Updated September 1, 2025
Bard College administers the Global Higher Education Alliance for the 21st Century (GHEA21), including its educational activity, website, e-newsletter, and constituent relationship management system. This Privacy Notice applies to all who interact with GHEA21 online or otherwise provide GHEA21 with their personal information. GHEA21 is deeply committed to the protection of your personal information. This Privacy Notice relates to the collection, use, transfer, and retention of your personal data as you participate in the online GHEA21 community.
This Privacy Notice does not apply to GHEA21-sponsored programs managed by individual GHEA21 institutions. Such programs are subject to the privacy policy of the institution that manages them.
1. Who We Are and What We Do
GHEA21, led by Bard, provides opportunities for students to pursue global learning with a curriculum taught by faculty around the world and to develop knowledge and skills in civic engagement. These opportunities bring together students from a broad diversity of geographies and backgrounds and fully integrate students from marginalized communities, particularly displaced students. GHEA21 seeks to prepare students to engage thoughtfully, proactively, and collaboratively in addressing fundamental global challenges.
2. Identity and Contact Details of Data Controllers
Bard College manages the everyday operations of GHEA21 and collects, uses, and stores personal data collected during the course of relationships that GHEA21 or GHEA21-sponsored programs develop with students, faculty, staff, alumni, partners, donors, and supporters or other third parties. Most of the personal data that GHEA21 holds is obtained directly from you when you apply for, participate in, or otherwise interact with a GHEA21-sponsored program, activity, or event.
Bard College
Campus Road, P.O. Box 5000
Annandale-on-Hudson, New York 12504-5000
Email: [email protected]
3. What Is the Purpose and the Legal Basis for Processing Your Data?
Your data is used by Bard for a variety of purposes in advancing GHEA21’s mission. These purposes include, but are not limited to, facilitating contacts and partnerships across GHEA21 institutions and expanding participation in GHEA21-sponsored programs, activities, and events. In particular, your data is used to:
• Publicize GHEA21-sponsored opportunities, such as certificate programs, courses, and events
• Collect applications for certificate programs, courses, and other opportunities
• Allow review and evaluation of applications
• Maintain a learning management system for GHEA21 courses
• Keep internal records on GHEA21-sponsored programs and activities that enable us to monitor their progress and completion
• Develop and support tailored communications channels and platforms, including newsletters and social media
• Assist with data collection and analysis on participation in GHEA21-sponsored programs, activities, and events for the purposes of grant reporting and strategic planning
• Perform administrative processes, such as event registrations
What Is the Legal Basis for Processing Your Data?
As Bard processes and stores personal information related to students, faculty, staff, alumni, partners, donors, and supporters, it adheres to applicable governmental and sponsor-related data protection rules. We take our responsibilities under these rules seriously. We obtain, hold, use, transfer, and process personal information in accordance with the applicable data privacy rules.
Bard processes the information outlined in this privacy policy in pursuit of our legitimate interests in:
• Communicating with students, faculty, staff, alumni, partners, donors, and supporters
• Providing students, faculty, staff, alumni, partners, donors, and supporters with opportunities and services
• Planning, supporting, monitoring, and evaluating GHEA21-sponsored programs and activities
• Advancing the educational and charitable missions of GHEA21 institutions
• Enabling GHEA21 to pursue its strategic and operational goals
4. Who Receives Your Information?
Personal data obtained by GHEA21 may be shared with or by GHEA21 institutions for the purposes of facilitating cross-institution collaboration or conducting GHEA21-sponsored programs, activities, or events. Other than that, Bard will not disclose your data to individuals, organizations, or other entities outside GHEA21 unless it has a legal obligation to do so.
On some occasions Bard needs to engage the services of third-party data processors, agents, or contractors for purposes set out in Section 3. For example, we may engage third parties to assist us with website hosting, distribution of online communications, data analysis, or other administrative services.
Whenever your data is shared with a third party, we share only the data needed to perform the specific service and we require a contract with a confidentiality agreement to be signed before any data transfer takes place. The confidentiality agreement requires the third party to keep your information secure and not to use it for their own purposes. We will not sell or rent your information to third parties.
Third parties that act as data processors for GHEA21 include:
• Salesforce used for contact records, constituent relationship management, and processing of applications: https://www.salesforce.com/company/privacy/
• Brightspace used as the learning management system for GHEA21 courses: https://www.d2l.com/legal/privacy/
• Panopto for videos integrated into the Brightspace learning management system: https://www.panopto.com/privacy/
• Zoom for online classes: https://explore.zoom.us/en/privacy/
• Padlet for online collaboration among students in GHEA21 courses: https://legal.padlet.com/privacy
• Perusall for collaborative annotation of texts by students in GHEA21 courses: https://support.perusall.com/hc/en-us/articles/1500002946822-GDPR-compliance
• Google Workspace for processing applications and collecting information for program monitoring and evaluation: https://workspace.google.com/security/?secure-by-design_activeEl=data-centers
• Visual Compliance to screen non-US program participants for compliance with U.S. economic sanctions laws: https://www.descartes.com/privacy-center
• MailChimp for GHEA21’s newsletter: https://mailchimp.com/legal/privacy/
5. What Are Your Rights?
You have a right to:
• request a copy of the personal information we hold about you
• withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information
• ask us to correct any personal information that we hold about you which you believe to be inaccurate
• request that we delete the personal information we hold about you, in so far as we are legally required to do so
• object to the processing of your personal information where we process on the basis of the legitimate interests ground or use the personal information for statistical purposes
• ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate use
If you wish to exercise any of these rights, please contact us at [email protected]. Bard, after confirming your identity, will make every effort to fulfill your request to the extent allowed by law.
6. Security of Your Data
Bard is committed to holding your data securely and treating it with sensitivity. While we take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information, there is no perfect security in the online environment, and we cannot guarantee the security of any information you transmit to us through or in connection with the GHEA21 website or portal.
If you believe that your interaction with us is no longer secure (for example, if you consider that the security of any account you might have with us has been compromised), please notify us immediately by contacting us at [email protected].
7. Future Changes
If our Data Privacy Policy is updated in the future, we will post the updated policy on the GHEA21 website at https://ghea21.org/.