Privacy Policy

Open Society University Network Privacy Notice

Updated January 19, 2022

Bard College and the Central European University Private University jointly administer the Open Society University Network (OSUN), including its educational activity, website, e-newsletter, constituent relationship management system, and grants management system.  This Privacy Notice applies to all who interact with OSUN online or otherwise provide OSUN with their personal information.  OSUN is deeply committed to the protection of your personal information and to compliance with applicable data privacy requirements, including the EU General Data Protection Regulation (GDPR).  This Privacy Notice relates to the collection, use, transfer, and retention of your personal data as you participate in the online OSUN community.  

This Privacy Notice does not apply to OSUN-sponsored programs managed by individual OSUN institutions.  Such programs are subject to the privacy policy of the institution that manages them.

1. Who We Are and What We Do
OSUN was co-founded by the Central European University and Bard College and is developing its programs jointly with the institutional partners.  OSUN is a global partnership of educational institutions that integrates learning and the advancement of knowledge across geographic and demographic boundaries, promotes civic engagement on behalf of open societies, and expands access to higher education for underserved communities.  Through its programs and collaborations, OSUN, together with its partner institutions, aims to build a new model of global higher education and create new opportunities for students, faculty, researchers, and administrators in its community.

2. Identity and Contact Details of Data Controllers
Bard College and the Central European University Private University qualify as joint data controllers according to Article 26 of the GDPR (the “Joint Data Controllers”), as they are the founding institutions of OSUN, while the everyday operations of OSUN are managed by the OSUN Secretariat.  The OSUN Secretariat acts on behalf and under the instructions of the joint data controllers when implementing their decisions regarding the purposes and means of data processing.  Thus, the OSUN Secretariat, representing the data controllers, collects, uses, and stores all the personal data collected during the course of relationships that OSUN or OSUN-sponsored programs develop with faculty, staff, students, alumni, partners, donors, and supporters or other third parties.  Most of the personal data that OSUN holds is obtained directly from you when you apply for, participate in, or otherwise interact with an OSUN-sponsored program, activity, or event.

Bard College
Campus Road, P.O. Box 5000
Annandale-on-Hudson, New York 12504-5000
Email: [email protected]

Central European University Private University
Quellenstrasse 51, 1010 Vienna, Austria
E-mail: [email protected]

3. What Is the Purpose and the Legal Basis for Processing Your Data?
Activity What data is collected Purpose for data processing Storage time Legal basis
Applications
Registration in OSUN Portal Name, email, phone, preferred pronoun, country of origin, academic information (institution, position,, department/faculty/center, highest academic degree completed, existing OSUN program affiliations, collaboration interests, area of expertise Document eligibility for OSUN opportunities. Facilitate cross-institution collaboration. Send targeted email communications. Until user deletes account Consent of data subject
Proposal submissions and applications for grants, fellowships, and other program opportunities For the requested data, please check the applicable form. Names, emails, institutional affiliations, narrative and budget proposals, and for participant screening purposes legal name, birthdate, country of citizenship, refugee status. For fellowship applications, CV and support letters. Review and select proposals or applications Accepted proposals or applications kept for 3 years after program closeout. Rejected proposals or applications kept for 3 years after the application deadline but can be deleted upon request. Consent of data subject
Courses
Network collaborative course sites Course syllabus and materials; faculty names, emails, institutional affiliation, short bios; enrolled students' names, emails, institutional affiliation, grades for course assignments (not the official final course grade) Develop course site and provide students with course materials and connected learning space 3 years; course syllabus and materials and faculty data can be kept longer at course leader’s request Legitimate interest of data controller
Recordings of class sessions Names (account profiles) of students, faculty, and guest speakers, profile pictures, video of students, faculty, and guest speakers Record videoconference class sessions and make videos accessible on the course page for asynchronous use by students 3 months after course ends Legitimate interest of data controller
Asynchronous student assignments Students’ collaborative assignments in different formats (online discussions, posts, videos, etc.) Provide online space for students to learn interactively 1 year after course ends Legitimate interest of data controller
Student registration in OSUN online courses Students' name, email, institutional affiliation, gender, date of birth, citizenship, ethnicity/race, pronoun, expected date of graduation, transcript, major, minor, permanent address (to get Bard ID), current address (if in-person) Register students in OSUN online courses. Verify qualifications for student enrollments. Assess diversity of participation in OSUN courses. 35 years Legitimate interest of data controller
Programs
Event registrations Participants’ name, email, institutional affiliation Document participation in OSUN-sponsored events Name, event and institution kept for 1 year Consent of data subject
Participant screening Participants’ name, date of birth, country of citizenship Screen non-US program participants for legal compliance 7 years following each screening Legitimate interest to meet legal obligations: US Executive Order 13224 and country-specific US economic sanctions laws
Program monitoring and evaluation Participant names, emails, institutional affiliations; descriptions of specific participant activities; quotes from participant evaluations Document program activities and participant feedback to evaluate program progress and impact 3 years after program closeout Legitimate interest of data controller
Communications
E-Newsletter Names, emails, institutional affiliations, date of consent Publicize OSUN-sponsored opportunities Until withdrawal; regular check every 3 years Consent of data subject
Targeted announcements Name, email, institutional affiliation, collaboration interests, area of expertise Target communications to publicize OSUN-sponsored opportunities Until user deletes account Legitimate interest of data controller
Network building Name, email, institutional affiliation, collaboration interests, area of expertise Connect faculty, staff, and students with similar interests across OSUN institutions to facilitate collaboration Until user deletes account Legitimate interest of data controller

4. Who Receives Your Information?
Personal data obtained by OSUN may be shared with or by OSUN institutions for the purposes of facilitating cross-institution collaboration or conducting OSUN-sponsored programs, activities, or events.  Other than that, the OSUN Secretariat will not disclose your data to individuals, organizations, or other entities outside OSUN unless it has a legal obligation to do so.

On some occasions OSUN needs to engage the services of third-party data processors, agents, or contractors for purposes set out in Section 3.  For example, we may engage third parties to assist us with website hosting, distribution of online communications, data analysis, or other administrative services.

Whenever your data is shared with a third party, we share only the data needed to perform the specific service and we require a contract with a confidentiality agreement to be signed before any data transfer takes place.  The confidentiality agreement requires the third party to keep your information secure and not to use it for their own purposes.  We will not sell or rent your information to third parties.

Third parties that act as data processors for the OSUN include:
5. What Are Your Rights?
You have a right to:
  • request a copy of the personal information we hold about you
  • withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information
  • ask us to correct any personal information that we hold about you which you believe to be inaccurate
  • request that we delete the personal information we hold about you, in so far as we are legally required to do so
  • object to the processing of your personal information where we process on the basis of the legitimate interests ground or use the personal information for statistical purposes
  • ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate use
If you wish to exercise any of these rights, please contact us at [email protected].  The OSUN Secretariat, after confirming your identity, will make every effort to fulfill your request to the extent allowed by law.

6. Security of Your Data
The OSUN Secretariat is committed to holding your data securely and treating it with sensitivity.  While we take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information, there is no perfect security in the online environment, and we cannot guarantee the security of any information you transmit to us through or in connection with the OSUN website or portal.

If you believe that your interaction with us is no longer secure (for example, if you consider that the security of any account you might have with us has been compromised), please notify us immediately by contacting us at [email protected].

7. Future Changes
If our Data Privacy Policy is updated in the future, we will post the updated policy here on this page.