Cold Spring Harbor Laboratory Privacy Policy
For more information about specific CSHL programs, services, and projects, please refer to our separate privacy notices for our Meetings and Courses program and CSHL Press Services for customers and authors
Personal Information we collect and use
Personal Information is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect Personal Information directly from you, either through personal communications or your use of the Services, and from third parties.
Note that we may be required by law to collect certain Personal Information about you, and we may need to collect Personal Information in order to fulfill a contract with you (e.g., your name, payment information, contact information, or employment history). Failure to provide this Personal Information may prevent or delay the fulfillment of these obligations.
Personal Information we collect directly from you
The categories of Personal Information that we may collect directly from you include the following:
- personal details (e.g., name, date of birth, place of birth);
- contact details (e.g., phone number, email address, postal address);
- authenticating information (e.g., user names, passwords, security questions and answers);
- demographic details (e.g., age, gender, marital status, languages spoken, current nationality, citizenship status);
- identification numbers (e.g., Social Security number, passport or visa number);
- financial information (e.g., payment information for a donation or event registration);
- professional information (e.g., credentials, certifications, memberships or affiliations); and
- application information (e.g., cover letter, resume or curriculum vitae, writing sample, letters of recommendation, evaluations);
- academic information (e.g., transcripts, student status, test scores, grades, disciplinary records and similar behavioral information);
- employment details (e.g., work history, professional accomplishments, professional research plans);
- information about your preferences;
- communications you send us (e.g., your requests, information you provide in the form of feedback or complaints about our programs or other matters);
- content you submit (e.g., posts, comments, and other content you submit via CSHL online forums or message boards; content may include text, links, images, gifs, and videos; and your messages with other users of our forums or message boards);
- emergency contact details (e.g., names of emergency contacts and their contact information and information about your next of kin);
- how you heard about our programs; and
- photographs (e.g., for use in identification).
Personal Information we generate about you
We may generate the following Personal Information about you:
- records of our interactions with you;
- internal notes (e.g., interview or meeting notes);
- photographs; videos (e.g., taken at public events for advertising purposes);
- information about your use of our website (e.g., the pages you visit within our website, the search terms you enter on our website); and
- technical information collected from your computer or mobile device (e.g., your IP address, browser type, operating system).
Personal Information we collect from third parties
The following are examples of the categories of Personal Information we may collect from third parties who have entered into contracts with us to perform functions on our behalf, including analytical services, hosting services and recruitment services, subject to the obligations of confidentiality, use of the Personal Information solely as necessary for delivering the services and safeguarding from unauthorized disclosure:
- personal, contact, or demographic details (as described above);
- application information (e.g., information from your designated references, academic information transferred from accrediting body); and
- employment information (e.g., confirmation of prior employment).
For example, we use Eventbrite for event registrations. Eventbrite tools are used to invite past participants to upcoming events. We also use Survey Monkey to send surveys about past events to participants. The only required information collected to use these services is the participant’s name and email address. We use Embark to administer undergraduate Research Program (URP) and graduate (Ph.D.) program applications. Required information collected from applicants includes name, address, email, cell phone, school birthdate, citizenship status, and city/country of birth.
Sensitive information we collect and use
Some of the categories of information we collect or use are considered special categories of information under applicable data protection laws. In particular, we may collect or use the following types of sensitive information:
- health and medical information (e.g., disabilities for which you request an accommodation, allergies or dietary restrictions, health insurance information);
- racial or ethnic origin (e.g., information collected for diversity reporting in the context of an application for our Ph.D. program); and
- criminal charges or convictions.
How we use your Personal Information and the basis on which we use it
We use your Personal Information for the following purposes:
- Identification: We use your identification information, including your photograph, to physically identify you when you access certain CSHL facilities or check in at CSHL events. This processing is necessary to serve our legitimate interest in keeping our facilities safe and secure.
- Authentication: We use your authenticating information, including user names, passwords, security questions and answers, to verify your identity when accessing or logging into the Services and to safeguard your Personal Information. This processing is necessary to comply with our contractual obligations to you and to support our legitimate interests in securing the Services for our users.
- Reviewing applications: We process your Personal Information when you apply for our URP or Ph.D. programs, internships, fellowships, CSHL-sponsored programs or grants, and employment with CSHL. Our basis for processing is often the performance of pre-contractual relations we have with you. Any processing outside the scope of a pre-contractual obligation is necessary to serve our legitimate interests in evaluating an applicant’s personal, educational, financial, and/or professional background to make employment decisions and to compile statistical information to evaluate CSHL’s diversity or equal opportunity performance.
- Fulfillment: We process your Personal Information to provide the Services or information you have requested. For example, we may process your information to register you for our public events; facilitate your travel to or accommodations at our events; publish the content you submit to our online forums or message boards; or provide you access to and functionalities within our online databases. This is so we can provide our Services according to our contract with you.
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Charitable giving: We process your Personal Information with regard to donations. For example, Cold Spring Harbor Laboratory collects and stores personal information such as names, addresses, telephone numbers, email addresses that have been provided by donors for communication purposes, and payment information when a contribution is made. We we maintain contact information of past or potential donors to send newsletters or donation requests. The names of donors may be included in materials such as annual reports and other Cold Spring Harbor Laboratory publications, both print and electronic, unless otherwise requested by the donor, and our donors are eligible to appear on our publicly available Honor Role of Donors page.
We may rely upon your consent as required by applicable law. Where we do not rely upon consent, this processing is necessary to serve our legitimate interests in maintaining an ongoing relationship with past or potential donors for the benefit of CSHL as well as in communicating CSHL’s funding successes to the scientific research community. The Laboratory does not sell, share or trade donors’ personal information with any other entity. Additionally, the Laboratory does not send mailings to donors on behalf of other organizations.
- Improving our website and Services: We analyze information about how you use our website or related Services, including site analytics, to provide an improved experience across our website. It is in our legitimate interest to use the information provided to us for this purpose, so we can understand and improve upon any issues with our website or Services.
- Improving our institutional effectiveness: We may use your Personal Information to assess our performance as an institution, including analyzing repeat program participation, event attendance, or partnerships. For example, we may analyze connections between webpages accessed and new newsletter registrations, or between event attendance and donations, and we do this in order to promote or improve specific resources. It is in our legitimate interests to use the information provided to us for this purpose, so we can understand and improve upon any issues with institutional Services.
- Communicating with you: We may use your Personal Information when we communicate with you, for example, if we are providing information about our programs or events, including sending you CSHL newsletters and publications. We also use your Personal Information to respond to you if you contact us with questions. It is in our legitimate interests to provide you with appropriate responses and with notices about our Services.
- Emergency communications: We may use your Personal Information to respond to emergencies, for example, if we need to contact your family or other contact in the event of an incident. This processing is necessary to serve our legitimate interests in supporting the health and wellbeing of individuals while participating in CSHL-sponsored opportunities or accessing CSHL-sponsored Services.
- Personalization and marketing: We may use your Personal Information to understand your preferences in order to personalize the marketing messages and other content we provide you. We also may use your photograph in our marketing materials, for example, if you attend a public event we may use photographs from the event to market the program to prospective participants. It is in our legitimate interest to provide more relevant content and communications. Where necessary, we will obtain your consent before sending such marketing messages.
- Exercising our rights: We may use your Personal Information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to fraud, intellectual property infringement, or violations of law or contract.
- Complying with our obligations: We may process your Personal Information to comply with legal or regulatory requirements, where required by law.
In addition to the purposes listed above, we may use certain categories of sensitive information in the following ways:
- Health and medical information: To the extent we process health and medical information, we do so to comply with legal obligations (e.g., to provide disability accommodations) or when such processing is necessary to protect the vital interests of you or another person. In some contexts, this information may be processed with your consent.
- Information revealing racial or ethnic origin: To the extent we process information revealing racial or ethnic origin, such information is voluntarily disclosed during the application or registration process. In this instance, we rely on your express consent for processing.
- Criminal charges or convictions: To the extent we process information relating to criminal charges or convictions, we do so to comply with legal obligations or, where not required by law, to serve our legitimate interests in selecting a qualified and suitable workforce in order to protect the safety and security of our facilities.
We also may anonymize your Personal Information in such a way that you may not reasonably be re-identified, and we may use this anonymized information for any other purpose.
How and when we share your Personal Information
We share your Personal Information with third parties under the following circumstances:
- CSHL partners and affiliates: CSHL partners with other organizations for a number of purposes, including clinical outreach, business development, programs and grants, research initiatives, or other strategic affiliations. As a result, we may share certain Personal Information about you with employees, faculty, or agents of these entities located in the United States or elsewhere.
- Service providers: We share your Personal Information with our service providers that perform services for us for the purposes set forth above. For example, we may engage other companies to process secure payments, provide technical support or database maintenance, host or organize events, or send newsletters.
- To comply with law: We may share your Personal Information with law enforcement agencies, regulators, courts, government authorities, or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- To protect the rights, property, or safety of us, you, or others.
- In the context of a transaction: We may share your Personal Information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which CSHL is acquired by or merged with another entity, or if we sell or transfer all or a portion of our assets. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your Personal Information to use it in a manner that is consistent with this Privacy Notice.
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Services). See the section below on international data transfers for more information.
Cookies
When you use or access our website, including related Services, we automatically collect certain information about your device and use of the website. To do so, we use “cookies” and other device identifying technologies (text files) that may be saved onto your computer and that allow an analysis of your use of the website. Cookies refer to all technologies which store and access information on the device that you use to access the website, such as your computer, tablet or mobile phone.
A cookie is a small text file that can be placed on your computer’s hard drive with your permission. The cookie helps analyze web traffic and lets us know when you visit a particular site. Cookies allow web applications to respond to your individual preferences when online and tailor operations by gathering and remembering information about your preferences.
While there are different types of cookies, our website employs third-party cookies (i.e., cookies served on our behalf, for example, by data analytics companies). Cookies help us provide a better user experience on our website, by monitoring which pages are most frequently visited and by providing additional functionality.
CSHL uses social networking cookies, such as Facebook Social Graph, and analytics cookies from external services, including Google Analytics and New Relic, to attain real-time statistics on use and navigation of the website, including page views, traffic patterns, and visit statistics.
Analytics
CSHL uses analytics to help improve both the user experience and functionality. We use external services including Google Analytics and New Relic to attain real time statistics on use and navigation of the website, including page views, traffic patterns, visit counts, and visit statistics. These are not used to gather, request, record, require, collect, or track Personal Information. You can find more information on Google Analytics on Google’s website and more information on New Relic on New Relic’s website.
Social Networking
CSHL allows for social networking cookies. For example, when you access our Services and are logged into your Facebook account, we use the Facebook Social Graph cookie enable you to share pages and content or events you might attend. You can find more information on Facebook Social Graph on Facebook’s website.
CSHL does not control any third-parties use of cookies or their privacy policy compliance. These cookies also may be used by those social networks for advertising purposes. Users should use caution when accessing these external services.
You have the right to reject the use of some or all of the cookies used on the website. The best way to refuse these cookies is to turn off the social options within your CSHL account settings. Please refer to your browser’s help file for the steps required. Please note that modifying browser settings to reject some or all cookies may impact user experience with our website. Modification may also impact the delivery of personalized content.
Your rights over your Personal Information
You may have certain rights regarding the Personal Information we hold about you, subject to local law. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your Personal Information. Where we are using your Personal Information on the basis of consent, and where applicable under local law, you have the right to withdraw your consent at any time. You also may have a right to lodge a complaint with your local data protection or privacy regulator.
Please note that we may require additional information from you in order to honor your requests.
If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below.
Information security and storage
We implement physical, technical, and organizational security measures designed to safeguard the Personal Information we process through our website and CSHL’s Services. These measures are aimed at providing on-going integrity and confidentiality for your Personal Information.
We retain certain Personal Information for as long as we have a relationship with you and other information for as long as needed to preserve historical records regarding research; grant or employment applications; scholarship, grant, or other funding allocations; donation records; and other archives relevant to CSHL. When deciding how long to keep your Personal Information, we take into account our legal obligations and our legitimate interest in maintaining historical records. We may also retain records to investigate or defend against potential legal claims. We will delete your Personal Information when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the information.
International data transfer
We collect information from individuals worldwide, and we store and process that information in the United States or other countries where our service providers have facilities. The laws of the country where your information is collected or processed may not provide the same level of protection of Personal Information as the laws of your home country (for example, if you live in the European Union), and may be available to the government of those countries under a lawful order made in those countries.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your Personal Information is adequately protected. For more information on the appropriate safeguards in place, please contact us using the information set forth below.
Contact us
CSHL is the controller responsible for the Personal Information we collect and process. If you have questions or concerns regarding the way in which your Personal Information has been used, please contact us.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the appropriate data protection authority. Contact information for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Changes to our privacy notice
We may modify or update this Privacy Notice from time to time. If we make any revisions that materially alter the ways in which we process your Personal Information, we will take reasonable steps to notify you of these changes before applying them to that Personal Information. You may always visit our website to view the most up-to-date version of this Privacy Notice.
Last updated: December 7, 2020