Student Privacy Policy

EFFECTIVE DATE OF THIS STUDENT PRIVACY POLICY

This Student Privacy Policy is effective as of October 5, 2006.

PURPOSE OF THIS STUDENT PRIVACY POLICY

Jones International University (“JIU®,” “we,” “us,” and “our”) is committed to protecting the privacy and accuracy of its students’ personal information. We have created this Student Privacy Policy for two purposes:

• to inform our students of their privacy rights under the Family Educational Rights and Privacy Act (together with the implementing regulations, “FERPA” or “the Act”), and
• to describe the ways we collect, use, and share the personal information we collect when our students log on to the password-protected areas of the websites that comprise our online university (our “Student Sites”).

If there is any conflict between the provisions of the Act and any section of this Student Privacy Policy (or any “Privacy Notice” posted on our Student Sites) then the provisions of the Act will apply.

PRIVACY NOTICES

This Student Privacy Policy may be supplemented or amended from time to time by “Privacy Notices” posted on our Student Sites. Our Privacy Notices provide a level of detail that we cannot provide in this more general description of our privacy practices. For example, certain pages of our Student Sites contain Privacy Notices providing details about the personal information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.

FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT NOTICE

Your rights under the Family Educational Rights and Privacy Act

The Family Educational Rights and Privacy Act (together with the implementing regulations, “FERPA” or “the Act”) protects the privacy of student educational records. Under the Act, you (or your parent or legal guardian, if you are under 18) have the right to

• inspect and review your education records;
• request an amendment to your education records, if you believe they are inaccurate, misleading, or otherwise violate your privacy rights;
• consent to disclosures of personal information from your education records, unless the Act authorizes disclosure without your consent; and
• file a complaint with the Family Policy Compliance Office of the U.S. Department of Education if you believe we have not complied with the Act.

With certain limited exceptions (set forth in the Act), you have the right to inspect and review your education records at our corporate office in Centennial, Colorado, or to request copies of them if it would be inconvenient to come to our office.

What are “education records”? Education records are the records maintained by JIU that relate directly to a current or former student, including student applications, transcripts obtained from other schools, course schedules, and grades. Education records do not include:

• information contained in the private files of JIU faculty and staff, that is used only as a personal memory aid and is not accessible or revealed to any other person except a temporary substitute for person who created the record;
• the records of JIU’s law enforcement unit;
• information in JIU’s employee records about a student employee, unless the student’s employment was contingent on his or her student status;
• medical and psychological records made, used and disclosed only for providing treatment purposes; or
• records that only contain information about an individual after he or she is no longer a JIU student.

How do I inspect my education records? If you wish to review or obtain copies of your education records, you (or a parent or legal guardian if you are under 18) must submit a written request by fax to the Registrar at +1.303.784.8547 or by postal mail to the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. Your request must include your name and contact information, a description of the records you would like to review, and the address to which you would like us to send any copies you request. For your protection, we may ask you for additional information to verify your identity. We do not charge for locating your records, but we do reserve the right to charge for photocopying as permitted under the Act. We will respond to your request within a reasonable period of time and, in any case, not more than 45 days after we have received your request.

There are some limited circumstances under which we may deny you access to your education records. For example, you will not be permitted to review financial records, including your parents’ financial information, nor will you be permitted to review confidential letters, or statements of recommendation if you have waived your right to inspect and review those letters or statements.

Your right to amend your education records

If you believe that your education records are inaccurate, misleading, or otherwise in violation of your rights under the Act, you (or a parent or legal guardian, if you are under 18) have the right to ask JIU to amend your education records. Note, however, that the Act does not provide a right to challenge grades, except to correct a grade that was inaccurately recorded.

How do I request amendment of my records? To challenge information in your records, you (or a parent or legal guardian if you are under 18) must submit a written, signed request for amendment to the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. Your request must describe the record you want to have amended, the amendment you request, and the reason for the amendment. You should also provide contact information, in case we need more information. We will respond to your request within a reasonable period of time. If we decide not to amend the record, we will explain why. If you disagree with our decision, you may request a hearing.

How do I request a hearing? To request a hearing, you (or your parent or legal guardian if you are under 18) must submit a written, signed request for a hearing to the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. We will schedule your hearing within a reasonable period of time.

How will the hearing be conducted? For your convenience, you may request that the hearing be conducted in person, via telephone, or by other electronic means. You (or your parent or legal guardian) may present evidence, and you may be represented by anyone you choose, including an attorney, at your own expense. The hearing will be conducted by a JIU official who does not have an interest in the outcome. We will notify you in writing of our decision within a reasonable period of time and provide a summary of the evidence and the reasons for our decision.

What are my rights if the hearing official denies my request for an amendment to my records? You may appeal the hearing officer’s decision to the President of JIU, but only if you do so in writing and within ten days after you receive the hearing officer’s decision. To appeal the hearing official’s decision, you (or your parent or legal guardian if you are under 18) must submit a written, signed request to the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The Registrar will forward your request to the President. The President will consider your appeal and render a decision within a reasonable period of time. The decision of the President represents JIU’s final decision.

Your right to place a statement in your record. If as a result of the hearing (or your appeal to the President) JIU decides that the information in your education record is not inaccurate, misleading, or otherwise in violation of your rights under the Act, you (or your parent or guardian if you are under 18) have the right to place a statement in the record commenting on the contested information in record or stating why you disagree with our decision, or both. If you choose to place a statement in the record, we will maintain your statement as part of the record for as long as we maintain the record. We will disclose your statement whenever we disclose the portion of the record to which it pertains.

Finally, if you believe that we have violated your rights under the Act, you may challenge the decision by filing a complaint with the Family Policy Compliance Office of the U.S. Department of Education as described below.

Your Right to Consent to Disclosure of Your Education Records

Except as provided in the Act, and except for “directory information,” before JIU will disclose any part of your education records to a third party, you (or, if you are under 18, your parent or legal guardian) must provide JIU with a signed, written release specifying which records may be disclosed, the purposes of the disclosure, and to whom the records may be disclosed. At your request (or at the request of your parent or legal guardian, if you are under 18), we will provide you (or your parent or legal guardian) with a copy of the records we disclosed at your request.

What is “directory information”? Under the Act, JIU may disclose directory information without your consent, unless you specifically ask us not to. For example, we may publish directory information in a student directory, a yearbook or the program for a graduation ceremony or provide directory information in response to inquiries and requests.

JIU defines the following categories of personal information as “directory information”:

• name
• email address
• business and home addresses
• business and home telephone numbers
• program of study and degree specialization
• participation in officially recognized JIU activities
• dates of attendance
• enrollment status (part-time or full-time/current or inactive)
• class status (freshman, sophomore, junior, or senior/undergraduate or graduate)
• expected graduation date
• graduation date
• degrees granted, including any honors or awards
• most recent previous school or institution attended
• picture (photograph) and/or audio or video clip

If you are a current student and you do not want JIU to classify any information about you as “directory information,” you must notify us by completing, signing, and submitting a Directory Information Request Form. Your request will ordinarily be processed within 10 days. Your request will only apply prospectively; it will not affect previously released information. You may change your direction at any time by submitting another Directory Information Request Form.

Exception for disclosure to JIU officials for a “legitimate educational purpose.” The Act identifies a number of situations in which JIU may disclose your education records without your prior consent. For example, we may disclose relevant parts of your education records to “JIU officials” we have determined have a “legitimate educational interest” in reviewing those parts of your records. “JIU officials” are JIU employees in academic, administrative, support or supervisory positions; members of JIU’s Board of Directors; and individuals and companies who provide services to JIU and who need access to education records to perform those services, such as our attorneys, auditors, and collection agencies. JIU officials have a “legitimate educational interest” if they need to review an education record in order to perform their responsibilities as JIU officials.

Your right to file a complaint

If you believe JIU has violated the Act, you are encouraged to immediately notify the President of JIU by email at dleasure@international.edu or by letter addressed to Office of the President, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The President will promptly review all allegations of noncompliance.

You also have the right to file a written complaint with the Family Policy Compliance Office, United States Department of Education, 400 Maryland Avenue, SW, Washington, DC 20202-5920. The complaint must contain specific allegations of fact giving reasonable cause to believe that a violation of the Act has occurred. Unless the Office extends the time limit for good cause, your complaint must be submitted to the Office within 180 days of the date the alleged violation occurred or of the date you knew or reasonably should have known of the alleged violation.

Questions about FERPA

If you have questions about your rights under the Act, please contact our FERPA Compliance Officer at registrar@international.edu or by calling +1.303.784.8048. Additional information about FERPA is available at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

INFORMATION ABOUT JIU’S ONLINE PRIVACY PRACTICES

Definitions

Because we are an online university, most of the personal information we collect from and about our students is collected through our Student Sites. As used in this Student Privacy Policy, the term “personal information” refers to information that identifies a particular student, alone or in combination with other information that is readily available to JIU. The term “Student Sites” refers to the password-protected areas of the websites that comprise our online university, including JIU Student Sites located at the following web addresses:

http://www.international.edu
http://my.jiu.edu
http://courses.jonesinternational.edu
http://jiublog.jonesinternational.edu

What Personal Information Do We Collect Through Our Student Sites?

Information You Provide. We collect the personal information you knowingly and voluntarily provide when you use one of our Student Sites, for example, the information you provide when you register for a course, participate in classroom discussion, submit coursework, complete a survey, or contact us with questions or comments.

Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your web browser. This information typically includes your IP address, the address of the web page you were visiting when you accessed our Site, the name of your operating system (such as Windows® or Macintosh®), the name and version of your browser (such as Netscape® or Internet Explorer®), and the date and time of your visit. The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings.

The information provided by your browser does not identify you personally. However, we may link the information provided by your browser to information that identifies you personally and use it for the purposes described below. In addition, we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we may share our server logs -- which contain visitors’ IP addresses -- with the appropriate investigative authorities who could use that information to trace and identify individuals.

Information Collected Using “Cookies” and Other Web Technologies. We use “cookies,” and similar technologies to collect information and support the functionality of our Student Sites. A cookie is a small text file that is placed on your hard disk by a web server. Cookies cannot be used to install computer programs or deliver viruses to your computer. We may use two types of cookies -- “session cookies” and “persistent cookies.”

Session Cookies. A “session cookie” assigns a randomly-generated, unique identification number to your computer when you access one of our Student Sites. Assigning your computer a number permits us to follow you as you move from page to page during a particular visit. A session cookie expires after you close your browser. Session cookies do not identify you personally, however, we may link the information collected by our session cookies to information that identifies you personally.

Generally, we use session cookies to collect information about the ways students use the Student Sites – which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “click-stream information”) to better understand our students’ interests and needs and to improve the content and functionality of our Student Sites. Session cookies are also used to facilitate the proper functioning of certain features of our Student Sites, for example, to ensure that our streaming multimedia server functions properly.

Persistent Cookies. When you enroll in JIU, we will place one or more “persistent cookies” on your computer. These persistent cookies will identify you as a student enrolled in one of our programs and may contain other information that will allow us to provide you with a personalized online educational experience. Unlike a “session cookie,” a persistent cookie does not expire when you close your browser. It stays on your computer until it expires (for example, at the end of the academic year) or until you delete it.

Although it is possible to set your browser to reject cookies or to delete our cookies as soon as you log off, doing so would prevent you from using the functionality of our course sites and other functionality critical to your interactions with JIU. For this reason, all students are required to set their browsers to accept cookies and must not delete JIU cookies while they are “active” students.

How Do We Use the Personal Information We Collect Through Our Student Sites?

JIU uses the personal information collected through the Student Sites to provide a personalized, quality educational experience to you, as well as any information, services or products you request.

We use your contact information to communicate with you, for example, to notify you of your course schedule, to answer your questions, and to tell you about upcoming events. We will also send you surveys asking you to provide feedback to us, for example, about the courses you have completed. In addition, from time to time we will send you “promotional” emails, for example, an email describing a new degree program. You may “opt-out” of receiving promotional emails at any time by clicking on the “opt-out” link at the bottom of the email.

We may use specific personal information for the purposes identified in a specific Privacy Notice posted on the page or area of our Site where you provided that information.

Finally, we may study the information we collect through our Student Sites to improve our programs and services, to improve the content, functionality, navigation, and usability of our Student Sites, and to market our programs, services, and products. We may remove all of the information that identifies specific individuals and use the rest for historical, statistical or scientific purposes.

With Whom Do We Share the Personal Information We Collect Through Our Student Sites?

We may disclose personal information we collect through our Student Sites with your prior written consent and as otherwise permitted under the Family Educational Rights and Privacy Act (FERPA). For example, we may disclose educational records to JIU staff and faculty who have a legitimate educational interest; to another school to which you are transferring; to appropriate parties in connection with financial aid for which you have applied or which you have received; and to accrediting organizations. In addition, we may disclose “directory information” to third parties or the general public unless you have asked us not to do so by completing our Directory Information Request Form. We may share specific personal information as disclosed in a specific Privacy Notice posted on the page or area of our Student Sites where you provided that information. To learn more about your privacy rights under the Act, please review our Family Educational Rights and Privacy Acts Notice.

Your personal information may be transferred to another company (either an affiliate or an unrelated third party) that has acquired the stock or assets of JIU, one of our affiliates, or one of our operating divisions, for example, as the result of a sale, merger, reorganization, dissolution, or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Student Privacy Policy, any applicable Privacy Notices, and the privacy preferences you have expressed to us.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have industry standard measures in place to protect the confidentiality and security of the personal information in our students’ “education records,” including the information we collect through our Student Sites. It is important that you understand, however, that no website or database is completely secure or “hacker proof.”

You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse, for example, by protecting your user name and password. We have the right to assume that any individual who logs on to a Student Site using a student user name and password is the student to whom that user name and password is assigned. If you believe that your user identity has been compromised, you must immediately change your password. You will be responsible for the activities of anyone who accesses a Student Site using a user identity assigned to you, whether those activities were authorized by you or not.

TRANSFERS TO OTHER COUNTRIES

JIU is a U.S. corporation headquartered in Centennial, Colorado. Our Student Sites are currently hosted on servers located within the United States, but the locations of our servers may change from time to time. Our students’ “education records” are stored at offices or on servers located within the United States or in another country.

Different countries have different privacy laws, some of which provide more protection than others. When JIU transfers personal information from one country to another, we do so in compliance with applicable privacy laws. Moreover, no matter where a student’s personal information is collected, used or stored, it will be protected by the terms of this Student Privacy Policy, any Privacy Notices that apply to you, and applicable data protection laws.

By enrolling in JIU as a student, you are consenting to the use and storage of your personal information in the United States or in any other country in which JIU data may be processed.

LINKS TO OTHER WEBSITES

Our Student Sites contain links to other websites operated by Jones International and its affiliates. Our Student Sites also contain links to websites that are owned and operated by unrelated third parties.

This Student Privacy Policy applies only to personal information collected through our “Student Sites.” It does not apply to personal information collected on any other website operated by Jones International, its affiliates, or any third party.

OUR STUDENT PRIVACY POLICY MAY BE UPDATED FROM TIME TO TIME

We reserve the right to update or modify this Student Privacy Policy, at any time and without prior notice, by updating our Student Handbook and posting the revised version of this Student Privacy Policy behind the appropriate links on our Student Sites. These changes will only apply to personal information we collect after we have updated the Student Handbook and posted the revised Student Privacy Policy on our Student Sites.

Unless the change is a non-substantive change, we will send you an email to alert you to the change. The email will describe the change and contain a link back to the revised Student Privacy Policy.

This Student Privacy Policy was last revised October 5, 2006.