#### EMPIRE STATE COLLEGE PRIVACY POLICY

#### Introduction

Empire State College is committed to protecting your privacy while making it easier and more efficient to interact with our college. You can navigate through much of the college's website without giving us any information about yourself. Sometimes we do need information to provide services that you request, and this commitment of privacy explains our online information practices. 

We do not collect any personal information about you unless you provide that information voluntarily by sending an e-mail, completing an online form, or completing the online application.

This policy is consistent with the provisions of the Internet Security and Privacy Act, the Freedom of Information Law, and the Personal Privacy Protection Law.   


#### Information Collected Automatically When You Visit this Website 

  
When visiting this website, we automatically collect and store the following information about your visit:

  * User client hostname. The hostname or Internet Protocol address of the user requesting access to a college website. 
  * HTTP header, "user agent." The user agent information includes the type of browser, its version, and the operating system on which the browser is running. 
  * HTTP header, "referrer." The referrer specifies the web page from which the user accessed the current web page. 
  * System date. The date and time of the user's request. 
  * Full request. The exact request the user made. 
  * Status. The status code the server returned to the user. 
  * Content length. The content length, in bytes, of the document sent to the user. 
  * Method. The request method used. 
  * Universal Resource Identifier (URI). The location of a resource on the server. 
  * Query string of the URI. Anything after the question mark in a URI. 
  * Protocol. The transport protocol and the version used. 
  * Processing time. The time, in milliseconds, it took for the server to process the request 
  * Host header. The hostname of the requested file, e.g., www.esc.edu. 
  * Cookies. The name of any cookie used.

  
None of the above-mentioned information is deemed to constitute personal information by the Internet Security and Privacy Act.

In addition to the above-mentioned information, when you access a password-protected part of the website, your username is collected automatically. 

All information that is collected automatically is used to improve our web content, to investigate possible problems and in general to help us understand how you are interacting with our Web site. This information is collected for statistical analysis and to determine what information is of most and least interest to our users. The information is not collected for commercial purposes and the college does not sell or otherwise distribute the information collected from the website for commercial purposes.  


#### Information Collected When You E-mail our Webmaster or Complete a Transaction 

  
If you send an e-mail to our webmaster, your email address and the contents of your message are collected. These are used to respond to you, to address issues you identify, to improve this Web site, or to forward your message to someone who can help you. We do not disclose your e-mail address to any person or organization outside the college.

If you voluntarily complete an online form, the personal information you provide will be retained in a way that is appropriate to complete your transaction. We do not knowingly collect personal information from children under the age of 13 or create profiles of children under the age of 13. Caution: if you submit personal information in an e-mail, the information will be treated as though it was submitted by an adult, and may, unless exempted from access by federal or State law, be subject to public access.   


#### Cookies

  
Cookies are simple text files stored on your web browser to provide a means of distinguishing among users of this website. The use of cookies is a standard practice among Internet websites. To better serve you, we may use persistent and/or session cookies to enhance or customize your visit to this website. Persistent and session cookies that are created automatically on the device you use to access this website do not contain personal information and do not compromise your privacy or security. We may use the cookie feature to store a randomly generated identifying tag on the device you use to access this website. A session cookie is normally erased during operation of your browser or when your browser is closed. Some web browsers retain session cookies by default; you can adjust your browser settings to ensure that session cookies are deleted. A persistent cookie remains on your computer until you decide to delete it. We use persistent cookies on some parts of our web site to gather non-personal statistical data when you visit our web site.

The software and hardware you use to access the website allows you to refuse new cookies or delete existing cookies. Refusing or deleting these cookies may limit your ability to take advantage of some features of this website.  


#### Information and Choice

  
As noted above, Empire State College does not collect any personal information about you unless you provide that information voluntarily by sending an e-mail, responding to a survey, or completing an on-line form. You may choose not to send us an e-mail, respond to a survey, or complete an on-line form. While your choice not to participate in these activities may limit your ability to receive specific services or products through this website, it will not normally have an impact on your ability to take advantage of other features of the website, including browsing or downloading information.   


#### Disclosure of Information Collected Through This Website 

  
The collection of information through this website and the disclosure of that information are subject to the provisions of the Internet Security and Privacy Act. Empire State College will only collect personal information through this website or disclose personal information collected through this website if the user has consented to the collection or disclosure of such personal information. The voluntary disclosure of personal information to Empire State College by the user, whether solicited or unsolicited, constitutes consent to the collection and disclosure of the information by Empire State College for the purposes for which the user disclosed the information to Empire State College, as was reasonably ascertainable from the nature and terms of the disclosure. 

However, Empire State College may collect or disclose personal information without consent if the collection or disclosure is: (1) necessary to perform the statutory duties of Empire State College, or necessary for Empire State College to operate a program authorized by law, or authorized by state or federal statute or regulation; (2) made pursuant to a court order or by law; (3) for the purpose of validating the identity of the user; or (4) of information to be used solely for statistical purposes that is in a form that cannot be used to identify any particular person. 

Further, the disclosure of information, including personal information, collected through this website is subject to the provisions of the Freedom of Information Law and the Personal Privacy Protection Law. 

Empire State College may disclose personal information to federal or state law enforcement authorities to enforce its rights against unauthorized access or attempted unauthorized access to Empire State College’s information technology assets.   


#### Retention of Information Collected Through this Website

  
The information collected through this website is retained by Empire State College in accordance with the records retention and disposition requirements of the New York State Arts & Cultural Affairs Law. Information on the requirements of the Arts & Cultural Affairs Law may be found at http://www.archives.nysed.gov/a/records/mr_laws_state.shtml. In general, the Internet services logs of Empire State College, comprising electronic files or automated logs created to monitor access and use of college services provided through this website, are retained in accordance with the records retention and disposition schedule established for the records of the Office of Educational Technology. Information, including personal information, that you submit in an e-mail or when you complete a survey, registration form, or order form is retained in accordance with the records retention and disposition schedule established for the records of the program unit to which you submitted the information. Information concerning these records retention and disposition schedules may be obtained through the Internet privacy policy contact listed in this policy.

#### Access to and Correction of Personal Information Collected Through this Website

  
Any user may submit a request to the Empire State College privacy compliance officer to determine whether personal information pertaining to that user has been collected through this website. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier generally known only to the user, or similar appropriate identification. The address of the privacy compliance officer is:

Privacy Compliance Officer  
Empire State College  
3 Union Avenue  
Saratoga Springs, NY 12866

The privacy compliance officer shall, within five (5) business days of the receipt of a proper request, provide access to the personal information; deny access in writing, explaining the reasons therefore; or acknowledge the receipt of the request in writing, stating the approximate date when the request will be granted or denied, which date shall not be more than thirty (30) days from the date of the acknowledgment. 

In the event that Empire State College has collected personal information pertaining to a user through the college website and that information is to be provided to the user pursuant to the user’s request, the privacy compliance officer shall inform the user of his or her right to request that the personal information be amended or corrected under the procedures set forth in section 95 of the Public Officers Law.   


#### Confidentiality and Integrity of Personal Information Collected Through this Website

  
Empire State College is strongly committed to protecting personal information collected through this website against unauthorized access, use or disclosure. Consequently, Empire State College limits employee access to personal information collected through this website to only those employees who need access to the information in the performance of their official duties. Employees who have access to this information follow appropriate procedures in connection with any disclosures of personal information.

In addition, Empire State College has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, monitoring, auditing, and encryption. These security procedures have been integrated into the design, implementation, and day-to-day operations of this website as part of our continuing commitment to the security of electronic content as well as the electronic transmission of information.

For website security purposes and to maintain the availability of the website for all users, Empire State College employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage this website.  


#### Disclaimer

  
The information provided in this privacy policy should not be construed as giving business, legal, or other advice, or warranting as fail proof, the security of information provided through this website.  


#### Contact Information

  
For questions regarding this Internet privacy policy, please contact:   
(via e-mail) 

privacypolicy@esc.edu

(via regular mail) 

Privacy Compliance Officer   
Empire State College   
3 Union Avenue   
Saratoga Springs, NY 12866   


#### Definitions

  
The following definitions apply to, and appear in italics, in this policy:

Personal information: For purposes of this policy, "personal information" means any information concerning a natural person which, because of name, number, symbol, mark, or other identifier, can be used to identify that natural person.

User: shall have the meaning set forth in subdivision 8 of section 202 of the State Technology Law.  


#### Required Submissions & Notices

  
Not applicable.   


#### Compliance

  
Not applicable.

01/22/08  

