POLICIES ON DATABASES WITH PERSONAL INFORMATION

those images for such purposes. All faculty and staff, when they begin their employment with the school sign a model release consenting to the use of this type of content.

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Contracts between employees and students for paid work outside of the formal activities of the school represent a conflict of interest, and as such are prohibited. No employee shall solicit the work of any currently enrolled student at PCA for their own financial or professional gain, even if the student stands to profit from the agreement. No faculty member shall be allowed to take royalties or other financial gains from the work of any student produced in their class.

Occasionally, students submit work or designs to their instructors as a part of a design project in which PCA participates with outside companies. Unless specified or agreed, all of these works or designs automatically become property of PCA together with their associated patent, copyright or other proprietary rights.

P O L I C I E S O N D A T A B A S ES W I T H P E R S O N A L I N F OR M A T I O N

PCA maintains several electronic databases, including Jenzabar and Constant Contact, which contain personal information on students, student applicants, employees, job applicants and faculty. All personal information collected should be handled with the utmost care and sensitivity. The use and maintenance of these databases is overseen in France by the Commission on Information Technology and Liberties or Commision Nationale de l’Informatique et des Libertés (CNIL). Please refer to www.cnil.fr for further details. To comply with French law, there must be a specific and legitimate need for all personal information requested and maintained electronically, and such information cannot be used for any other purpose than that for which it was legitimately requested. Additionally, only authorized personnel can access the personal data contained in a file. For example, at PCA, only Student Advising and the Office of the Registrar has access to students’ self-disclosed learning disabilities. The misuse of personal information (i.e., using it for purposes other than that for which it was collected) as well as disclosure of such information, whether intentionally or negligently, is punishable under French law by imprisonment and significant monetary fines. PCA may sanction an employee as it sees fits for such violations.

Absent an explicit need, certain information should not be requested or stored, including information that directly or indirectly reveals racial or ethnic origins, political opinions, philosophical beliefs, religious and/or union affiliations and beliefs, health and/or sexual orientation. When in doubt about whether such information is necessary, it is better not to request it. Any questions about whether such information can be requested should be directed to the HR Office.

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Under French law, files containing personal information may be made available to the person whose information is collected. In addition to the information that should not be requested from students, student applicants, employees, job applicants and faculty, certain things should never be reduced to writing. This includes, but is not limited to, comments on the physical appearance and mental status of students, staff, faculty and/or applicants (both student and job candidates). Employees should also refrain from making notes relating to the protected statuses mentioned above (i.e., race or ethnic origin, sexual orientation, etc.). When interviewing student and job candidates as well as when reviewing student and staff performance, it is important to include both negative and positive impressions. When recording negative impressions, pejorative adjectives should be avoided. Instead, negative impressions should be recorded in a manner that would not embarrass the institution, student, applicant or employee if shared.

All faculty, staff and student information collected by the school is maintained in the PCA databases and used

in furtherance of its business purposes. It is for internal use only. Employees’ and consultants’ personal information will not be released to any third parties without their explicit permission. Anonymous statistical

information gathered from the institution’s database may be used to complete reports for affiliated academic organizations.

In accordance with the French Computer and Freedoms law of January 6, 1978, employees have the right to access and rectify any information concerning them. If an employee wishes to exercise this right and be notified of any such information, they should contact the HR Manager. Please refer to www.cnil.fr for further details.

The Family Educational Rights and Privacy Act of 1974 as amended in 1995 and 1996, with which PCA complies, was enacted to protect the privacy of educational records, to establish the right of students to inspect and review their educational records, and to provide guidelines for the correction of inaccurate or misleading statements.

PCA has established the following student information as public or directory information, which may be disclosed by the school at its discretion: student name; major field of study; dates of attendance; full or parttime enrollment status; degrees and awards received; the most recent previous educational agency or institution attended, addresses, phone numbers, photographs, email addresses, and date and place of birth.

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