Financial information about your bank account, and personal income;
- Photographs of you during your participation in a program;
- Information about your personal history such as your travel history and other events in your life; and
- Information about your preferences such as your opinions, intentions and interests.
- Additionally, we may process data that is generally considered to be sensitive in nature. Please see the section below for more details.
In addition to the types of data listed above, we may also collect, hold and use the following categories of personal data about you that are of a sensitive nature (“Sensitive Personal Data”):
Sensitive Personal Data may include:
- Information concerning your health;
- Information relating to criminal convictions and offences or related security measures;
- Information related to dependents accompanying you on your program, including minors
- Information about your political views
- Information about your sexual orientation
- Data revealing racial or ethnic origin
- Political, religious or philosophical beliefs
- Trade union membership
We will only collect this information when it is necessary and required for the purposes listed in the “What are the purposes of processing your data?” section below or if you choose to provide it to us voluntarily.
Please note that the most common scenarios of processing sensitive data are when we collect medical information in order to review your medical history to determine eligibility to participate in a program; your criminal history when we are required to run a background check; and information concerning minors, if you are bringing dependents with you and we are required to process their information for visa sponsorship or other purposes. In most cases we only process other types of sensitive information if you voluntarily provide it to us, such as referring to religious or political views in an application essay.
IIE may carry out the following processes as part of the management of a program:
- Application/Selection (Collecting and reviewing applications for the purpose of selecting potential program participants and/or notifying them of their selection for a program)
- Academic Review and Placement (Reading, reviewing, submitting and/or analysing applications for the purpose of matching a participant with a host institution, employer or any other entity)
- Record Creation/Management (Creating and maintaining a record in IIE’s systems, electronic or otherwise, in order to carry out the management of the program.)
- Background Check (Automated screening of government watch lists and background information for regulatory compliance purposes.)
- Financial Verification (Verifying availability of funds or income to cover program-related costs/expenses, financial need, or other financial requirements of a program.)
- Medical Review (Reviewing medical information for the purpose of determining visa eligibility, identifying any issues that would prohibit an individual from participating in a program or activity, or would require additional accommodations to be arranged.)
- Participant Agreements (Drafting, sending, or receiving an agreement document such as Terms of Agreement, Terms of Appointment, Program Contracts, or any other type of agreement document with program participants.)
- Insurance/Health Benefit Enrolment and/or Management (Enrolling a participant in a health benefit plan to ensure coverage in the case of medical issues or emergencies.)
- Visa Sponsorship (Creating, monitoring and/or maintaining a SEVIS/Visa Sponsorship record.)
- Travel Management (Planning or booking of domestic or international travel by IIE or vendors on behalf of IIE.)
- Event Management (Planning and/or executing events including registration, scheduling of participants, or any other event-related activities for purposes including program enrichment or external engagements by IIE.)
- Program Reporting (Producing and sharing reports, usually with the sponsors or donors, about progress, activities and other program related information.)
- Program Promotion and Outreach (Promoting IIE and/or IIE programs, including soliciting applications to programs or email marketing.)
- Participant Progress Management (Collecting and analysing any academic, employment or other information to ensure a participant is meeting the requirements of a program or on track for successful completion of an award.)
- Financial Management (Processing payment transactions to or from participants, vendors, or other payees using a bank transfer such as ACH, wire payments, checks or other methods.)
- Emergency Management (Assisting, corresponding and handling emergencies during a program participation.)
- Tax Assistance (Preparation or filing of tax returns on behalf of IIE participants.)
- Program Evaluation (Reporting, exporting, or compiling of data for the purposes of understanding and/or evaluating the state of the program/participants, impacts, or any other legitimate interest.)
- Alumni Management: (Managing data of participants whose programs have ended, including the production of statistical reports, alumni correspondence and organizing alumni events.)
We may send your data to or receive it from third parties to carry out the processes listed above. These third parties may include:
- Academic credential evaluation companies
- Educational testing services
- Academic and research institutions
- Insurance and health providers
- Program and award sponsors
- Commissions and posts
- External interview panellists and award selection committees
- Travel management companies
- Background check and watchlist providers
- Translation services
- Governmental agencies
- Additional third parties which may include legal counsel representing IIE, courts, tribunals, regulators, government authorities and law enforcement officials if required by law or for IIE’s legitimate interest in compliance with applicable laws/regulations.
These third parties will process your personal data pursuant to applicable local data processing regulations.
- In order to potentially enter or carry out a contract with you and/or the program sponsor to administer the program.
- As required by us to pursue our legitimate interests or the legitimate interests of others, in particular, provided that the legitimate interests below are not overridden by the interests or fundamental rights or freedoms of the individuals whose personal data we are processing:
- when carrying out the processes listed above;
- when investigating any complaints received from you or from others, about us, or our service providers; or
- in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
IIE will retain your personal data for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal data. We may also retain personal data for the period during which a claim may be made in relation to our professional relationship with you.
IIE may also retain a permanent record of participation for its own internal record keeping. This may include basic information such as your name, citizenship and the program you participated in.
As required by data protection legislation, we have strict security procedures regarding the storage and disclosure of personal data.
The personal data that we collect about you may be transferred to, stored at or processed in one or more countries, including those outside the European Economic Area (“EEA”), which have not yet been deemed by regulators to offer adequate data protection. These include but are not limited to, the United States of America, which is where IIE and other third parties identified in the “With Whom Do We Share Your Data?” section above may be located.
It is often necessary for us to transfer the personal data that we collect about you to these countries so that IIE can take steps that will enable it to enter into a contract with you so that you can become a participant of the program and then to perform the contract.
We do not envisage that any decisions will be taken about you using automated means.
You have the right to submit inquiries to IIE regarding the handling of your personal data. IIE will review your request in a timely manner and will carry out the request if it meets the proper legal requirements.
You may have the right to:
- access your personal data;
- have your personal data rectified if it is inaccurate or incomplete;
- have your personal data deleted or removed if there is no reason for its continued storage and processing;
- object to your personal data being processed and to restrict the processing of your personal data in certain circumstances;
- request the transfer of your personal data to another party; and
- where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent. Please note that the withdrawal of your consent will not affect the lawfulness of any processing of personal data based on your consent before its withdrawal.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
You may submit your requests using IIE’s Data Subject Request Portal. You can, in principle, exercise your rights free of charge, subject to statutory exceptions.
If you are dissatisfied with any aspect of IIE’s handling of your personal data, you have a right to lodge a complaint with the appropriate authority in your home country or relevant jurisdiction.
If you have any questions concerning this Statement or the policies or procedures referred to above, please visit IIE’s Data Subject Request Portal and select “General Inquiry”.
We reserve the right to change this Statement and any other relevant policies or procedures at any time without notice to you. We will always keep this statement up to date on IIE’s website, where it is available to the public and accessible at any time. We recommend revisiting and reviewing this statement regularly to ensure that you understand how we may be processing your personal data.