2.45 Personal Information Policy

Personal Information Policy 2.45.1 Purpose of this Policy

Protecting the personal information related to our constituents (students, faculty, staff, and alumni) and their activities is necessary to ensure the safety and well-being of all members of the campus community and to reinforce Ithaca College’s official commitment to be an inclusive, respectful learning environment.

The types of data discussed in this policy require special care and attention concerning the access and use of confidential data. This policy outlines the required controls for and appropriate use of personal information data.

This policy requires that, Ithaca College administrative systems shall be configured in accordance with these personal information standards and shall contain the necessary access controls and safeguards to maintain compliance. Under this policy, people who experience or witness a practice that violates this policy have the option of contacting the Bias Impact Response Team (BIRT), a supervisor, or the Ithaca College EthicsPoint hotline to report the case. Providing various reporting mechnisms  is intended to reinforce this policy and ensure that individuals have an efficient, responsive process when practices are not in compliance with this policy.

All College faculty, staff, students, volunteers, and affiliates who are approved to access, analyze, or use personal information to conduct College business functions must understand these information standards and adhere to the associated requirements of this policy.

2.45.2 Chosen Name and Legal Name

2.45.2.1 Definition

A person’s chosen name is that which is dictated by an individual to Ithaca College (referred to in some instances as ‘chosen name’). It may differ from a person’s legal name, which is displayed on official documents such as government-issued ID cards.

2.45.2.2 Appropriate Use

A person’s chosen name shall be accepted by Ithaca College and be used in all interactions and communications with that person by College faculty, staff, students, volunteers, and affiliates, except in instances where federal or state law requires the use of legal names. Regulatory compliance and the need for legal name by outside agencies will not preclude the use of chosen name when interacting and communicating with individuals.

The chosen name shall be the primary name used in Ithaca College administrative systems and shall be entered into primary name records so that the person’s chosen name appears on all screens and reports as the default, not as an exception.  A request to modify a name shall be made in writing to the appropriate office (Registrar, Human Resources, Institutional Advancement) and each office will have the responsibility of updating the respective administrative systems in a timely fashion following receipt of the  request.  

A person’s legal name, when different from that person’s chosen name, is private information and shall not be generally accessible to College faculty, staff, students, volunteers, or affiliates. Only those who require knowledge of a person’s legal name for fiduciary, legal, or governmental purposes will have access to that person’s legal name.

2.45.3 Gender and Biological Sex

2.45.3.1 Definition

A person’s gender is that which is dictated by an individual to Ithaca College. This term, as it relates to personal information and appropriate use includes a person’s gender identity as well as a person’s sex assigned at birth (sometimes referred to as “biological sex”). While the distinction is important, the two terms are often used interchangeably. Regardless of the label that is used, the same standards apply.

2.45.3.2 Appropriate Use

A person’s gender, as dictated by that individual, shall be accepted by Ithaca College.

A person’s gender is personal information and shall not be generally accessible to College faculty, staff, students, volunteers, or affiliates. An individual may choose to share or express their gender in whatever ways they wish, but this decision shall always rest with the individual.

The provided gender may be stored in Ithaca College administrative systems where it is needed for pre-approved, specific purposes that might include, but are not limited to, financial aid, preparation of travel documents, payroll, state and federal reporting, and clinicians' prescriptions/medical orders.

Those whose job functions require access to a person's gender must meet the requirements of having understood all institutional, state, and federal policies and laws governing the privacy of this information.

Policy added:  March 1, 2019