Alumni and Friends Data Privacy Policy

Jan. 19, 2010

I. Principles of privacy and respect

1. Mitchell Hamline respects the privacy of its alumni and friends and will honor and respect that privacy to the extent permitted by law.  Mitchell Hamline is committed to protecting from disclosure personal data collected and maintained by the school (including Education Records as defined in the Family Education Rights and Privacy Act) except for the limited, school-related purposes outlined in this policy.
2. Alumni and friends of the school have the right to communicate their preferences about how the personal data retained by the school is used and with whom it is shared, and Mitchell Hamline will strive to honor such preferences whenever possible.

II. Guidelines regarding use and sharing of personal data

1. For the purposes of this policy, “personal data” includes information about alumni and friends such as name, contact information, employment history, participation in school activities or events, and giving history, along with other information related to a person’s relationship with Mitchell Hamline.
2. For the purposes of this policy, “friends” refers broadly to persons who are not alumni and for whom personal data is retained, including students, faculty (full-time and adjunct), and staff, in addition to persons who have registered to attend events or who have made a financial contribution or provided a volunteer service to the school.
3. Mitchell Hamline will use and share personal data only for purposes related to advancing the mission of the school, including communications about events or news of interest to alumni, and other outreach, development, and engagement programs.
4. All staff who have access to personal data are expected to maintain the confidentiality of the data, to take precautions to avoid inadvertent disclosure of the data, and to disclose such data only as provided in this policy.
5. When reasonably convenient, Mitchell Hamline may offer to forward communications to alumni or friends on behalf of someone requesting their contact information if it appears they would appreciate or benefit from receiving the information sought to be conveyed.
6. Alumni who register on alumni.net (Mitchell Hamline’s current online alumni community) are subject to the privacy and disclosure rules set forth in “Questions About Alumni.Net” found online.
7. As a general rule, personal information about alumni and friends will not be disclosed to any outside party (not employed by Mitchell Hamline), including other alumni, the public, or outside vendors, with the following exceptions:
   1. Personal data may be shared with vendors selected by the school to perform services related to advancing the mission of the school (such as mail houses, consultants, and phonathon contractors), but only for the specific purposes for which the vendor is hired.
   2. The school may verify attendance and year of graduation of alumni if requested by a third party with a legitimate reason to know, including for employment purposes.
   3. Alumni who wish to organize reunions or other inclusive school-related gatherings with classmates (such as events for alumni groups outside the Twin Cities) may be provided with contact information for their classmates with the express understanding that the information may not be used for any other purpose.  When time and cost permit, however, it is preferable for the school to handle such communications.
   4. Personal data may be disclosed as required by law in connection with judicial or administrative proceedings or if, in the sole discretion of Mitchell Hamline, disclosure is necessary to protect the school.
8. Requests to share or disclose personal data—whether internally or externally—must be made to the Office of Institutional Advancement and brought to the attention of the Alumni Relations Officer, who will track the requests, consult others where appropriate (e.g., the Director of Development, the Director of Marketing and Alumni Relations, the Vice President of Institutional Advancement, the Registrar, Admissions, and the Office of Career and Professional Development),  and evaluate the requests against the following criteria:
   1. the type of data requested (e.g., addresses, emails, employment information, etc.)
   2. the purpose for which the data is sought
   3. the number of alumni the requester seeks to contact (or for whom other information is requested)
   4. the connection or relationship of the requester with the school (e.g., whether faculty, staff, alumni, relatives of alumni, media, member of general public, etc.)
   5. whether the data requested is publicly available
   6. the ease with which the information might be available elsewhere (both the alumni information sought to be disclosed and the information sought to be communicated to the alumni)
   7. the extent to which any requested  communication with alumni may conflict with other scheduled communications (e.g., email blasts, invitations, or annual fund solicitations) in terms of timing and recipients
   8. the extent to which disclosing the data furthers the mission of the school, including building relationships between alumni and the school and among alumni and enhancing the reputation of the school and its alumni
   9. the resources required to meet the timeframe and scope of the request
   10. the fit between the type and amount of data requested and the purpose for which the data is requested
9. If a disclosure request is granted (whether internally or externally), only the minimum amount of information necessary to meet the reasonable and legitimate needs of the requester will be provided.