Touro University Nevada is responsible for all personal information under its control and remains responsible when personal information is processed by third parties on their behalf.

• The Chief Information Security Officer (CISO) for Touro College is Patricia Ciuffo. This is communicated both internally and externally for public knowledge. The CISO is responsible for understanding the broad impact of privacy, for the implementation of policies and procedures, and handling any complaints.
• Touro University Nevada is responsible for personal information in its possession or custody, including information that has been received by a third party and requiring their adherence to privacy legislation.

Touro University Nevada will identify the purposes for which personal information is collected; at or before the time the information is collected.

• The primary purposes for the collection of personal information is to deliver services and to keep individuals informed and up-to-date on the activities of Touro University Nevada, including programs, services, special events, projects, employment opportunities, solicitations and more through periodic contacts.
• When personal information that has been collected is to be used for a purpose not initially identified, the new purpose shall be identified prior to use and the individual provided notice of the new usage.
  When individuals supply personal information in connection with a job application or educational inquiry, whether advertised on this website or otherwise, such as a resume or curriculum vitae, we may use this information throughout Touro University Nevada and its related entities for the purpose of employment consideration or educational inquiry. Except where an individual tells us not to, we may keep the information for future employment or educational consideration.
• If an individual requests something from our website, for example, course materials, educational information, a callback, or specific marketing materials, we will use the information provided to fulfill the request. To help us do this, we may share information, with others, for instance, other parts of Touro University Nevada or Touro College, Touro Educational Partners, financial institutions, shipping companies, postal or government authorities (for example, immigration or customs authorities) involved in fulfillment. In connection with a transaction we may also contact the individual as part of our customer satisfaction surveys or for market research purposes.
• The information provided to Touro University Nevada on our websites may also be used by Touro University Nevada and selected third parties for marketing purposes.  However, on marketing emails, we will offer users the opportunity to choose whether or not to opt-out of having information used in this way.
• If an individual represents a Touro Educational Partner, they may visit a Touro University Nevada website intended specifically for Touro Educational Partners. We may use information provided on that site to administer and develop our relationship, the partner organization the individual represents, and other partners generally. For instance, this may involve using information to send details of Touro University Nevada partner or alliance programs. It may also include sharing certain information with other Business Partners (subject to any confidentiality obligations that may exist), or Touro University Nevada students or prospects. In connection with a particular transaction or program, we may also contact Educational Partners as part of student satisfaction surveys or for market research purposes.
• If an individual represents a Touro University Nevada supplier, vendor or consultant, they may visit a Touro University Nevada website intended specifically for this use. We may use the information provided on that site in connection with entering into or performing a transaction with the supplier, vendor or consultant. For example, this may include sharing information with other parts of Touro University Nevada or Touro College, Touro University Nevada’s partners, shipping companies, financial institutions, postal or government authorities involved in fulfillment. It may also be used to administer and develop our relationship with the entity or consultants the individual represents and/or other Touro University Nevada vendors and suppliers generally.

Knowledge and consent by the individual for the collection, use and disclosure of personal information will be obtained by Touro University Nevada. Indeed, submission of personal information over a secure and encrypted internet connection is tacit consent to collection, use and disclosure of personal information obtained by Touro University Nevada.

• This privacy policy is therefore provided in a prominent manner and specifies the nature of the information uses. Users have the ability to notify Touro University Nevada to opt-out at any time (subject to later agreed to legal or contractual restrictions and reasonable notice).
• As can be readily discerned, this consent is stated in such a manner that individuals supplying personal information can reasonably understand how the information will be used or disclosed.

The collection of personal information shall be limited to that which is necessary for the purposes identified by Touro University Nevada. All personal information shall be collected by fair and lawful means.

• Touro University Nevada does not collect personal information indiscriminately. Both the amount and type of information collected is limited to that which is necessary to fulfill the purposes identified.
• Any new purposes for the use of an individual’s personal information will require the individual’s consent.
• We will only collect personal information by fair and lawful means and we will never collect information by misleading or deceiving individuals about the purpose for which information is being collected. Thus we require and obtain consent with respect to collection, use or disclosure and never will we obtain such consent through deception.

• Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
• Personal information will be stored in confidence and accessed only by authorized Touro University Nevada employees, faculty and agents or consultants retained by Touro University Nevada.
• Personal information will be retained only as long as necessary for the fulfillment of those purposes. Personal information that is no longer required will be destroyed, erased or made anonymous in accordance with current Touro University Nevada Document/Records Retention Policy.

By supplying personal information users affirm that such information is accurate, complete and up-to-date as is necessary for the purposes for which it is used by Touro University Nevada, taking into account its use and the interests of the individuals.

• Personal information shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information be used to make a decision about the individual.
• Touro University Nevada will update an individual’s personal information only when necessary to fulfill the specific purposes for which it was collected.

Touro University Nevada will take steps to protect personal information from theft and loss, as well as unauthorized access, disclosure, copying, use or modification. The methods of protection include:

• Physical measures (locked filing cabinets, restricted access to files and offices);
• Technological measures (passwords, encryptions, firewalls, and audits);
• Organizational measures (clearances, “need-to-know” access, etc.); and
• Staff training that includes the sharing of all Touro University Nevada privacy policies and procedures.

Touro University Nevada will make readily available to individuals specific information about Touro University Nevada’s policies and practices relating to the management of personal information. Touro University Nevada will make these policies and practices understandable and easily available through a variety of forms, including this very positing. Information about these policies and practices may be made available in person, in writing, by telephone, in publications and on the Touro University Nevada website. The information made available will include:

• The name or title and business address of the person who is accountable for Touro University Nevada’s privacy policies and practices and to whom complaints or inquiries can be forwarded;
• The means of gaining access to personal information held by Touro University Nevada;
• A description of the type of personal information held by Touro University Nevada, including a general description of its use and disclosure.

Upon request by an individual, Touro University Nevada shall inform the individual of the existence, use and/or disclosure of his or her personal information and be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

• Individuals have the right to be given access to their personal information (except where it contains references to other individuals or if it cannot be disclosed for legal, security or commercial proprietary reasons). Touro University Nevada will advise the individual of the reason for denying the access request.
• Touro University Nevada will respond to an individual’s request within a reasonable time and at minimal or no cost to the individual related to retrieval, photocopying and delivery.
• In providing an account of third parties to which it has disclosed personal information about an individual, Touro University Nevada will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, Touro College will provide a list of organizations to which it may have disclosed information about the individual.

An individual can challenge Touro University Nevada’s compliance with the above principles through Touro College Chief Information Security Officer.

• Touro University Nevada has put these procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures are accessible and simple to use. To initiate a complaint all an individual must do is notify Touro College Chief Information Security Officer and provide information and assistance to allow Touro College to properly investigate the claim.
• Touro College shall investigate all complaints. If a complaint is found to be justified, Touro University Nevada will take appropriate measures, including, if necessary, amending its policies and procedures.