General Data Protection Regulation (GDPR) Data Protection Policy
Published: www.tcmi.edu, students.tcmi.edu, learn.tcmi.edu, library.tcmi.edu, and www.tcmi.org (Link Name: Data Protection)
Referenced in: Catalog, Student Handbook, Faculty & Adjunct Faculty Handbook, Staff Handbook, Short-term Worker Handbook, and Long-term Worker Handbook.
Last Updated: January 2025
Part 1: Employee, Faculty, Adjunct Faculty, and Employment Applicants
How We Use Your Personal Data
What is “Personal Data”?
“Personal Data” means any information relating to an identified or identifiable natural person.
Who will process my Personal Data?
The information published here applies to the use, sharing, and disclosure of your Personal Data by TCM and its service providers and vendors.
What Personal Data will be processed?
TCM will keep a record of the details you provided on your application form, any supporting documents requested as part of your employment decision, additional details provided by recommendations, and all information provided to TCM related to your employment and payroll matters. This Personal Data will include, but not be limited to, the following items:
personal contact details such as name, addresses, telephone numbers, and personal email addresses;
date of birth;
sex;
marital status and dependents;
emergency contact information;
Government identifier;
bank account details, payroll records, and tax status information;
salary, annual leave, pension, and benefits information;
start date;
location of employment or workplace;
recruitment information (including copies references and other information included in a resume or cover letter or as part of the application process);
employment records (including job titles, work history, working hours, training records, and professional memberships);
education records as recorded on transcripts provided to TCM;
compensation history;
performance information;
disciplinary information;
information about your use of our information and communications systems; and
photographs.
Your Personal Data is created, stored, and transmitted securely in various paper and electronic formats. Access to your Personal Data is limited to TCM staff who have a legitimate interest in it under the principle of least privilege to carry out their duties, and our use of your Personal Data will not be excessive.
What is the purpose of Personal Data processing?
TCM will process your Personal Data for various purposes, including but not limited to the following:
To prevent or detect fraud;
To evaluate your candidacy for employment and/or addition to TCM’s faculty/adjunct faculty;
To perform tasks as your employer or contracting company or for other contracts we have entered into with you or for your benefit;
To exercise our legal rights or need to comply with a legal obligation;
To protect your interests (or someone else’s interests);
When it is needed in the public interest or for official purposes;
To make a decision about your recruitment or position;
To determine the terms on which you work for us;
To verify that you are legally entitled to work;
To pay you and, if you are an employee, to deduct tax and other contributions;
To provide health or other benefits;
To administer a contract that we have entered into with you;
For business management and planning, including accounting and auditing;
For conducting performance reviews, managing performance, and determining performance requirements;
To help TCM make reasonable adjustments for any disability requested by you;
To allow us to consider any future accommodation requirements;
To provide information required by accreditation officials and/or legislation; and
For research and statistical purposes, but no information which could identify you will be published.
TCM considers the processing of your Personal Data for these purposes to be either necessary for the performance of our obligations with you, necessary for compliance with a legal obligation, or necessary for the pursuit of the legitimate interests of TCM or an external accreditation organization. If we require your consent for any specific use of your Personal Data, we will collect it at the appropriate time, and you can withdraw this consent at any time.
We generally will only use your Personal Data for the purposes for which we collected it. We may also use your Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law. We will notify you if we need to use your Personal Data for a different purpose.
Where will my Personal Data be transferred?
Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. If you are located in the EU, we have implemented procedures in accordance with the GDPR to secure the transfer of your Personal Data to the United States and other jurisdictions.
With whom will my Personal Data be shared?
We may share your data with third parties, including our service providers, for the purposes described in this Policy.
We will share your Personal Data with service providers where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so. The following activities are examples of activities carried out by third-party service providers: compensation benefits administration, payroll, benefits provision and administration, and as necessary, IT services.
. We take reasonable measures to ensure service providers use Personal Data in accordance with applicable laws. Third parties may have their own data security and privacy policies. For more information, contact us using the form provided on our website.
We may share your Personal Data with accreditation organizations to assist with research.
We may also need to share your Personal Data with a regulator, local authorities, or to otherwise exercise our legal rights or comply with the law.
How is my Personal Data used if I become a staff member?
TCM will use your Personal Data for the purposes described and in support of your annual letter of appointment decision. This letter sets forth the terms of your employment and is renewed on an annual basis. By signing your annual letter of appointment, you agree to TCM’s use of your Personal Data as described in this privacy policy.
What rights do I have associated with my Personal Data?
You have the right to access the Personal Data held about you by TCM through your immediate supervisor.
You also have the right to ask TCM to correct any inaccurate Personal Data held, to delete Personal Data, or otherwise restrict processing or to receive a copy of the Personal Data you provided TCM.
How long is my Personal Data kept?
TCM stores your Personal Data for as long as necessary to complete the employment process. If you become a staff member, your information will be kept for the duration of your employment. If you apply but do not become a staff member, your information will usually be kept for at least one year after completing the application process.
Who may I contact?
If you have any questions about how your Personal Data is used or wish to exercise any of your rights, please consult your immediate supervisor. Applicants who do not become staff members may consult the Vice President of Ministry Services.
How do I complain?
If you are not happy with the way your information is being handled, or with the response received from TCM, you have the right to lodge a complaint with your supervisory Vice President, or with the Vice President of Ministry Services.
Are changes made to this Policy?
This GDPR Policy is reviewed every two years, or more frequently, as needed. Any changes to the Policy will be published on the TCM websites and referenced in the TCM Staff Handbook.
Part 2: Student Applicants
How We Use Your Personal Data
1. What is “Personal Data”?
“Personal Data” means any information relating to an identified or identifiable natural person.
2. Who will process my Personal Data?
The information provided here applies to the use, sharing and disclosure of your personal information by TCM and its service providers and vendors as part of the admissions process.
3. What Personal Data will be processed?
For applicants to TCM certificate and/or degree program and for non-admitted registrants to TCM courses (e.g., audit): TCM will use the details you provide on your application/registration, supporting documents requested in the application/registration process, plus additional details provided by anyone providing personal references. This Personal Data will include, but not be limited to, the following:
Full name;
Date of birth;
Sex;
Citizenship and residency status;
Passport or equivalent national ID;
Contact, email, address, phone number;
Religious affiliation;
Photographs;
Previous school(s) attended and graduation dates
GPA, class rank, and coursework details;
Medical history (if relevant for certain accommodations)
Your Personal Data is created, stored, and transmitted securely in various paper and electronic formats. Access to your Personal Data is limited to TCM staff who have a legitimate interest in it under the principle of least privilege for the purpose of carrying out their duties, and our use of your Personal Data will not be excessive.
4. What is the purpose of Personal Data processing?
TCM will process the Personal Data provided on your application/registration and the other information referred to above to identify you, process your application/registration, verify the information provided, decide whether to offer you a place for the program/course you have applied for, and communicate that outcome.
We may also use or disclose the information provided as described below:
To make admissions decisions;
To determine eligibility for scholarships;
To verify identity;
To validate letters of recommendations;
To prevent or detect fraud;
To help TCM make reasonable adjustments for any disability requested by you;
To provide information required by accreditation officials and/or legislation;
To allow us to consider any future accommodation requirements;
To provide information required by accreditation officials and/or legislation; and
For research and statistical purposes, but no information which could identify you will be published
TCM considers the processing of your Personal Data for the above purposes to be either necessary for your admission/registration, or necessary for compliance with a legal obligation. TCM requires you to provide the information requested during the application/registration process to assess your application properly. Admission decisions are not automated.
We generally will only use your Personal Data for the purposes for which we collected it. We may also use your Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law. We will notify you if we need to use your Personal Data for a different purpose.
5. Where will my Personal Data be transferred?
Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. If you are located in the EU, we have implemented procedures in accordance with the GDPR to secure the transfer of your Personal Data to the United States and other jurisdictions.
6. With whom will my Personal Data be shared?
We may share your data with third parties, including our service providers, for the purposes described in this Policy.
We will share your Personal Data with service providers where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so.
We take reasonable measures to ensure service providers use Personal Data in accordance with applicable laws. Third parties may have their own data security and privacy policies. For more information, contact us using the form provided on our website.
We may share your Personal Data with accreditation organizations to assist with research.
We may also need to share your Personal Data with our Regional Representatives, your funders and/or potential funders, with a regulator, local authorities, or to otherwise exercise our legal rights or comply with the law.
7. How is my Personal Data used if I am accepted?
If you are accepted, TCM will use your Personal Data for the purposes described above and in compliance with the GDPR (EU) and Family Educational Rights and Privacy Act (US).
If you are accepted, TCM will also return data to accreditation agencies as required.
8. What rights do I have associated with my Personal Data?
You have the right to access the Personal Data held about you by TCM through the Registrar’s office.
You also have the right to ask TCM to correct any inaccurate Personal Data held, to delete Personal Data, to restrict processing otherwise, or to receive a copy of the Personal Data you provided TCM.
9. How long is my Personal Data kept?
TCM stores your Personal Data for as long as necessary to complete the application/registration process. If you are admitted as a student, your information will be kept as part of your student record for the duration of your studies. If you are not admitted as a student, your information will usually be kept for at least one year after completing the application process.
10. Who may I contact?
If you have any questions about how your Personal Data is used, or wish to exercise any of your rights, please consult registrar@tcmi.edu.
11. How do I complain?
If you are not happy with the way your information is being handled or with the response received from TCM, you have the right to lodge a complaint. You may do so by submitting your complaint using the Grievance link posted on TCM’s website.
12. Are changes made to this Policy?
This GDPR Policy is reviewed every two years or more frequently, as needed. Any changes to the Policy will be published on the TCM websites and referenced in the Catalog and the Student Handbook.
Part 3: Students
How We Use Your Personal Data
1. What is “Personal Data”?
“Personal Data” means any information relating to an identified or identifiable natural person.
2. Who will process my Personal Data?
The information published here applies to the use, sharing and disclosure of your Personal Data by TCM and its vendors and service providers.
3. What Personal Data will be processed?
TCM will keep a record of the details you provided on your application form, any supporting documents requested as part of your admission and additional details provided by recommendations. TCM will also maintain records about your studies and your use of the academic and non-academic facilities and services we offer. This Personal Data will include, but not be limited to, the following:
Full name;
Date of birth;
Sex;
Citizenship and residency status;
Passport or equivalent national ID;
Contact, email, address, phone number;
Religious affiliation;
Photographs;
Previous school(s) attended and graduation dates;
GPA, class rank, and coursework details;
Grades, assessments, and other student performance data;
Degree program;
Medical history (if relevant for certain accommodations);
Disclosure of any past suspensions or expulsions; and
Grievances
Your Personal Data is created, stored, and transmitted securely in a variety of paper and electronic formats. Access to your Personal Data is limited to TCM staff who have a legitimate interest in it under the principle of least privilege for the purpose of carrying out their duties, and our use of your Personal Data will not be excessive.
4. What is the purpose of Personal Data processing?
TCM will process your Personal Data for a range of purposes including:
To deliver and administer your education, record the details of your studies, and determine/confirm your academic achievements;
To retain sample assessment for conducting self-studies and program reviews;
To retain sample assessment to meet accreditation criteria;
Where relevant, to monitor, evaluate, and support your research activity;
To administer the financial aspects of your relationship with TCM and funders;
To deliver facilities to you;
To enable your participation at mentoring centers or events (e.g., graduation);
To communicate with you effectively via mail, email, and phone, including the distribution of relevant newsletters;
To operate security, governance, disciplinary, complaint, and quality assurance processes;
To support your education, medical, safety, and welfare requirements;
To enable your continued education (e.g., credit transfers, transcript sharing);
To compile statistics and conduct research for internal and statutory reporting purposes;
To fulfill and monitor our responsibilities for visa, immigration, and public safety legislation; and
To enable TCM to contact others in the event of an emergency.
TCM considers the processing of your Personal Data for these purposes to be either necessary for the performance of our obligations with you, or necessary for compliance with a legal obligation, or necessary for the pursuit of the legitimate interests of TCM or an external accreditation organization. If we require your consent for any specific use of your Personal Data, we will collect it at the appropriate time, and you can withdraw this at any time.
We generally will only use your Personal Data for the purposes for which we collected it. We may also use your Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law. We will notify you if we need to use your Personal Data for a different purpose.
5. Where will my Personal Data be transferred?
Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. If you are located in the EU, we have implemented procedures in accordance with the GDPR to secure the transfer of your Personal Data to the United States and other jurisdictions.
6. With whom will my Personal Data be shared?
We may share your data with third parties, including our service providers, for the purposes described in this Policy.
We will share your Personal Data with service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
We take reasonable measures to ensure service providers use Personal Data in accordance with applicable laws. Third parties may have their own data security and privacy policies. For more information, contact us using the form provided on our website.
We may share your Personal Data with accreditation organizations to assist with research.
We may also need to share your Personal Data with our Regional Representatives, your funders and/or potential funders, with a regulator, local authorities, or to otherwise exercise our legal rights or comply with the law.
6. What rights do I have associated with my Personal Data?
You have the right to access the Personal Data held about you by TCM through the Registrar’s office.
You also have the right to ask TCM to correct any inaccurate Personal Data held, to delete Personal Data, to restrict processing otherwise, or to receive a copy of the Personal Data you provided TCM.
7. How long is my Personal Data kept?
TCM stores your Personal Data for as long as necessary to complete the application/registration process. As a student, your information will be kept as part of your student record for the duration of your studies and after graduation for research purposes. If you do not complete your program, your information will usually be kept in accordance with state and federal regulations governing document and data retention.
8. Who may I contact?
If you have any questions about how your Personal Data is used, or wish to exercise any of your rights, please consult registrar@tcmi.edu.
9. How do I complain?
If you are not happy with the way your information is being handled, or with the response received from TCM, you have the right to lodge a complaint. You may do so by submitting your complaint using the Grievance link posted on TCM’s website.
10. Are changes made to this Policy?
This GDPR Policy is reviewed every two years or more frequently, as needed. Any changes to the Policy will be published on the TCM websites and referenced in the Catalog and the Student Handbook.
Part 4: Alumni/Graduates
How We Use Your Personal Data
1. What is “Personal Data”?
“Personal Data” means any information relating to an identified or identifiable natural person.
2. Who will process my Personal Data?
The information published here applies to the use, sharing, and disclosure of your Personal Data by TCM and its vendors and service providers.
3. What Personal Data will be processed?
TCM will keep a record of the details you provided on your application form, any supporting documents requested as part of your admission and additional details provided by recommendations. TCM will also maintain records about your studies, and about your use of the academic and non-academic facilities and services that we offer. This Personal Data will include, but not be limited to, the following:
Full name;
Date of birth;
Sex;
Citizenship and residency status;
Passport or equivalent national ID);
Contact, email, address, phone number;
Religious affiliation;
Photographs;
Previous school(s) attended and graduation dates;
GPA, class rank, and coursework details;
Grades, assessments, and other student performance data;
Graduation date;
Degrees earned;
Medical history (if relevant for certain accommodations);
Disclosure of any past suspensions or expulsions; and
Grievances
Your Personal Data is created, stored and transmitted securely in a variety of paper and electronic formats. Access to your Personal Data is limited to TCM staff who have a legitimate interest in it under the principle of least privilege for the purpose of carrying out their duties, and our use of your Personal Data will not be excessive.
4. What is the purpose of Personal Data processing?
TCM will process your Personal Data for a range of purposes including:
To determine/confirm your academic achievements;
To enable your continued education (e.g., credit transfers, transcript sharing);
To retain sample assessment for conducting self-studies and program reviews;
To retain sample assessment to meet accreditation criteria;
To enable your participation at events (e.g., graduate seminars);
To communicate with you effectively via mail, email, and phone, including the distribution of relevant newsletters;
To operate security, governance, disciplinary, complaint, and quality assurance processes;
To compile statistics and conduct research for internal and statutory reporting purposes;
To fulfill and monitor our responsibilities for visa, immigration, and public safety legislation;
To enable TCM to contact others in the event of an emergency.
TCM considers the processing of your Personal Data for these purposes to be either necessary for the performance of our obligations with you, or necessary for compliance with a legal obligation, or necessary for the pursuit of the legitimate interests of TCM or an external accreditation organization. If we require your consent for any specific use of your Personal Data, we will collect it at the appropriate time, and you can withdraw this at any time.
We generally will only use your Personal Data for the purposes for which we collected it. We may also use your Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law. We will notify you if we need to use your Personal Data for a different purpose.
5. Where will my Personal Data be transferred?
Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. If you are located in the EU, we have implemented procedures in accordance with the GDPR to secure the transfer of your Personal Data to the United States and other jurisdictions.
6. With whom will my Personal Data be shared?
We may share your data with third parties, including our service providers, for the purposes described in this Policy.
We will share your Personal Data with service providers where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so.
We take reasonable measures to ensure service providers use Personal Data in accordance with applicable laws. Third parties may have their own data security and privacy policies. For more information, contact us using the form provided on our website.
We may share your Personal Data with accreditation organizations to assist with research.
We may also need to share your Personal Data with our Regional Representatives, your funders and/or potential funders, with a regulator, local authorities, or to otherwise exercise our legal rights or comply with the law.
7. What rights do I have associated with my Personal Data?
You have the right to access the Personal Data that is held about you by TCM through the Registrar’s office.
You also have the right to ask TCM to correct any inaccurate Personal Data held, to delete Personal Data, to restrict processing otherwise, or to receive a copy of the Personal Data you provided TCM.
8. How long is my Personal Data kept?
TCM stores your Personal Data for as long as necessary to confirm the details of your academic achievements and for statistical or historical research.
9. Who may I contact?
If you have any questions about how your Personal Data is used or wish to exercise any of your rights, please consult registrar@tcmi.edu.
10. How do I complain?
If you are not happy with the way your information is being handled or with the response received from TCM, you have the right to lodge a complaint. You may do so by submitting your complaint using the Grievance link posted on TCM’s website.
11. Are changes made to this Policy?
This GDPR Policy is reviewed every two years or more frequently, as needed. Any changes to the Policy will be published on the TCM websites and referenced in the Catalog and the Student Handbook.
Part 5: Donors and Volunteers
How We Use Your Personal Data
What is “Personal Data”?
“Personal Data” means any information relating to an identified or identifiable natural person.
Who will process my Personal Data?
The information published here applies to the use, sharing, and disclosure of your Personal Data by TCM and its service providers and vendors.
What Personal Data will be processed?
TCM will keep a record of the details you provided to TCM while making your gift, upon entering into a financial transaction with TCM, or otherwise becoming a donor to TCM. In addition, TCM will keep a record of the details you provided to TCM on your application form, any supporting documents requested as part of your volunteer decision, additional details provided by recommendations, and all information provided to TCM related to your volunteer service. This Personal Data will include, but not be limited to, the following items:
personal contact details such as name, addresses, telephone numbers, and personal email addresses;
giving history;
financial information provided to TCM by you;
volunteer history;
any personal data, including medical and health data, provided to TCM in connection with your volunteer service; and
photographs.
Your Personal Data is created, stored, and transmitted securely in various paper and electronic formats. Access to your Personal Data is limited to TCM staff who have a legitimate interest in it under the principle of least privilege to carry out their duties, and our use of your Personal Data will not be excessive.
What is the purpose of Personal Data processing?
TCM will process your Personal Data for various purposes, including but not limited to the following:
To process financial transactions with you;
To prevent or detect fraud;
To exercise our legal rights or need to comply with a legal obligation;
To protect your interests (or someone else’s interests);
When it is needed in the public interest or for official purposes;
To make a decision about your volunteer service;
To determine the terms on which you volunteer for us;
To administer a contract that we have entered into with you;
For business management and planning, including accounting and auditing;
To help TCM make reasonable adjustments for any disability requested by you;
To allow us to consider any future accommodation requirements;
To provide information required by accreditation officials and/or legislation; and
For research and statistical purposes, but no information which could identify you will be published.
TCM considers the processing of your Personal Data for these purposes to be either necessary for the performance of our obligations with you, necessary for compliance with a legal obligation, or necessary for the pursuit of the legitimate interests of TCM or an external accreditation organization. If we require your consent for any specific use of your Personal Data, we will collect it at the appropriate time, and you can withdraw this consent at any time.
We generally will only use your Personal Data for the purposes for which we collected it. We may also use your Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and the law. We will notify you if we need to use your Personal Data for a different purpose.
Where will my Personal Data be transferred?
Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. If you are located in the EU, we have implemented procedures in accordance with the GDPR to secure the transfer of your Personal Data to the United States and other jurisdictions.
With whom will my Personal Data be shared?
We may share your data with third parties, including our service providers, for the purposes described in this Policy.
We will share your Personal Data with service providers where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so. The following activities are examples of activities carried out by third-party service providers: gift processing, select financial transactions, audits, and as necessary, IT services.
We take reasonable measures to ensure service providers use Personal Data in accordance with applicable laws. Third parties may have their own data security and privacy policies. For more information, contact us using the form provided on our website.
We may share your Personal Data with accreditation organizations to assist with research.
We may also need to share your Personal Data with a regulator, local authorities, or to otherwise exercise our legal rights or comply with the law.
How is my Personal Data used?
TCM will use your Personal Data for the purposes described herein and in support of your giving and volunteering interaction with TCM.
What rights do I have associated with my Personal Data?
You have the right to access the Personal Data held about you by TCM through the Vice President of Ministry Services.
You also have the right to ask TCM to correct any inaccurate Personal Data held, to delete Personal Data, or otherwise restrict processing or to receive a copy of the Personal Data you provided TCM.
How long is my Personal Data kept?
TCM stores your Personal Data for as long as financial records are required to be held by pursuant to its Document Retention and Destruction Policy
Who may I contact?
If you have any questions about how your Personal Data is used or wish to exercise any of your rights, consult the Vice President of Ministry Services.
How do I complain?
If you are not happy with the way your information is being handled, or with the response received from TCM, you have the right to lodge a complaint with the Vice President of Ministry Services.
Are changes made to this Policy?
This GDPR Policy is reviewed every two years, or more frequently, as needed. Any changes to the Policy will be published on the TCM websites and referenced in the TCM Short-term Worker Handbook and the TCM Long-term Worker Handbook.
