This document sets forth the Data Privacy Standards of Wade College and provides information about the collection, maintenance, and use of personal information or data provided to or otherwise collected or processed by Wade College.

The purpose of this policy is to establish a generally applicable college-wide data privacy standard and to provide interested persons with information about Wade College’s collection, maintenance, and use of personal information or data regardless of the lawful bases under or legitimate purpose for which the information was obtained.

The Data Privacy Standard applies to all domains within Wade College Web and to any other Wade College action or process concerning the collection, processing, analysis, and other data processing of personal information regardless of the method by which such information came to be owned and/or controlled by Wade College.

Wade College, by and through its academic and administrative units and programs, owns, controls, operates, and/or maintains websites under a number of domains (collectively, “College Web”). While this policy applies across campus, some Wade College websites may have additional policies and practices regarding privacy that also must be observed. Wade College’s President must approve any such “local” policies prior to the policy’s implementation.

Wade College’s Web may contain links to third party external websites over which Wade College has no control. Wade College disclaims any responsibility for the privacy practices or the content of external websites regardless of a link to such websites being displayed on Wade College Web.

For the purposes of the policy, “processing” means obtaining, recording, or holding the information or data or carrying out any operation or set of operations on the information or data, including – organization, adaptation, or alteration of the information or data, retrieval, consultation or use of the information or data, disclosure of the information or data by transmission, dissemination or otherwise making available, or alignment, combination, blocking, erasure, or destruction of the information or data. A “data subject” is a phrase that refers to the person to whom the personal data relates.

Each Wade College Web application or site shall contain a link to this Wade College Web Privacy Policy

What is ‘personal information’ or ‘personal data’?

‘Personal information’ or ‘personal data’ means any information that relates to or identifies a person as an individual.

How Is Personal Information Collected and Processed by Wade College?

Wade College obtains personal information when a person fills out and submits an application to attend Wade College along with any additional information the person submits to Wade College before or after they submit an application. People may also provide Wade College personal information when they seek financial aid or visit certain parts of Wade College Web or make use of student services.

In addition to the application process or an individual requesting college services, Wade College may also acquire personal information when a person seeks to interact or do business with Wade College or to participate in other activities offered by Wade College. As discussed elsewhere in this policy, some College Web (as well as third party’s) webpages use “cookies” to collect information about the web user. Wade College Web servers (“Web Server”) may also “collect” information about people by generating temporary logs that may contain the following information:

• Internet address (IP address) of computer being used
• Web pages requested
• Referring Web page
• Browser used
• Date and time

The data collected on Wade College Web are used in aggregate to tune the Wade College Web site for its efficiency and are not ordinarily associated with specific individuals. Raw data from the Web Server logs may only be shared with the custodian of each Wade College Web site. Summary reports produced from the logs help College Web publishers determine what College Web browsers and pages are most popular. For example, if the aggregate reports show that a particular College Web page is very popular or is used more by freshmen than by seniors, publishers might use this information to customize the content of that page and make it easier to find.

Individual data gathered through a specific process, such as the submission of an application to attend Wade College, related submissions, and subsequent interaction with admissions staff, will only be used for its intended purpose, such as the consideration of an applicant for admission or an employment decision, or for certain archiving, research, or statistical purposes described below. Personal information may also come from third parties that are authorized to provide personal information to Wade College.

Wade College may use personal data it collects for a specific purpose and further process that personal data for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes (“research purposes”). Processing for research purposes will be subject to appropriate safeguards, including the use of data minimization and pseudonyms when possible. Wade College will anonymize the personal data it uses for research purposes whenever Wade College can fulfill the purpose without the need of identification of the personal data subject. Wade College is not required to provide notice to data subjects when it further processes personal data for research purposes.

Further processing of personal data for research purposes is only permitted when the purpose of the processing is to support Wade College. Further processing of personal data by researchers for their own research purposes is not permitted unless the researcher follows Wade College’s processes for human subject research, if applicable, and the researcher provides any required notice to the data subjects.

Cookies are small pieces of data stored by Wade College Web browser. Cookies are often used to remember information about preferences and pages a person has visited. For example, when a person visits some sites on College Web, they might see a "Welcome Back" message. The first time the person visited the site, a cookie was probably set on their computer; when they return, the cookie is read again. A person can configure their web browser to refuse to accept cookies, to disable cookies, and to remove cookies from their hard drive as needed.

Some Web Servers may also use cookies to retain user preference information. It is against Wade College policy to share this information with external third parties.

Some pages within the wadecollege.edu domain may contain content that is served from external third parties. For example, a wadecollege.edu web site might include a graphic logo or a script from a third party.

Wade College does not transmit any information to these third parties. However, when a person visits wadecollege.edu pages that contain third party content, information, such as their IP address, date, browser, and requested page, may be transmitted from the person’s computer to that third party.

Wade College processes personal data for a number of reasons, including to meet its contractual obligations, the legitimate conduct of its business operations, and to comply with applicable law. Sometimes, consent will be the basis for processing personal data. In these cases, Wade College will ask the data subject for consent to process their personal data and to share that data with third parties. The processing of personal data provided to Wade College by a data subject or from authorized third parties, like their high school or a national testing service, enables Wade College to identify the data subject; engage in processing an application or other submission to Wade College; or verify information already provided to Wade College.

Wade College may also use or disclose personal data for the following statutory or public interest purposes: to prevent or detect fraud; to monitor equal opportunity; to better serve the needs of students with disabilities with reasonable accommodations; or for research and statistical purposes, the later purpose relying only on aggregate data.

Furthermore, Wade College processes personal data either necessary for Wade College to take steps with a view to creating a contractual relationship with a person or for the purposes of a legitimate interest of Wade College pursued by Wade. Wade College requires persons to provide Wade College with certain information during the application process in order to assess their application properly except where providing personal information is marked as optional. Neither admissions nor employment decisions are automated.

Some College Web websites use Google Analytics; a web analytics service provided by Google, Inc. Google Analytics uses cookies to collect information such as URLs, Internet domain and host names, browser software, and the date and time that the user visits the site. This information is used to monitor the effectiveness of the website and to consider potential improvements to the website. The information is non-personal and is transmitted to and stored by Google on its servers. Wade College does not share any specific information about a particular user.

Please visit the following pages for more information on Google Analytics terms of use and Google's privacy practices. To opt out of Google’s data collection, read more about the Google Analytics opt-out browser add-on.

Wade College does its best to ensure that the personal information it has is accurate. Users can check and update personal information such as their address and email address at Campus Cafe.

Although no computer system is 100% secure, Wade College has deployed extensive security measures to protect against the loss, misuse, or alteration of the information under our control.

Wade College has policies and procedures in place in case of a data breach or some other incident that places information held by Wade College in jeopardy. Any individual who believes a data breach has occurred must immediately notify the Office of the President, who will investigate the alleged breach and remediate the breach, including providing any required notices.

In certain circumstances, Wade College may be required to provide notice to affected individuals or certain governing authorities if a data breach results in disclosure of personal data.

Several sites within Wade College Web may enable users to pay for products or services online with a credit card. It is Wade College policy to only use confidential information that a user enters during a transaction for the purposes described in that transaction unless an additional use is specifically stated on that site.

Except for educational records governed by the Family Educational Rights and Privacy Act (“FERPA”) or information made confidential by other law, all information provided to and collected from Wade College Web, including the summary server log information, emails sent to Wade College Web, and information collected from College Web-based forms, along with any other form or type of document or other instrument containing personal information, may be subject to all applicable federal and state laws and regulations.

Such information may also, in the legal context, be subject to discovery requests or other legal demand that personal data or information be released and made public. The same is true for any personal information obtained by Wade College through other means such as written submission or communications with previous schools or employers.

Wade College does, upon explicit request of users, share information with other parties and gather information from other private data providers. For example, Wade College receives test scores from testing agencies and sends transcripts to other institutions. This is done only at the request of users.

As well as circulating application and related materials to the appropriate staff at Wade College and its various departments and colleges, Wade College may share personal information for the above purposes as relevant and necessary with:

• School/college or training organizations;
• Examination boards or testing services;
• In the case of international applicants, the appropriate state and federal agencies;
• Immigration authorities in order to act as a person’s sponsor for visa purposes;
• Governmental bodies, including local authorities; and other agencies or private actors, such as health care providers, that circumstances require be privy to certain personal information;
• Other Higher Education organizations, in order to assist with tracking and research into access to Higher Education; and
• Companies or organizations providing specific services to, or on behalf of, Wade College and/or one or more of its component colleges, schools, department or programs.

Unless specifically required under public information requests or otherwise compelled by lawful means, or as a party to a legal action, it is against college policy to release confidential information gathered through Wade College Web, such as pages visited, or personalized preferences.

Consistent with FERPA and other applicable privacy law, Wade College does not release personal student information, other than public directory information, to other parties unless Wade College receives explicit written consent, is required to do so by law, or for other legitimate ends of Wade College. Wade College students can read more about directory information in the Wade College Catalog. Examples of directory information include first and last name, address, and date of birth. Enrolled students can restrict release of their directory information by contacting the Office of the Registrar.

Wade College may make some public chat rooms, forums, message boards, and news groups available to its users. Wade College does not ordinarily log public chat sessions; however, any information that users disclose in these areas becomes public information, so users should exercise caution when deciding to disclose confidential information in such places.

Academic chat sessions and discussion forums may be logged. However, FERPA generally prohibits disclosure of these educational records.

At any time, Wade College may conduct numerous online surveys on Wade College Web. It is college policy only to use personal information gathered in these online surveys for the research purposes indicated in the survey. Unless otherwise noted on the specified survey, answers are confidential and individual responses will not be shared with other parties unless compelled by law. Aggregate data from surveys may be shared with external third parties.

Wade College will internally share the personal information it receives from applications and other information submitted to Wade College in accordance with Wade College’s policy and practice. Various university staff and faculty may be involved in processing personal data for the purposes for which Wade College obtained the data. In some instances, a third-party vendor employed by Wade College to assist in data processing might process personal data. Data subjects have the right to be notified of such third-party processing of their personal information.

For students, Wade College will use the details provided on their application, together with any supporting documents or other forms of information that an applicant may provide with their application. For the purposes of this policy the “application” may include, but not limited to, the online application, application fee, high school transcripts, college transcripts, test scores, resume, letters of recommendation and, if applicable, permanent residence card. Different application forms may apply depending on citizen/residency status.

In addition to the application form, Wade College will use the details in a transcript from every senior college the applicant has attended. Wade College may also rely on personal information that arises from student conduct investigations or hearings.

Data subjects have the right to access the personal information that Wade College holds about them. Data subjects also have the right to ask Wade College to correct any inaccurate personal information Wade College holds about them. In some cases, data subjects may request that Wade College delete personal information, request that Wade College restrict processing their personal information, or object to Wade College processing their personal information.

There are several laws, including FERPA, that give data subjects certain rights so far as it pertains to their personal information.

FERPA provides the right to correct one’s personal data and have access to personal information kept about them.

As a general rule but subject to certain exceptions, schools must have written permission from the parent or adult student in order to release any part of the student’s education records.

Persons have the right to request access to, a copy of, rectification, restriction in the use of, or erasure of your information in accordance with all applicable laws. The erasure of your information will be subject to the retention periods of applicable federal and state law and Wade College’s Record Retention Schedule. If you have provided consent to the use of your information, you have the right to withdraw consent without affecting the lawfulness of Wade College's use of the information prior to receipt of your request. A Data Subject may exercise their rights by contacting Wade College’s Office of the President.

The State of Texas and the United States also have laws that address privacy generally and the use of certain types of records, such as educational records that contain personally identifiable information. Texas has laws that govern records retention.

Wade College follows a records retention schedule, Wade College’s Record Retention Schedule for in the Wade College Policy Handbook. Wade College may update the records retention schedule from time to time.

Students with questions about how their personal information is used or who wish to exercise any of their rights, may consult this policy and contact the Office of President.

This webpage was last updated in April 2024. It is reviewed when necessary and at least annually. Wade College will publish changes here and may provide notification to users via this webpage and/or by email.