Scope of Policy

This policy outlines how the American University of Sharjah obtains personal information, how we use and disclose that information and how we manage requests to access and/or change that information.

 

What is personal information and how do we collect it?

Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from an individual in their capacity as a student, contractor, volunteer, stakeholder, job applicant, alumni, visitors or anyone else that comes into contact with the University.

In the course of American University of Sharjah activities, we may collect and hold:

• Personal information that includes, amongst other things, the name, address and other contact details, date of birth, next of kin details, attendance records, financial information and professional memberships.

• Sensitive personal information that includes, amongst other things, government identifiers (such as Emirates ID), religious beliefs, nationality, country of birth, photographic images, professional memberships, court orders and criminal records, and health information such as medical records, allergies, disabilities, immunization details and psychological reports.

As part of our recruitment processes for employees, contractors and volunteers, we may collect and hold:

• Personal information that includes, amongst other things, the name, address and other contact details, date of birth, next of kin details, attendance records, financial information, professional memberships, employment references, regulatory accreditation, media, directorships, property ownership, and driver's license information.

• Sensitive personal information that includes, amongst other things, government identifiers (such as Emirates ID), nationality, country of birth, court orders and criminal records, and health information such as medical records, allergies, disabilities, immunization details and psychological reports.

Generally, we will seek consent from a person in writing before we collect their sensitive personal information.

 

Collection of personal information

The collection of personal information depends on the circumstances in which American University of Sharjah is collecting this information. If it is reasonable and practical to do so, we will aim to collect this personal information directly from the individual.

 

Solicited information

American University of Sharjah, where possible, standardizes the collection of personal information by using specifically designed forms (e.g. an Enrolment Form or Health Information Disclosure Form). However, we also receive personal information by other methods such as email, letters, notes, via our website, over the telephone, in face-to-face meetings, through financial transactions and through surveillance activities such as the use of CCTV security cameras or email monitoring.

We may also collect personal information from other people such as a third-party administrator, referees for prospective employees or from any other sources. However, we will only do so where it is not reasonable and practical to collect the personal information from an individual directly.

We may collect information based on how people use our website. We use ‘cookies’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyze and improve our website, marketing campaigns and to record statistics on web traffic. We do not use this information to personally identify individuals.

 

Unsolicited information

American University of Sharjah may be provided with personal information without having sought it. This is known as ‘unsolicited information’ and is often collected by:

• misdirected postal mail – such as letters, notes and documents;

• misdirected electronic mail – such as emails and electronic messages;

• employment applications sent to us that are not in response to an advertised vacancy; and

• additional information provided to us which was not requested.

Unsolicited information obtained by American University of Sharjah will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the personal information as appropriate.

 

Collection and use of sensitive personal information

We only collect sensitive personal information if it is:

• reasonably necessary in the course of conducting American University of Sharjah activities, and we have the individual's consent;

• necessary to lessen or prevent a serious threat to life, health or safety;

• another permitted general situation;

• another permitted health situation; or

• required by law or a competent court.

We may share sensitive personal information to other entities in our organization structure, but only if necessary in the course of conducting American University of Sharjah activities.

 

How we use personal information

American University of Sharjah only uses personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented.

Our primary uses of personal information include, but are not limited to:

• providing education, pastoral care, co-curricular and health services;

• satisfying our legal obligations;

• keeping parents informed as to University community matters through correspondence, newsletters and magazine;

• marketing, promotional and fundraising activities;

• supporting the activities of University associations such as American University of Sharjah Enterprises;

• supporting fundraising and development activities of the University;

• supporting community-based causes and activities, charities and other causes in connection with the University’s functions or activities;

• helping us to improve our day-to-day operations including training our staff;

• systems development; developing new programs and services; undertaking planning, research and statistical analysis;

• University administration including for insurance purposes;

• the employment of staff; and

• the engagement of volunteers.

We will only use or disclose sensitive personal information for a secondary purpose if you would reasonably expect us to use or disclose the information and the secondary purpose is directly related to the primary purpose, e.g. in case of a medical emergency.

We may share personal information to related legal entities in the course of conducting American University of Sharjah activities.

American University of Sharjah may disclose information about an individual to overseas recipients only when it is necessary, for example to facilitate an overseas excursion. The University will not however send information about an individual outside of the United Arab Emirates without their consent.

 

Storage and security of personal information

American University of Sharjah may store personal information in a variety of formats including, but not limited to:

• databases;

• hard copy files;

• personal devices, including laptop computers;

• third party storage providers such as cloud storage facilities; and

• paper based files.

American University of Sharjah takes reasonable steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.

These steps include, but are not limited to:

• restricting access and user privilege of information by staff depending on their role and responsibilities;

• ensuring staff do not share personal passwords;

• ensuring hard copy files are stored in lockable filing cabinets in lockable rooms. Staff access is subject to user privilege;

• ensuring access to American University of Sharjah’s premises are secured at all times;

• implementing physical security measures around the University buildings and grounds to prevent break-ins;

• ensuring our IT and cyber security systems, policies and procedures are implemented and up to date;

• ensuring staff comply with internal policies and procedures when handling the information;

• undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the legal privacy requirements of the United Arab Emirates; and/or

• the destruction, deletion or de-identification of personal information we hold that is no longer needed or required to be retained by the University.

 

How long will personal information be kept?

We will keep personal information for as long as reasonably necessary for any legitimate purpose. We will not retain any personal information for longer than is necessary for the purposes it was obtained. Different retention periods may apply for different types of information.

 

Responding to data breaches

We will take appropriate and prompt action if we have reasonable grounds to believe that a serious harm data breach may have occurred.

This may involve for example the review of our internal security procedures, taking remedial internal action, notifying affected individuals and/or any other steps as may be appropriate.

 

Disclosure of personal information

Personal information may be disclosed to government agencies, other parents, other universities, recipients of University publications, visiting educators, counsellors and coaches, our services providers, agents, contractors, business partners, related entities and other recipients from time to time, if the individual:

• has given consent; or

• would reasonably expect the personal information to be disclosed in that manner.

American University of Sharjah may disclose personal information without consent or in a manner which an individual would reasonably expect if:

• the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;

• another permitted general or health situation applies; or

• it is required by law or a competent court.

 

Disclosure of your personal information to overseas recipients

Personal information about an individual may be disclosed to an overseas organization in the course of conducting American University of Sharjah activities. For example, information might be stored with a ‘cloud service provider’ who may store data outside of the UAE.

We will however take reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

• we have the individual’s consent (which may be implied);

• we have satisfied ourselves that the overseas recipient is compliant with privacy requirements of the United Arab Emirates;

• we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;

• we are taking appropriate action in relation to suspected unlawful activity or serious misconduct; or

• it is required by law or a competent court.

 

Personal information of students

At the American University of Sharjah, we take a common-sense approach to dealing with a student’s personal information and generally would refer any requests for personal information to a student and/or their parents or legal guardians as appropriate.

There may be occasions where parents or legal guardians are denied access to information with respect to their children, because to provide such information would have an unreasonable impact on the privacy of others or result in a breach of the University’s duty of care to the students.

Accuracy of personal information

We take reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.

If the American University of Sharjah becomes aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.

 

General rights to an individual's personal information

An individual has the following general rights with respect to their personal Information:

• to obtain a copy of their information in an easily accessible format;

• request for their information to be corrected or updated;

• to restrict or limit the ways in which their information is used;

• to object to the processing of their information; and/or

• to request the deletion of their information.

A person may submit a request to us to access the personal information we hold, or request that we change the personal information.

Upon receiving such a request, we will take steps to verify the individual’s identity before granting access or correcting the information. We will respond to an individual's request within a reasonable timeframe.

If we reject the request, the individual will be notified accordingly. Where appropriate, we will provide the reason/s for our decision. If the rejection relates to a request to change personal information, an individual may make a statement about the requested change and we will attach this to their record.

If an individual withdraws their consent to our use or sharing of their personal information for the purposes set out in this Privacy Policy, that individual may not have access to all (or any) of the services that we provide, and we might not be able to provide them with all (or any) of the services.

 

Complaints Procedure

An individual can make a complaint about how the American University of Sharjah manages personal information, including a privacy breach, by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response.

American University of Sharjah does not charge a fee for the handling of complaints.

 

How to contact us

American University of Sharjah can be contacted about this Privacy Policy or about personal information generally, by:

• Emailing: PrivacyOfficer@aus.edu

• Writing To:

Privacy Officer American University of Sharjah PO Box 26666 Sharjah United Arab Emirates

An individual can contact us anonymously or by using a pseudonym. However, in such circumstances, without identification, we may not practically be able to provide information or assistance.

 

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time.

Please check our Privacy Policy on our website https://www.aus.edu/privacy regularly for any changes.

Last Updated: February 2019 Date of Next Review: January 2020