Welcome to the University of Niagara Falls Canada (“UNF”) privacy notice. UNF is part of Global University Systems B.V. group of companies (“GUS”) which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com.
UNF respects your privacy and is committed to protecting your personal data. This privacy notice tells you how and why we collect, use, disclose and protect your personal information in compliance when you visit our websites (regardless of where you visit from) or use our services, and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at section 12 for the meaning of some of the terms used in this privacy notice.
Purpose of this privacy notice
This privacy notice aims to give you information on how University of Niagara Falls Canada collects and processes your personal data including any data you may provide through this website when you:
- arrive on our website from a social media site (e.g., Facebook Twitter, Instagram, Snapchat, Pinterest, TikTok, VKontakte, or LinkedIn);
- complete a callback or enquiry form;
- register on our site to apply for a course, program, corporate/executive education, or professional training, whether it is online, distance-learning or campus-based, and whether you are applying for yourself or on behalf of employees or staff at your organization which may be or become a customer of ours;
- sign up for marketing materials; or
- provide us with your personal data by any other means.
This website is not intended for children, and we do not knowingly collect data relating to children on this website. However, where UNF processes personal data of children in its business operations, we ensure that appropriate safeguards and consent are obtained from parents or caregivers as applicable. If you are under the age of 16 and wish to submit an application or other personal data to UNF, please contact the Privacy and Data Protection Officer at firstname.lastname@example.org for further information about obtaining parental consent.
You must read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and does not replace them.
- Important information and who we are
This website is operated on behalf of Niagara Education Inc., a company registered in Canada with number with its registered records office at 199 Bay Street, Suite 2200, Toronto, ON M5L 1G4, Canada.
We have appointed a Privacy and Data Protection Officer who is responsible for overseeing questions about this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Privacy and Data Protection Officer using the details set out below.
Our full details are:
Full name of data controller legal entity: University of Niagara Falls Canada
Name or title: Privacy and Data Protection Officer
Email address: email@example.com
Postal address: C/O Niagara Education Inc., 199 Bay Street, Suite 2200, Toronto, ON M5L 1G4, Canada.
Telephone number: 1-877-431-6887
You have the right to make a complaint at any time to the Information and Privacy Commissioner of Ontario (the “IPC”), the supervisory authority in Ontario for data protection issues. More information about the IPC may be found at: IPC – Information and Privacy Commissioner of Ontario
We would always prefer that you come to us to help address any concerns of a privacy nature before you go to the IPC, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on April 1, 2023.
We may from change the details in this notice time to time. Any changes we may make in the future will be posted on this page. Please check back frequently to see any such updates or changes.
The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins, and applications. Clicking on such links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or policies. When you leave our website, we encourage you to read the privacy notice of every website that you visit.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. Anonymous data is not treated as personal data.
The personal data that we collect, use, disclose, transfer, and process through this website and our educational programs and business activities include:
- Academic Data includes eligibility data (e.g., education and academic history, training records, qualifications, personal statements, résumés, curricula vitae (CV), personal achievements, and references).
- Contact Data includes billing address, temporary and permanent residential addresses, mailing address, country of residence, email address, and telephone numbers.
- Emergency Contact Data includes the names and contact information of your next of kin, which will allow us to communicate with these persons in the event of an emergency that has involved you. It is your responsibility to ensure that you do not provide us with such information unless you have notified your emergency contacts and obtained their authorization to provide their information to us.
- Employment Data includes the name of your employer, start date, end dates, your job title, and your contact details at work (email address, telephone number and mailing address). This information may be required when a student is sponsored by their employer.
- Financial Data includes billing address, payment information, student loan information, bank account information, payment card details, and records about products and services that you have purchased from UNF. This information is collected to allow UNF to process payments and other financial transactions between you (or others on your behalf) and UNF.
- Health Data includes information relating to your health, including doctors’ notes, medical records, information related to allergies, dietary requirements, medical conditions, or disabilities, and requests for accommodation.
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender identity, marital status, Unique Learner Number, nationality, residency status, disability declaration, criminal conviction declaration, third party student reference number where that third party shares your data with us, and photographic images.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Monitoring and Reporting Requirements Data includes the data reported to third parties for regulatory purposes.
- Profile Data includes any of your usernames and passwords, enquiries or requests made by you, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Student Data is collected when you apply or register for, or enroll in, one of our educational programs and is used to assess your eligibility and to enroll, deliver, manage, and terminate your educational services at UNF. Student Data includes your:
- Contact Data
- identification photo;
- subject, course, or program of interest;
- chosen program of study;
- progress data;
- coursework results;
- exam results (including mocks);
- other results from before final study years;
- exam scripts;
- feedback or references from lecturers;
- communications with UNF;
- use of any learning facilities or services by UNF information Services;
- use of the UNF library resources (including materials checked out and overdue items);
- membership in student groups and associations;
- attendance at any event hosted or advertised by UNF and its partners and affiliates;
- mentor and mentee;
- membership in any relevant alumni network;
- learner analytics and profiling data; and
- disciplinary data.
Student Data will also include any:
- complaints regarding a student, course, tutor, faculty member, or UNF employee;
- claims involving you of any nature whatsoever;
- extenuating circumstances;
- appeals involving you;
- additional information as required by professional, accreditation, or awarding body; and
- other information that we are required by law to collect or report about your participation in an educational program.
- Technical Data includes your Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our electronic systems.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Usage Data includes URL data, web analytics data (e.g., how you arrived at our websites, from where, what items or terms you searched for, which pages you visited on our websites, the duration of your visits and such other information about how you use our websites and the information provided on them), and how you use our products and services to assist us to improve our website offering to you and for system maintenance, evaluation, and improvement purposes.
- Visa Data includes passport information, visa information, information regarding previous visas, bank statements, and other financial information to allow us to validate such information and to satisfy ourselves that all Canadian visa requirements are met.
Some personal data that we collect, use, and disclose may also be used to generate aggregated information (“Aggregated Data”) that allows us to assess, analyze, evaluate, and improve our websites, electronic systems, programs, and services. When personal data is used in this way, we will take commercially reasonable efforts to remove your personal identifiers and combine it with the information of other individuals so that the Aggregated Data cannot be used to, directly or indirectly, identify you. We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Category Data
When you make an application on our website for a course, program, or service, we may provide you with the option to provide other information about yourself that may be related to your studies, such as whether you have any disabilities or medical conditions that may require accommodation. You are not obliged to share this information with us, but any information you do provide will allow UNF to assess how we will meet our legal obligations to you. We recognize that such information is sensitive and will make all reasonable efforts to ensure that it is protected and not used or disclosed for purposes not authorized by law.
Criminal Offence Data
For compliance and risk management purposes, we may ask for background checks or seek criminal record information. This type of data is regulated under the Privacy Act, R.S.C., 1985, c. P-21, and we ensure that we limit the use of any such data both in time and in scope and that we meet appropriate lawful grounds for processing such data.
For further information please contact us at firstname.lastname@example.org.
If you fail to provide personal information
You have the right to refuse to provide personal information to us. However, where we need to collect personal data by law or to perform our contractual or other obligations to you or third parties, your refusal may impact our ability to provide or continue providing services to you. In this case, we may have to cancel a product or service you have with us and will notify you of our determination at that time. If you have questions about whether your refusal to supply personal information will impact your relationship with us, please feel free to contact the Privacy and Data Protection Officer at email@example.com
- How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms (paper or electronic) or by communicating with us by mail, telephone, email, or otherwise. This includes personal information that you provide when you:
- apply for and enroll or register in our educational programs, courses, and related services;
- create an account on our website;
- use our website;
- subscribe to our service(s) or publications;
- request that marketing material(s) be sent to you;
- enter a promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical and other Data from the following parties:
- analytics providers such as Google Analytics, Google Optimizer, Google Webmaster tools, Google tag manager, Facebook, Instagram, Conversant (based in Europe), Convertr Media (based in the United Kingdom), and other similar services that we may use in the future.
- social media and advertising networks such as Google Advertising Network, Facebook, Instagram, Bing, and LinkedIn based outside Ontario and similar networks that we may partner with in the future.
- search information providers such as Google, Bing and other search engines based inside and outside Ontario, social media networks such as Facebook, LinkedIn, and Instagram based inside the European Union, and others providing similar services.
- providers of technical, payment and delivery services such as Conversant, Google Analytics, Facebook, Instagram, Bing, LinkedIn and Stripe, based outside Ontario and Convertr Media based inside the UK including similar services we may partner with in the future. These third parties may provide Contact, Financial, and Transaction Data to UNF.
- data aggregators may provide Identity and Contact Data to UNF.
- staff, administrators, and faculty from other educational establishments, mentees or mentors, referees, and complainants may provide Student Data to UNF.
- publishers, who are owners of private websites, and are based in and outside the European Union may provide Academic, Contact, Identity, Marketing and Communications, and Technical Data to UNF.
- agents and referring organizations (e.g., employers and other universities), may provide Academic, Contact, Identity, Marketing and Communications, and Technical Data to UNF
- How we use your personal data
We will only use your personal data as the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- to perform or enter into a contract with you;
- as necessary for our legitimate interests (or those of a third party), such as the provision of educational services and the administration of our operations, and your interests and fundamental rights do not override those interests;
- to comply with a legal or regulatory obligation; and
- in accordance with your express, deemed, or implied consent to the collection of your personal information.
Please see the table below to find out about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org or by clicking the unsubscribe link in the relevant emails.
- Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
For Students and Prospective Students:
|Purpose or Activity||Type of data||Lawful basis|
|Responding to your requests, course enquiries, or applications||Contact Data Identity Data Student Data Academic Data||Performance of a contract with you (in our anticipation of entering into such a contract with you) Necessary for our legitimate business interests|
|Enrolling or registering you as a new candidate, and providing your student number and UNF identity card||Identity Data Contact Data Student Data Academic Data||Performance of a contract with you Necessary for our legitimate business interests Consent|
|Providing you with information about: student benefits and opportunities; UNF activities and events; UNF programs, products, and services; career opportunities; and professional and industrial bodies wishing to communicate with students about career opportunities.||Contact Data Marketing and Communications Data||Consent|
|Direct marketing may include cookie-based remarketing services intended to deliver targeted marketing to you based on your internet searches||Contact Data Usage Data Marketing and Communications Data||Legitimate interest|
|Processing your application for the provision of services including: managing payments, fees, and charges; collecting and recovering money owed to us; and accounting for GST purposes.||Identity Data Contact Data Financial Data Transactional Data Student Data Marketing and Communications Data Academic Data||Performance of a contract with you Necessary for our legitimate interests (e.g., to recover debts due to UNF) Consent|
|Monitoring diversity, equity, and inclusion metrics and equal opportunities||Identity Data||Necessary for our legitimate interests Necessary to comply with a legal obligation|
|Implementing adjustments, supports, and accommodations to meet disability requirements or other medical conditions||Identity Data||Consent|
|Responding to emergencies, accidents, and health concerns, including: Ensuring student, faculty and staff health and safety while on campus; Providing first aid assistance; Carrying out an emergency evacuation, hazard risk assessment, and accident monitoring; Providing assistance and support to students, faculty, and staff in relation to an emergency, accident, and health issue; and Notifying emergency contacts of students, faculty, and staff where necessary||Identity Data Emergency Contact Data||Vital interests Consent|
|Managing, administering, evaluating, and improving our educational programs and related services||Identity Data Contact Data Student Data Academic Data Employment Data Profile Data Usage Data Technical Data Marketing and Communications Data||Consent Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests|
|Monitoring legal compliance and reporting to government authorities||Student Data Transaction Data Academic Data Employment Data Visa Data||Consent Necessary to comply with a legal obligation Necessary for our legitimate interests|
For Customers (or Prospective Customers) of Online Courses and Published Media:
|Purpose or Activity||Type of data||Lawful basis|
|Registering new customers of online materials||Identity Data Contact Data||Performance of a contract with you|
|Managing our payment and accounting processes, including: Processing, fulfilling, and delivering customer orders; Managing payments, fees, and charges; Collecting and recovering monies owed to UNF; Maintenance of accounting records.||Identity Data Contact Data Financial Data Transaction Data Marketing and Communications Data||Performance of a contract with you Necessary for our legitimate interests (e.g., to recover debts due to us) Necessary to comply with a legal obligation|
|Defending legal claims brought against us||Identity Data Contact Data Financial Data Transaction Data Marketing and Communications Data||Performance of a contract with you Necessary for our legitimate interests (e.g., to recover debts due to us) Necessary to comply with a legal obligation|
|Registering you as a client of UNF||Identity Data Contact Data||Performance of a contract with you|
|Managing, administering, evaluating, and improving our educational programs and related services||Identity Data Contact Data Student Data Academic Data Employment Data Profile Data Usage Data Technical Data Marketing and Communications Data||Performance of a contract with you Necessary for our legitimate interests|
For Alumni and Research Participants:
|Purpose or Activity||Type of data||Lawful basis|
|Providing you with information about: alumni benefits and opportunities; UNF activities and events; UNF programs, products, and services; career opportunities; and professional and industrial bodies wishing to communicate with alumni about career opportunities.||Identity Data Contact Data Student Data Marketing and Communications Data||Necessary for our legitimate interests Consent|
|Facilitating academic research||Identity Data Contact Data Student Data Academic Data Employment Data Marketing and Communications Data||Necessary for our legitimate interests Consent|
|Defending legal claims brought against us, and complying with our regulatory obligations||Identity Data Contact Data Student Data Financial Data Transaction Data Marketing and Communications Data||Necessary for our legitimate interests Necessary to comply with a legal obligation|
|Communications for one of the above purposes||Identity Data Contact Data Student Data Marketing and Communications Data||Necessary for our legitimate interests Consent|
|Purpose or Activity||Type of data||Lawful basis|
|Recruiting (e.g., academic job applications performed via a webform)||Identity Data Contact Data||Performance of a contract Necessary for our legitimate interests Consent|
|Updating terms and conditions and notifying you of the same||Contact Data Profile Data||Necessary to comply with a legal obligation Necessary for our legitimate interests (e.g., continuous improvement, updating records, analyzing customer behaviour patterns)|
|Seeking your feedback||Marketing and Communications Data||Necessary for our legitimate interests (e.g., continuous improvement, analyzing customer behaviour patterns)|
|Processing complaints||Identity Data Contact Data Financial Data Transactional Data Student Data Marketing and Communications Data Academic Data||Necessary for our legitimate interests (e.g., continuous improvement, analyzing customer behaviour patterns) Necessary for complainant’s legitimate interests (i.e., resolution of their complaint) Consent|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Data Contact Data Profile Data Usage Data Technical Data||Necessary for our legitimate interests (e.g., for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with a legal obligation|
|Delivering relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data Technical Data||Necessary for our legitimate interests (e.g., to study how customers use our products, programs, and services, to develop products, programs, and services, to grow our business and to inform our marketing strategies)|
|Using data analytics to improve our website, products/services, marketing, student and partner relationships and experiences||Technical Data Usage Data||Legitimate interests (e.g., to define customer types for our products, programs, and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategies)|
|Making suggestions and recommendations to you about goods or services that may be of interest to you||Technical Data Usage Data||Necessary for our legitimate interests (e.g., to develop our products/services and grow our business)|
|Managing, administering, evaluating, and improving our website services and electronic systems||Profile Data Usage Data Technical Data Marketing and Communications Data||Necessary for our legitimate interests|
- How we use sensitive personal data (Special Category Data)
The law requires us to meet additional conditions for collecting, storing, and using personal data that is considered “Special Category” data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
|Purpose or Activity||Type of data||Lawful basis|
|To enroll you as a student we need to determine your immigration status with UNF||Identity Data Contact Data Visa Data||Performance of a contract with you Necessary to comply with a legal obligation|
|Assessing and implementing required adjustments, support, and accommodations for learning needs, disabilities, and medical conditions||Identity Data Health Data||Performance of a contract with you Necessary to comply with a legal obligation (e.g., Human Rights Code, R.S.B.C. 1996, c. 210) Express consent (voluntary)|
|Monitoring student absences||Identity Data Student Data Health Data||Performance of a contract with you Where necessary to comply with a legal obligation (e.g., where a visa stipulates that a student must maintain a minimum level of attendance).|
|Dealing with applications for mitigating circumstances||Identity Data Student Data Health Data||Express consent (this information is voluntary)|
|Dealing with applications for interruptions of studies or deferrals||Identity Data Student Data Health Data||Performance of a contract with you Necessary for our legitimate interests (e.g., processing applications for interruptions of studies or deferrals; maintaining student records) Necessary to comply with a legal obligation (e.g., where a visa stipulates that a student must maintain a minimum level of attendance).|
|Confirming any dietary requirements||Identity Data Health Data||Express consent (this information is voluntary)|
|Monitoring and reporting on diversity, equity, and inclusion metrics and on equal opportunities||Identity Data||Necessary for our legitimate interests Consent|
The above information may also need to be used using the lawful basis of pursuant to a legal claim or to protect your interests (or someone else's interests) (where you are not capable of giving your consent (for example if you suffer a medical problem preventing your ability to communicate).
It is not a condition of becoming a student with us that you give us consent for any processing of Special Category Data. However, should you choose not to give consent, this may impact UNF’s ability to accommodate or support you and may limit your ability to benefit from certain support services at UNF.
We do not need your consent in circumstances where we use Special Category Data in accordance with our legal obligations.
On rare occasions, we may ask for your express, written consent to use certain Special Category Data. If we do this, we will make sure you have a detailed explanation of the Special Category Data that we need and why. This will enable you to make an informed decision regarding whether you wish to consent.
We strive to provide you with choices regarding certain uses of your personal data, particularly around marketing, communications, and advertising. We will always give you options to determine how we use your personal data in this regard.
Promotional offers from us
You will receive marketing communications from us if you have:
- requested information from us;
- purchased products or services from us; or
- provided us with your details when you filled out a survey or feedback form;
and, in each case, you have not opted out of receiving marketing communications.
You can ask us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you, or by contacting our Privacy and Data Protection Officer at email@example.com.
Where you opt-out of receiving UNF marketing messages, this will not stop us from storing your data provided to us as a result of you having applied for a course or program or bought some other service or materials from us.
We use “cookies” on this site
A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our website. Cookies can also enable us to track and target the interests of our users to enhance the experience on our website. The usage of a cookie is in no way linked to any personally identifiable information on our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Privacy and Data Protection Officer at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties (see Glossary in section 12);
- External Third Parties (see Glossary in section 12); and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, or that we may choose to acquire.
If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
We share your personal data within the GUS Group of which UNF is a part. This will involve transferring your data outside Canada.
Some of our external third parties are based outside Canada, so their processing of your personal data will involve a transfer of data outside Canada.
Whenever we transfer your personal data outside of Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries by following the guidelines set by the Privacy Commissioner of Canada (the “OPC)” on the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), which have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see Guidelines for Processing personal data across borders available at: https://www.priv.gc.ca/en/privacy-topics/airports-and-borders/gl_dab_090127/
- You have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for you due to the absence of an adequate decision and appropriate safeguards.
- The transfer is necessary for:
- the performance of a contract between you and us as the data controller, or for the implementation of pre-contractual measures taken at your request.
- the conclusion or performance of a contract concluded in your interests between us as the data controller and another natural or legal person.
- important reasons of public interest.
- the establishment, exercise, or defence of legal claims.
- the protection of your vital interests or the vital interests of other persons, where you are physically or legally incapable of giving consent.
Please contact our Privacy and Data Protection Officer (email@example.com) if you want further information on the specific mechanism used by us when transferring your personal data
- Data security
We have put appropriate security measures in place to prevent your personal data from being accidentally lost, used, altered, shared, disclosed, or accessed in an unauthorized way. In addition, we limit the access to and the use and sharing of your personal data to those employees, agents, contractors and other third parties on a “need-to-know” basis. They will only use, process, share, and access your personal data on our instructions, and they are subject to a duty of confidentiality. We have put procedures in place to deal with any known or suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
In some circumstances you can ask us to delete your data: Email our Privacy and Data Protection Officer at firstname.lastname@example.org for more information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you or identify you, either directly or indirectly) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
You have the right to access your personal data (known as an “access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
UNF will endeavor to provide access to your personal data, but may refuse to disclose such information that:
- is privileged, such as legal advice;
- is personal information of a third party;
- would threaten the mental or physical health of another person;
- constitutes UNF’s confidential or commercial interests;
- is otherwise permitted under PIPA.
To make a request:
If you wish to request access to your information, please contact us at 199 Bay Street, Suite 2200, Toronto, ON M5L 1G4, Canada or by email at email@example.com.
What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response to provide you with your information promptly
- Request correction of your personal data
You may have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data
You may ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, we may not always be able to comply with your request for erasure for specific legal reasons. If applicable, you will be notified at the time of your request.
- Object to processing of your personal data
You may object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something that makes you wish to object to processing on the basis that you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- Request restriction of processing your personal data
You may request to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- you want us to establish the accuracy of the data;
- where our use of the data is unlawful, but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- where you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data
You may exercise your right to transfer your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information that you had initially provided consent for us to use the personal data, or where we used the information to carry out a contract with you.
- Right to withdraw consent
This applies only where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
In certain circumstances, you can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also contact us at firstname.lastname@example.org if you wish to exercise your rights.
If you wish to exercise any of the rights set out above, please contact our Privacy and Data Protection Officer.
Many of the online website(s) and service(s) we provide allow you to manage your personal information. Should you need further assistance, please contact UNF’s Privacy and Data Protection Officer at email@example.com.
Consent means a person’s voluntary agreement to the collection, use or disclosure of their personal information. Consent may be express, deemed or implied.
Deemed consent exists if we give an employee prior notice of a proposed collection, use or disclosure of their personal information and an opportunity to object, and we receive no objection from them.
Express consent exists where we receive a deliberate written or verbal agreement for the collection of an individual’s own personal information.
Implied consent exists when an individual voluntarily provides their personal information for a purpose that would, at the time, be considered obvious to a reasonable person.
Lawful Basis is a valid lawful basis for processing data in accordance with the European Union’s General Data Protection Regulation (GDPR), andincludes certain specific purposes such as:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service, program, course, or product, and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Privacy and Data Protection Officer.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take preliminary pre-contractual steps at your request before entering into such a contract.
Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Personal Information means information about an identifiable individual, but it does not include their business contact information. Personal information generally does not include an employee’s work product or information an employee compiles in the course of carrying out their employment responsibilities.
Privacy means the protection of the collection, usage, storage, destruction, and dissemination of personal information on alumni, students, staff, faculty, and UNF stakeholders.
Privacy Breach means unauthorized access to or collection, use, disclosure, or disposal of personal information.
Record means information in any form and recorded or stored in any manner, including paper, electronic, digital, audio, and video, but does not include a computer program or a mechanism that produces records on any storage medium
Internal Third Parties means other companies in the GUS Group acting as joint controllers or processors, and who are based throughout the world and provide shared services such as IT, legal services, system administration services, and leadership reporting.
External Third Parties include:
- service providers acting as processors based outside Canada that provide IT, marketing, system administration, and other services.
- professional advisers acting as processors or joint data controllers, including legal counsel, bankers, auditors, and insurers based throughout the world who provide consultancy, banking, legal, insurance, and accounting services.
- governmental authorities and regulators acting as processors or joint controllers based in Canada (e.g., Canada Revenue Agency, Immigration, Refugees and Citizenship Canada, and the Ontario government) and other countries who require reporting of processing activities in certain circumstances.
- employers and potential employers who request a reference from UNF;
- other post-secondary institutions and providers of supervised training who request documentation from UNF;
- external examiners for examination, assessment, and moderation purposes;
- awarding body partners (i.e., to process the administration of student enrolment into programs);
- professional and funding bodies;
- the National Student Loans Service Centre, financial institutions and companies providing student loans; and
- marketing service providers.