Privacy of Personal Information
The College Futures Foundation (the “Foundation”) is committed to the responsible use of personal information collected from and about grantees, students, staff, business partners and others who provide such information to us and to compliance with both state and federal regulations concerning the use of personal information. Such personal information includes any number that may be used, alone or in conjunction with any other information, to identify a specific individual; or other personal information that could be used to cause financial or reputational harm to an individual. This policy applies to information that is collected by any means whether electronically, by telephone, or on paper.
Limits on Use and Access
The responsible use of personal information requires that the Foundation respect individual privacy, protect against identity theft and other unauthorized uses, and comply fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of personal information within the Foundation are limited to those which a) are necessary to meet legal and regulatory requirements; b) facilitate access to services, transactions, facilities and information; or c) support efficient philanthropic and administrative processes.
Access to personal information is limited to:
- The individual whose information is produced or displayed,
- A Foundation employee or agent of the Foundation with authorized access based upon a legitimate mission or business interest and a need to know,
- An organization or person authorized by the individual to receive the information,
- A legally authorized government entity or representative, or other circumstances in which the Foundation is legally compelled to provide access to personal information, or
- Other individuals or entities, as allowed by law, for purposes judged to be appropriate or necessary for the reasonable conduct of Foundation business.
Social Security Numbers
State law protects the use of Social Security numbers. The Foundation will continue to collect and maintain Social Security numbers in all instances in which that number is required by law for reporting or other uses. This includes, but is not limited to, all borrowers of student loans the Foundation holds, and all individuals receiving payment from the Foundation. In addition, the Foundation will continue to use Social Security numbers, as allowed by law, for operational purposes for which there is no reasonable substitute. Social Security numbers are always considered confidential, and therefore subject to the access restrictions described above.
It is against the state law and Foundation policy to:
- Publicly post or display the Social Security number in any manner;
- Print the Social Security number on any card required to access service;
- Require an individual to transmit his or her Social Security number over the Internet unless the connection is secure or the number is encrypted;
- Require an individual to use his or her Social Security number to access an Internet site unless a unique password or PIN is also required; or
- Print a Social Security number on any materials that are mailed unless required by a state or federal agency, unless state or federal law requires the Social Security number to be on the document to be mailed. Also, Social Security numbers may be included in forms sent by mail, including documents sent to establish, amend or terminate an account, contract or policy, or to confirm the accuracy of the Social Security number.
Department and Personal Responsibility
Each Foundation department is responsible for reviewing and monitoring internal procedures, reports and other documents to assure compliance with this policy. This responsibility includes providing training and control systems for the responsible use of personal information that is accessible to employees for doing the work of the department. The Foundation expects that all members of the community also will exercise caution in making available their own personal information to others. In particular, individuals should not give others access to their building pass, passwords or personal identification numbers.
Online Collection of Personal Information