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"Degrees & Programs"

University of Phoenix Policy - Applicant Privacy

Effective: March 30, 2021
Supersedes: N/A
Policy Owner: Ethics, Compliance, and Data Privacy
Version: 1

1.0 Overview

This policy describes the University’s collection and use of your Personal Information in the context of reviewing, assessing, considering, managing, storing, or processing your application or otherwise considering you for a position with the University. Please note that the University maintains separate policies regarding the confidentiality, acceptable use, and monitoring of University-provided communications systems.

2.0 Scope

All applicants for positions at the University

3.0 Personal Information

For the purposes of this policy, “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Please note that this policy does not address or apply to the University’s collection of protected health information (or “PHI”), consumer credit reports and background checks, or publicly available data lawfully made available from state or federal government records. This policy also does not apply to the Personal Information the University may collect from contractors or job applicants or from customers or end users of the University’s products and services, including employees in the context of their personal use of such products and services.

4.0 Policy

Categories of Personal Information Collected and Purposes for Use
The categories of Personal Information the University collects and the University’s use of Personal Information may vary depending upon the circumstances, such as an applicant’s role and responsibilities with the University. The information in this policy is intended to provide an overall description of the University’s collection and use of such information.

Generally, the University may collect the following categories of Personal Information about applicants:

Name, Contact Information, and Other Identifiers:

Such as real name, alias, postal address, telephone number(s), internet protocol (IP) address, email address, social security number, driver’s license number, passport number, or other similar identifiers.

Purpose(s) for Use Include:

  • Scheduling and conducting interviews.
  • Identifying candidates, including by working with external recruiters.
  • Reviewing, assessing, and verifying information provided to conduct criminal and background checks and to otherwise screen or evaluate applicants’ qualifications, suitability, and relevant characteristics.
  • Extending and negotiating the terms of offers.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Communicating with applicants regarding their applications and/or about other similar position(s) in which they may be interested.
  • Maintaining applicant personal information for future consideration.
  • Facilitating financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or complying with legal obligations, and for other internal business purposes.
  • Complying with applicable legal obligations such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Protected Classifications:

Characteristics of protected classifications under state or federal law such as race, color, gender identity, sexual orientation, age, religion, national origin, disability, and citizenship status.

Purpose(s) for Use:

  • In support of the University’s equal opportunity employment policy and diversity and inclusion efforts.
  • Administering University policies relating to disability accommodation, pursuant to applicable federal, state, and local laws.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Usage Data:

Internet or other electronic network activity information related to your use of any University device, network, or other information resource, including, but not limited to, browsing history, search history, information regarding your interactions with our websites, applications, or advertisements, physical and network access logs, and other network activity information.

Purpose(s) for Use:

  • Auditing and assessing University operations. • Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of University policies and procedures.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Monitoring for, preventing, investigating, and responding to security and/or privacy incidents.
  • Monitoring activities, access, and use to ensure the security and function of the University’s systems and assets.
  • Securing the University’s offices, premises, and physical assets, including through the use of electronic access systems and video monitoring.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Geolocation Data:

Precise geographic location information about a particular individual or device when used to access a University network, application, or other information resource.

Purpose(s) for Use:

  • Securing the University’s offices, premises, and physical assets through the use of electronic access systems and video monitoring.
  • Protecting the health and safety of the University community by minimizing the risk of exposure to communicable illnesses during a pandemic or other national or local health emergency consistent with recommendations and guidance from local, state, and federal health authorities.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Audio, Video, and Other Electronic Data:

Audio, electronic, visual, or similar information such as, CCTV footage from University facilities, photographs, and audio and/or video recordings (e.g., recorded meetings or webinars).

Purpose(s) for Use:

  • Auditing and assessing University operations.
  • Monitoring for, preventing, investigating, and responding to security and/or privacy incidents.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Monitoring for, preventing, and investigating suspected or alleged misconduct or violations of University policies and procedures.
  • In connection with the University’s marketing efforts.
  • Securing the University’s offices, premises, and physical assets through the use of electronic access systems and video monitoring.
  • Protecting the health and safety of the University community by minimizing the risk of exposure to communicable illnesses during a pandemic or other national or local health emergency consistent with recommendations and guidance from local, state, and federal health authorities.
  • Conducting audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Employment Information:

Professional or employment-related information.

Purpose(s) for Use:

  • Scheduling and conducting interviews.
  • Identifying candidates, including by working with external recruiters.
  • Reviewing, assessing, and verifying information provided to conduct criminal and background checks and to otherwise screen or evaluate applicants’ qualifications, suitability, and relevant characteristics.
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Communicating with applicants regarding their applications and about other similar position(s) in which they may be interested.
  • Maintaining applicant personal information for future consideration.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Education Information:

Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

Purpose(s) for Use:

  • Identifying candidates, including by working with external recruiters.
  • Reviewing, assessing, and verifying information provided to conduct criminal and background checks and to otherwise screen or evaluate applicants’ qualifications, suitability, and relevant characteristics.
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Communicating with applicants regarding their applications and about other similar position(s) for which they may be interested.
  • Maintaining applicant personal information for future consideration.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

Profiles and Inferences:

Inferences drawn from any of the information identified above (excluding protected classifications) to create a profile about an applicant reflecting the applicant’s preferences, characteristics, attitudes, abilities, and aptitudes.

Purpose(s) for Use:

  • Identifying candidates, including by working with external recruiters.
  • Reviewing, assessing, and verifying information provided to conduct criminal and background checks and to otherwise screen or evaluate applicants’ qualifications, suitability, and relevant characteristics.
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters.
  • Administering and monitoring compliance with the University’s policies and procedures.
  • Communicating with applicants regarding their applications and about other similar position(s) in which they may be interested.
  • Maintaining applicant personal information for future consideration.
  • Protecting and defending the University’s rights and interests and those of third parties, including managing and responding to employment-related and other legal claims or disputes and otherwise establishing, defending, or protecting the University’s rights or interests or the rights and interests of others, including in the context of anticipated or actual litigation with third parties.
  • Complying with applicable legal obligations, such as responding to court orders, subpoenas, or other requests for information from government agencies, as well as assessments, reviews, and reporting relating to such legal obligations, including under privacy laws, employment and labor laws and regulations, and other applicable laws, regulations, opinions, and guidance.

5.0 Related Policies and Procedures

Code of Ethics

Terms and Conditions

University of Phoenix Privacy Policy

6.0 Revision History

Version: 1
Date: 3/30/2021

Contacting Us:

If you have any questions or concerns regarding our use of Personal Information as described in this policy, please contact University of Phoenix Ethics, Compliance, and Data Privacy.