- The information that we collect, including personally identifiable information
- Reasons we collect your personally identifiable information
- Ways in which information, including personally identifiable information, may be used and disclosed
- Security measures to prevent misuse of information entrusted to MEFA
- Modifying and deleting your information
- Methods of enforcing this policy
THE INFORMATION WE COLLECTMEFA Pathway automatically collects certain types of data from all visitors to the web portal, for example, the name of the domain and host from which you accessed the Internet, the Internet Protocol (IP) address, computers and browser software used to access the web portal. When you log on to www.mefapathway.org your browser will automatically transmit to our server the IP address of your computer and type of browser you are using. (An IP address is a number that is automatically assigned to your computer whenever you are surfing the Internet). Although your browser transmits the IP address of your computer, we do not associate this IP address with any personally identifiable information. We may collect aggregate and anonymized information about you and your use of our website whenever you visit us online. For instance, we may collect various forms of “click stream” information such as entry and exit points for our website (i.e. referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser type. In addition, when users request pages on our website, our servers may automatically log their IP addresses. This aggregate information will not personally identify you or be correlated to you individually for external purposes.
MEFA Pathway also collects personally identifiable information about you when you create your plan for college and career readiness and post-secondary success. Such information includes name, date of birth, address, e-mail address, telephone number, grade level, and such additional information as you may be required to provide by the college and financial aid applications that you choose to complete.
Our agreement with your school also permits the school to upload “student records” to MEFA Pathway. “Student records” include (as provided by the school) names, student identification numbers, date of birth, e-mail addresses, GPA, grades, courses taken, standardized test scores, demographic information, and related information on college application plans and acceptance. The schools have designated MEFA as an agent or contractor to help collect and process such information for the purpose of facilitating guidance counseling relating to post-secondary success, including the college selection process.
In sum, MEFA Pathway does not collect any personally identifiable information about users other than what users submit and their browsers transmit, and student records obtained from middle and high schools. No personal information will be released without your prior approval and only for a designated purpose, subject to the exceptions noted below under “Ways in Which Information May Be Used and Disclosed”.
MANAGEMENT AND PROTECTION OF STUDENT INFORMATIONMEFA Pathway and MEFA handles student information received from participating educational institutions and operates, on behalf of contracting schools, in compliance with federal and state school privacy laws, including The Family Educational Rights and Privacy Act of 1974 (FERPA) and the Children’s Online Privacy Protection Act (COPPA). FERPA is a federal law that protects the privacy of student educational records, and applies to all schools receiving federal funding. With certain exceptions, this law prohibits schools from releasing personally identifying information of students under the age of 18 without parental consent. By designating MEFA as a “school official” and/or a designated contractor to facilitate guidance and counseling in connection with college selection, institutions are permitted to share data with MEFA without express, parental consent under the exception provided by 34 CFR § 99.31 (a)(1).
More information about classifications as a “school official” and contracted companies with “legitimate educational interest” can be found at http://www.ed.gov/policy/gen/guid/fpco/index.html and http://www.ed.gov/policy/gen/guid/fpco/ferpa/lea‐officials.html.
REASONS WE COLLECT YOUR PERSONALLY IDENTIFYING INFORMATIONMEFA, through MEFA Pathway, collects personal information from you for three reasons. The first reason is to enable us to respond to your questions or contact you when necessary in connection with the functioning of the web portal. The second reason is to perform a task, such as helping guide you through educational planning as well as planning for your career and college aspirations . Finally, as described earlier, we collect additional information about users to help us better facilitate the use of our service.
WAYS IN WHICH YOUR INFORMATION MAY BE USED AND DISCLOSEDExcept as set forth below, the personally identifiable data you submit to the web portal (or that MEFA Pathway obtains from your school) is not made available or distributed to third parties, except with your express consent (or that of your parents) and at your direction. In particular, unless otherwise specified below, neither MEFA nor MEFA Pathway will give, sell or provide access to your personal information to any company, individual, or organization for its use in marketing or commercial solicitation or for any other purpose, except as is necessary for the operation of this site. The remarketing and advertising features within Google Analytics are disabled in MEFA Pathway, so that your actions are not tracked for the purposes of marketing products or services.
WAYS IN WHICH INFORMATION MAY BE USED
- Forms and Surveys. The web portal will use your personally identifiable information to automatically fill out the forms and surveys noted below upon your instructions to do so.
- Applications for college admission
- Financial aid applications
- Course planners, which can assist you in selecting courses and otherwise planning to meet graduation requirements and your post-secondary goals.
- Requests for information or material from colleges or other institutions you specify
- Completion of a resume
- Completion of an Individualized Learning Plan
Unless expressly instructed or authorized by you (or your parents), these forms and surveys are not disclosed to third parties.
- Internal Analysis. We may use your information, including your personally identifiable information, to help diagnose problems with MEFA’s servers and to administer the web portal. We may aggregate your information with the information of other users for our own internal statistical, design, or operational purposes such as to estimate our audience size; measure aggregate traffic patterns; and understand demographic, customer interest, and other trends among our guests and customers.
- Use and Disclosure of Aggregated Data. As described earlier, we may collect aggregate and anonymized information about you and your use of MEFA Pathway whenever you visit us online. This aggregate information will not personally identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided that such information does not personally identify you. When we share such information with other companies, or with contracting schools, it is not traceable to any particular user, and will not be used to contact you. If we do correlate any aggregate information to you, such information will be treated like any other personally identifying information under this policy.
- Compliance with the Law and Other Special Circumstances. When required by law to comply with any valid legal process such as a search warrant, subpoena, statute, regulation or court order, MEFA will supply such information contained in your MEFA Pathway account that MEFA may be legally required to supply. In addition, MEFA may release specific information relevant to special cases, such as a physical threat to you or others or an attempted breach of security on the web portal.
- Permission‐Based Support Services. From time to time, users will be offered resources and support services related to their use of the site. For example, users who select colleges for their college list often elect to receive additional information from and/or have online interaction with those colleges. Whether or not information is received by users from interested parties is permission‐based. Users will affirmatively choose to receive such information and have such interactions at their sole discretion. Users may receive reminders of these opportunities or invitations to participate in certain activities (such as an online chat) in order to maximize their college search and application process but will make individual decisions regarding participation.
- Legal Rights to Protect and Defend. We may disclose personal information if required to do so by law or if we in good faith believe that such action is necessary to protect and/or defend our rights or property.
SECURITY MEASURES TO PREVENT MISUSE OF INFORMATION ENTRUSTED TO USWe use technical, administrative, and physical safeguards to maintain the security of your information. We enable the data you input to be encrypted when in transit between your browser and the web portal server and when in transit between the web portal server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your private data during transmission over the Internet. We use industry‐standard encryption supported by all popular web browsers.
Data residing on the web portal server is password protected, and access is provided only to those employees of MEFA or our service provider who require such access to administer and maintain our system or to provide requested customer support to users of the web portal. Each MEFA employee who has access to the data residing on the web portal server has agreed in writing to respect the privacy of all such personal data.
MEFA has contractual provisions in place with our service provider to protect the privacy and security of your personal data.
MEFA shall not be responsible for any damages incurred as a result of unauthorized use of your password and hereby expressly disclaims all responsibility for any such damages.
MODIFYING, CORRECTING, OR DELETING YOUR INFORMATIONYou may update, otherwise modify or delete from the data stored on the web portal any personal information you previously provided. To modify personal information, (i) log on to www.mefapathway.org, (ii) access either your user profile or an application containing the information you want to change, and (iii) modify that information using standard word‐processing techniques. To delete personal information, (i) log on to www.mefapathway.org, (ii) access your user profile, and (iii) delete the information you want to remove from your web portal account using standard word processing techniques. Please recognize that if you delete information, it will no longer be available through your account.
If you are unable to change your profile using the standard web portal service features, or wish to delete or modify your student records provided to MEFA by your school, or delete your account from the MEFA system, you may:
- Send e‐mail to email@example.com, or
- Call 800-449-MEFA (6332) to request a correction or deletion.
Also, please note that in the event your school discontinues its relationship with MEFA Pathway, they have
the option to notify MEFA, in writing, and request that MEFA destroy and remove all of the personally
identifiable data provided to MEFA Pathway by the school, and MEFA will do so within 15 days.
ENFORCEMENTMEFA is committed to ensuring the integrity and security of user information. MEFA intends to pursue all legal remedies available to it in the event that its security measures and/or this Policy is breached, including but not limited to pursuit of all criminal and civil law enforcement proceedings available as of the occurrence of any breach. Should you believe that your data has been released or used in a way that is contrary to your rights or this policy you should contact firstname.lastname@example.org or call 800-449 MEFA (6332).