Your Privacy Matters

Privacy Policy

Last updated: January 15, 2025

We take the protection of your personal data seriously. This policy explains how we collect, use, and safeguard your information while providing workforce development services.

Security InformationContact Privacy Team
Data CollectionData UsageData RetentionAccess ControlsYour RightsRecord DeletionIncident ResponseContact

Data We Collect

As a workforce development organization, we collect specific data to deliver our services effectively:

Student Records

  • Personal information (name, address, contact details)
  • Enrollment history and progress data
  • Attendance records
  • Transcripts and credentials

Application Data

  • Eligibility documentation
  • Funding source information (WIOA, etc.)
  • Intake forms and assessments

Apprenticeship Records

  • On-the-Job Learning (OJL) logs
  • Related Technical Instruction (RTI) records
  • Competency verification
  • Host employer information

Testing & Credentials

  • Exam scores and results
  • Certification data
  • Testing session records

Payment Information

  • Billing addresses
  • Funding source records
  • Payment history (Stripe-handled, not stored)

How We Use Your Data

We use your data exclusively for delivering workforce development services:

Service Delivery

  • • Enrollment and registration
  • • Course delivery and progress tracking
  • • Credential issuance
  • • Apprenticeship management

Compliance & Reporting

  • • DOL apprenticeship reporting
  • • WIOA outcome tracking
  • • Funding source documentation
  • • Audit compliance

Communication

  • • Program announcements
  • • Appointment scheduling
  • • Financial notifications
  • • Career services updates

Analytics & Improvement

  • • Program outcome analysis
  • • Service quality improvement
  • • Aggregate reporting (de-identified)
  • • Research with consent

We never sell your data. Your personal information is never sold, rented, or traded to third parties for marketing purposes.

Data Retention Policy

We retain your data only as long as necessary for service delivery and legal compliance:

Student Records

7 years post-completion

Maintained for federal financial aid compliance, apprenticeship documentation, and credential verification purposes.

Apprenticeship Records

DOL requirement: 5 years

OJL logs, RTI records, and competency documentation retained per Department of Labor apprenticeship regulations.

Application Data

3 years

Retained for eligibility verification, funding documentation, and audit purposes.

Testing Records

Permanent

Credentials and certification records are maintained permanently for verification and employer reference purposes.

Financial Records

7 years

Payment records maintained for tax compliance and funding source reconciliation.

Access Controls & Role Permissions

We implement strict access controls to ensure only authorized individuals can access your data:

Role-Based Access

  • A
    Administrators: Full access to organization data
  • S
    Staff: Access to assigned programs only
  • I
    Instructors: Access to enrolled students only
  • H
    Host Shops: Apprenticeship data only
  • E
    Employers: Job placement outcomes only

Audit Logging

Every access and change to your data is logged:

  • Who accessed the record
  • When access occurred
  • What data was viewed/modified
  • Before and after values
  • IP address and device info

Multi-Factor Authentication

📱

Authenticator Apps

TOTP recommended

📧

Email Verification

Backup method

🔑

Session Management

Auto-logout enabled

Your Rights

You have control over your personal data. Here's what you can request:

Access Your Data

Request a complete copy of all personal data we hold about you.

Response within 30 days

Correct Inaccuracies

Request corrections to any inaccurate personal information.

Processed within 15 days

Request Deletion

Request deletion of your personal data (subject to legal retention requirements).

Processed within 30 days

Restrict Processing

Request limited processing of your data for specific purposes.

Processed within 15 days

Record Deletion Process

When you request data deletion, we follow a strict process:

1

Verification

We verify your identity to ensure the request is legitimate.

2

Legal Review

We check for any legal hold requirements or regulatory retention mandates that may affect deletion timing.

3

Deletion Execution

Personal data is removed from our primary systems and databases.

4

Backup Purge

Data is purged from backups within the next backup cycle (within 30 days).

✓

Confirmation

You receive written confirmation when deletion is complete.

Note: Some data may be retained longer due to legal requirements (e.g., financial records for tax purposes, apprenticeship records for DOL compliance). We'll inform you of any such requirements.

Backup & Recovery Statement

Backup Schedule

  • Daily automated backups
  • 30-day retention
  • Encrypted storage
  • Geographic redundancy

Recovery Capabilities

  • Point-in-time recovery
  • Individual record restore
  • Full system restore
  • Disaster recovery site

Recovery Time Objectives

1hr

RPO

4hr

RTO

99.9%

Uptime

30day

Backup Retention

Incident Response Policy

In the event of a data breach or security incident:

1

Detection & Assessment (Minutes 0-60)

Automated systems detect anomalies. Security team assesses scope and impact.

2

Containment (Minutes 60-120)

Affected systems isolated. Threat neutralized. Additional access blocked.

3

Notification (Hours 24-72)

Affected individuals notified per GDPR/CCPA requirements. Regulatory bodies informed as required.

4

Remediation & Prevention

Root cause identified. Systems hardened. Measures implemented to prevent recurrence.

Questions About Your Data?

Our privacy team is here to help with any questions or requests.

privacy@elevateforhumanity.org
(317) 314-3757
Contact Us