Internet Privacy Policy

PURPOSE:

The New York State Internet Security and Privacy Act requires all state agencies which provide a public website to have an Internet Privacy Policy.

STATEMENT OF POLICY:

All members of the College community have a responsibility to respect the privacy and rights of others.
Jefferson Community College does not collect any personal information about users unless the user provides the information voluntarily by sending email, completing an online information request form, completing the online application or completing online registration.
Information collected automatically when you visit sunyjefferson.edu
1. While visiting sunyjefferson.edu, JCC automatically collects and anonymously stores the following information about the visit:
  1. The Internet protocol address of the computer that accessed the JCC website
  2. The type of Internet browser, its version and the operating system on which that browser is running.
  3. The webpage from which the user accessed the current web page
  4. The date and time of the user’s request
  5. The pages that were visited and the amount of time spent on those pages
  6. The size of the content, in bytes, of any file or document sent to the user’s computer
  7. The country where the computer resides
  8. Search engines that brought users to the official JCC website and the text search strings that allowed users to find a page on the official JCC website
  9. Downloads the user requested (PDF, DOC, MOV, etc) from the official JCC website
2. None of the above-mentioned information is deemed to constitute personal information by the Internet Privacy and Security Act. The information that is collected automatically is used to improve Jefferson’s web content and to help understand how users are interacting with the website. This information is collected for statistical analysis and to determine what information is of most and least interest to our users.
Cookies
1. A cookie is a unique text file stored on a user’s computer by an Internet browser. These text files are used as a means of distinguishing among users of a website. A cookie will not include personal information, unless the user has volunteered that information
2. Cookies are not currently stored from sunyjefferson.edu web pages
3. Cookies are stored from certain areas of other JCC web applications, such as Blackboard and Banner (SOAR) as well as linked third party applications such as the application for requesting transcripts.
4. Cookies stored from JCC web applications are not used by the College to gather personal information but to assist with the appropriate functioning of the application.
Information collected when you email sunyjefferson.edu or complete a transaction
1. During a visit to sunyjefferson.edu, a user may send an email to a JCC office through an email link or an information request form. The user’s email address and the contents of the message will be collected. The information collected is not limited to text characters and may include audio, video and graphic information formats included in the message. The user’s email address and the information included in the message will be used to:
  1. Respond to the user
  2. Address issues identified by the user
  3. Improve the website
  4. Notify the user about updates, services, special events or activities offered by JCC
  5. Ask the user to participate in surveys
  6. Forward to appropriate JCC offices for action
2. If a user chooses not to receive email or other means of communication from JCC, and would prefer not to in the future, the user may request to not receive communications by contacting the JCC webmaster, webmaster@sunyjefferson.edu.
3. During a visit to sunyjefferson.edu, a user may also complete a transaction such as an online application, online registration from other JCC web applications. The information collected by JCC, including personal information volunteered by the user in completing the transaction, is used by JCC and may be disclosed by JCC for those purposes that may be reasonable ascertained from the nature and terms of the transaction in which the information was submitted.
4. JCC does not knowingly collect personal information from children under the age of 13 or create profiles of children under the age of 13. Users are cautioned, however, that the collection of personal information submitted in an email 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.
Retention of information collected through sunyjefferson.edu
1. In general, the Internet services logs of JCC, comprising electronic files or automated logs created to monitor access and use of College services provided through sunyjefferson.edu are archived kept indefinitely. 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 sunyjefferson.edu
1. Any user may submit a request to JCC’s webmaster to determine whether personal information pertaining to that user has been collected through sunyjefferson.edu. 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 address of the webmaster is:
  
  Webmaster
  Jefferson Community College
  1220 Coffeen Street
  Watertown, New York 13601
2. The webmaster 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 therefore; 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 acknowledgement.
3. In the event that JCC has collected personal information pertaining to a user through sunyjefferson.edu and that information is to be provided to the user pursuant to the user’s request, the webmaster 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 sunyjefferson.edu
1. Jefferson Community College is committed to protecting personal information collected through College web applications against unauthorized access, use or disclosure.
2. The College limits employee access to personal information collected through the College web applications to only those employees who need access to the information in the performance of their official duties.
3. Employees who have access to personal information follow appropriate procedures in connection with any disclosures of personal information.
4. Visitors can travel through most of the College’s official website without offering any information about themselves.
5. The College has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, authorization, and monitoring. These security procedures have been integrated into the design, implementation and day-to-day operations of Jefferson’s web applications as part of the continuing commitment to the security of electronic content as well as the electronic transmission of information
6. For web site security purposes and to maintain the availability of sunyjefferson.edu for all users, Jefferson employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage the website.
Disclosure of information collected through sunyjefferson.edu
1. The collection of information through sunyjefferson.edu and the disclosure of that information are subject to the provisions of the Internet Security and Privacy Act. JCC will only collect personal information through sunyjefferson.edu or disclose personal information collected through sunyjefferson.edu if the user has consented to the collection or disclosure of that personal information.
2. JCC may collect or disclose personal information without consent if the collection or disclosure is
  1. Necessary to perform the statutory duties of JCC or necessary for JCC to operate a program authorized by law, or authorized by state or federal statutes or regulation
  2. Made pursuant to a court order or by law
  3. For the purpose of validating the identity of the user
  4. Of information to be used solely for statistical purposes that is in a form that cannot be used to identify a particular person
3. The disclosure of information, including personal information, collected through sunyjefferson.edu is subject to the provision of the Freedom of Information Law and the Personal Privacy Protection Law
4. JCC may disclose personal information to federal or state law enforcement authorities to enforce its rights against unauthorized access or attempted unauthorized access to JCC’s information technology assets.
External websites
1. Users should be aware that links to web sites not controlled by Jefferson are not subject to this notice. Users should check the privacy policy of these individual sites to see what data is collected and how these sites will be used
2. If the URL does not contain sunyjefferson.edu, then you are visiting a site that is not subject to this policy. One exception is Microsoft Live which is used for student and retiree email.
Links within sunyjefferson.edu
1. JCC provides links to third parties as a convenience in locating relative information and services for our users. JCC does not take any responsibility for the content, the accuracy of the information and/or quality of products or services provided by or advertised on these third-party web sites.
Disclaimer

The information provided in this policy should not be construed as giving business, legal or other advice or warranting as fail proof, the security of information provided through sunyjefferson.edu.
The Board of Trustees hereby authorizes the President, or his/her designee, to develop and establish appropriate standards and procedures to implement and enforce this policy.
Contact information
1. For questions regarding this policy, please contact the webmaster (webmaster@sunyjefferson.edu) or by regular mail:
  
  Webmaster
  Jefferson Community College
  1220 Coffeen Street
  Watertown, New York 13601
Definitions:
1. Personal information: for purposes of this policy, “personal information” means any information concerning a natural person which, because of name, number, symbol, mark or other identifier, can be used to identify that natural person
2. User: shall have the meaning set forth in subdivision 8 of section 202 of the state technology law.

Adopted:
June 2012, Res. 128-12