Why We Process Your Personal Data As set out above, we process your Personal Data because it is necessary for the performance of a contract with you (i.e., our agreement with you to provide you with an education), or in order to take steps at your request prior to and in furtherance of entering into that “education contract.” In this respect, we use your Personal Data as follows: (i) to interact with you before you are enrolled as a student, as part of the admissions process (i.e., to send you a prospectus or answer inquiries about our courses); (ii) to provide you with services once you have enrolled; (iii) to deal with any concerns or feedback you may have; and (iv) for any other purpose for which you provide us with your Personal Data. We also may process your Personal Data because it is necessary for the performance of our business as a provider of higher education, or because it is necessary for our, or a third party’s legitimate interest. In this respect, we may use your Personal Data for the following: (i) to provide you with educational services that are a part of our academic and educational mission; (ii) to monitor and evaluate our performance and effectiveness, including by training our faculty and staff, or monitoring their performance; (iii) to maintain and improve our academic, financial, and human resource management; (iv) to promote equality and diversity throughout Hodges; (v) to seek advice on our rights and obligations, such as where we require legal advice; (vi) recovering money you owe to us; and (vii) for alumni relations and fundraising purposes. We also may process your Personal Data for our compliance with our legal obligations. In this respect, we may use your Personal Data for the following: (i) to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws, Title IX and other non-discrimination laws, FERPA, and certain other legal requirements; (ii) to assist with investigations (including criminal investigations) carried out by the police and other legal authorities; and (iii) to maintain or acquire accreditation status with regulatory
bodies. Finally, we also may process your Personal Data where: (i) it is necessary for medical purposes (i.e., medical diagnosis, provision of health or social care or treatment, or a contract with a health professional); (ii) it is necessary to protect your (or another person’s) vital interests; or (iii) we have your explicit consent to do so. How We Share Your Personal Data For the purposes referred to in this Notice and relying on the legal bases for processing as set out above, we may share your Personal Data with certain third parties in accordance with applicable law (including FERPA). We may disclose limited Personal Data to a variety of recipients including: (i) the US Department of Education, the Federal Student Aid office, and relevant state agencies and/or offices; and (ii) our Board of Trustees, faculty members, employees, agents, contractors, consultants, volunteers, students serving on official committees or assisting school officials, where there is a legitimate reason for their access to or receipt of the information, including disclosures to: (A) third parties who work with us to provide student services; (B) third parties who work with us to provide student support services (i.e., health services and counselling); (C) organizations operating anti-plagiarism software on our behalf; (D) internal and external auditors, attorneys, and other professional service providers; (E) certain third parties interested in tracking student progress and attendance, including: (1) current or potential education providers; (2) current or potential employers (i.e., to provide references and, where students are sponsored by their employer and/or where you take part in a placement program, to provide details of progress/attendance); (3) professional and regulatory bodies in relation to the confirmation of qualifications, professional registration, conduct, and the accreditation of courses; (4) government departments and agencies where we have a statutory obligation to provide information; (5) police or law enforcement agencies; (6) parents, guardians, and next-of-kin (where
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Hodges University Student Handbook
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