Office of Alumni Affairs Policy on Security of Alumni Personal Information and Donor Records
Purpose– The University recognizes the expectation of its donor and alumni communities to protect the privacy of personal information, and has adopted this policy to protect Alumni Personal Contact and Donor Data, and to provide donor and alumni with appropriate control over the use, accuracy and availability of their personal data.
Scope– This policy applies to the National Hampton Alumni Association (NHAA), Inc., officers, various approved alumni volunteers and all University offices that seek to interact with alumni contact and giving data.
Definitions– The following definitions apply for purposes of interpreting this policy.
“Personal Donor and Alumni Data” means personally identifiable information collected from University donors and graduates of Hampton University after the individual is no longer a student. Information may include the donor or graduate’s name, address, telephone number, email address, employer, occupation, year of graduation and degree conferred by the University.
“University Donor and Alumni Records”means the database of donor and alumni records maintained in the Office of Alumni Affairs that are subject to the oversight of the Vice President for Development, the Director of Alumni Affairs and the Center for Information Technology (CIT).
University Donor and Alumni Records-The University maintains a central database of Personal Donor and Alumni Data subject to the authority of the Vice President for Development and the Director of Alumni Affairs. No other database of Personal Donor and Alumni Data shall be maintained by any other alumni entity, faculty, college, unit or department of the University with the exception of the Office of Career Services which may maintain alumni records for the purpose of facilitating the activities of that office and not for the purposes of facilitating philanthropic activities or alumni-oriented outreach, service, development and engagement programs as described in this policy.
Process for Requesting Access to Personal Donor and Alumni Data – The NHAA, Inc., faculties, colleges, units, departments and volunteer fundraisers may request access to Personal Donor and Alumni Data for use consistent with this Policy by submitting a formal request to the Director of Alumni Affairs through the information request portal located at oaa.hamptonu.edu. The request must include specific details regarding the intended use to confirm permissible disclosure as set forth in this policy. Upon approval, the requestor assumes ultimate responsibility to: (1) protect the security of the requested Personal Donor and Alumni Data, (2) limit use of the Personal Donor and Alumni Data to the objective set forth in the request for disclosure, and (3) destroy the requested Personal Donor and Alumni Data after the objective of the project is completed/achieved.
Donor and Alumni Requests Not to Disclose Personal Data– Donor and Alumni who provide personal data to the University will be provided the opportunity to request confidentiality and nondisclosure of their personal information. Personal data for any donor or alumni requesting confidentiality of their personal information shall be excluded from any information disclosed in accordance with the terms of this policy.
Restrictions on the Use and Disclosure of Personal Donor and Alumni Data -Except as specifically provided for in this policy, the University will not use or disclose Personal Donor and Alumni Data to any individual or organization other than approved University officials and alumni volunteers for the purpose of facilitating philanthropic activities or alumni-oriented outreach, service, development and engagement programs as approved by the University. Within this limited scope of disclosure, Personal Donor and Alumni Data will only be disclosed on a “need to know” basis, which will be specifically confirmed in writing and approved by the Office of Alumni Affairs prior to disclosure.
Volunteers– Personal Donor and Alumni Data may be shared with approved University volunteers engaged in annual solicitation events and/or alumni events upon confirmation by the Office of Alumni Affairs that disclosure of the data is necessary for the purposes of conducting University business and will not otherwise compromise donor and/or alumni privacy protections. Prior to any volunteer service, University volunteers must provide written confirmation of their agreement not to disclose Personal Donor or Alumni Data for any purpose other than the scope identified in their immediate campaign, event or project. ALL activities that involve the use of alumni data requires advanced approval and will have reporting requirements.
University Offices & Alumni Organizations– The University may provide academic deans and chairs, alumni clubs, affinity groups, student groups, regional representatives, class representatives and other volunteers with access to Personal Donor and Alumni Data upon confirmation that: (1) the data will only be used in a manner consistent with this policy and with any privacy protections expressed by the donor or alumni and, (2) upon written agreement by a representative of the group, that they will abide by all privacy and security requirements related to Personal Donor and Alumni Data.
Service Providers/Partners – The University may provide Personal Alumni Data to organizations that offer products and services that provide a significant and desired benefit to alumni upon confirmation that the data will be used consistently with any privacy protections expressed by the alumni and upon written agreement to abide by specific privacy and security requirements.
Legal Requirements– The University will provide Personal Alumni Data consistent with authority established in federal law including directory information unless disclosure is specifically prohibited as provided for in the Family Education Rights and Privacy Act, information required to be disclosed in connection with judicial or administrative proceedings, or if such disclosure is necessary to protect health, safety or property.
No Disclosure to Third Parties– Except as provided for in section 5.3 of this policy and in order to facilitate delivery of University mailing, the University will not disclose Personal Donor and Alumni Information to any third party for their independent use not associated with University alumni or fundraising activities unless specifically authorized by the individual donor or alumni in advance.
