October 1, 2018
Who We Are and What This Policy Covers
The Critical Language Scholarship (CLS) Program is an intensive overseas language and cultural immersion program for American students enrolled at U.S. colleges and universities. The CLS Program is part of a wider government initiative to expand the number of Americans studying and mastering foreign languages that are critical to national security and economic prosperity. CLS plays an important role in preparing students for the 21st century's globalized workforce and increasing national competitiveness.
The CLS Program is sponsored by the U.S. Department of State, with funding provided by the U.S. Government.
American Councils advances scholarly research and cross-border learning through the design and implementation of educational programs that are well grounded in key world languages, cultures and regions. We contribute to the creation of new knowledge, broader professional perspectives, and personal and intellectual growth through international training, academic exchange, collaboration in educational development, and public diplomacy. With a presence in the U.S., Russia and Eurasia for nearly four decades, in addition to representation in over thirty countries across Asia, the Middle East and Southeastern Europe, American Councils strives to expand dialog among students, scholars, educators and professionals for the advancement of learning and mutual respect in the diverse communities and societies in which we work.
Since 2010, American Councils has supported the implementation of the CLS Program. Since 2012, American Councils has supported the implementation of recruitment and selection for the CLS Program, including administration of the https://www.clscholarship.org website and online application forms.
Application forms for the CLS Program are hosted on a platform called AIS Forms, which has been developed by American Councils expressly for this purpose.
Information We Collect
We only collect information about you if we have a reason to do so–for example, to facilitate the administration of our programs and services, to communicate with you, or to improve our programs and services.
We collect information in three ways: 1) if and when you provide it to us; 2) automatically through the operation of our services; and 3) we also may collect limited information about you from outside sources.
Information You Provide to Us
We collect a variety of information from you when you voluntarily provide it to us, such as when you register on the AIS Forms website or complete an application for our programs. The amount and type of information we collect depends on the context of why it is collected and how we intend to use the information.
Registering to Use AIS Forms
We collect personal data from you when you register with AIS Forms and when you enter information into the CLS Program application form and other forms on the AIS Forms website.
You may anonymously browse some limited information about the CLS Program available on the AIS Forms' login pages. AIS Forms login account registration is required, however, to view, complete, and submit online forms for the purpose of voluntarily applying or registering for programs and other activities. During registration you are required to give us personal data that includes your name and email address, and to designate your AIS Forms login username and password. Registration helps us to ensure the security and privacy of the information that you choose to share with us through our online forms. You should not share your AIS Forms login username or password with anyone. We will not ask you for your password.
Using Online Forms
When you complete and submit the CLS Program application and other forms via AIS Forms, you will be asked to share some personal data with us, including:
- Contact Information: such as your name, phone number, home address, and email address;
- Employment History: such as the name of previous employers and your work experience;
- Education History: such as current and prior schools attended, transcripts, fellowships and scholarships received, academic honors, and disciplinary records;
- Personal Information and History: such as your date of birth, passport details, country of birth and citizenship, self-reported criminal records and information about your citizenship and legal status;
- Demographic Information: such as your legal gender, age, date of birth, race and ethnicity;
- Health Information: such as your disability status, medical history and information on medical conditions that may affect your ability to participate in the CLS Program; and
- Other information you choose to disclose in your form responses.
We may also ask for personal data about your parents, legal guardians, emergency contacts, and recommenders. This may include their names, addresses, email addresses, telephone numbers, and other information.
You may choose not to submit your personal data or that of others to us via AIS Forms. In some cases, however, doing so will prevent us from providing certain services. For example, not providing required information such as your name can prevent the processing your program application. Questions on forms to which responses are required in order to process your information are clearly marked with an asterisk (*).
Communications with Us
You may provide us information when you respond to surveys, communicate with our staff about a question or inquiry, or post a question about our programs and services in a public forum.
Information We Collect Automatically
We also collect some information automatically, including:
- Log Information: We collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
- Usage Information: We collect information about your usage of our services. For example, we collect information about what happens when you use our Services along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our services to you, as well as get insights on how people use our services, so we can make our services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
Information We Collect from Other Sources
We may also get information about you from other sources. We may combine personal data that you provide to us with other information that is publicly available or that we receive from other sources, such as grade transcripts, or information provided by your recommenders.
How and Why We Use Personal Information
It is our practice not to collect your personal data unless we need it or intend to use it. We use the information we collect through the AIS Forms platform to manage your registration and application process, evaluation and selection of applications, your program and alumni activities participation, as well as to fulfill our legal responsibilities to provide monitoring, evaluation and reporting on behalf of our program funders.
We use information about you as mentioned above and for the purposes listed below:
- To provide our programs and services–for example to facilitate communication with you about our programs at your request, to make selection decisions for our programs, to facilitate placement of students in individual program sites or with host family accommodations, and to provide support to you before and during our programs;
- To further develop and improve our programs and services–for example by adding new features to our services that we think you will appreciate or to better inform our visitors about our programs;
- To monitor and analyze trends and better understand how users interact with our website and application, which helps us improve our services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals applied for our program after receiving a marketing message or the features used by those who continue to use our services after a certain length of time;
- To monitor and prevent any problems with our services, protect the security of our services, detect and prevent fraudulent or illegal activities, fight spam, and protect the rights and property of American Councils and others; and
- To communicate with you, for example through an email, about the CLS Program and other opportunities we think will be of interest to you and solicit your feedback.
Legal Bases for Collecting and Using Information
Our use of your personal data is made on the following bases:
- The use is necessary for compliance with a legal obligation;
- The use is necessary in order to protect your vital interests or those of another person;
- We have a legitimate interest in using your information, as described below; or
We rely on several legitimate interests in our use and sharing of your personal data, including:
- Providing and improving our programs;
- Administration of our operations;
- Promoting the success of our current and former students;
- Maintaining ongoing relationships with alumni, and helping them to connect them with one another;
- Providing opportunities for participation in events;
- Conducting research;
- Understanding how our services are used;
- Ensuring the safety and security of our students, employees and others;
- Meeting reporting requirements set by the federal government;
- Maintaining records;
- Evaluating and selecting participants for our programs;
- Meeting our obligations and enforcing our legal rights.
How We Share Information
American Councils does not sell your personal data.
We may share your personal data with various American Councils' offices, affiliated organization, and third-party business partners. Our third-party business partners may include program funders, service providers, and others located in the United States of America and throughout the world that work with us to process your application or request, and to deliver our program and other services to you. All third-party business partners that we share your personal data with are required to comply with applicable regulations and privacy requirements.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Funders: The CLS Program is sponsored by the U.S. Department of State, with funding provided by the U.S. Government and supported in its administration by American Councils for International Education under a cooperative agreement. Personal data collected by American Councils may be provided to the funders of the CLS Program at their request to facilitate their legitimate interest in providing oversight for the administration of this cooperative agreement.
- Partners, Employees, and Independent Contractors: We may disclose information about you to our partners, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services and programs (e.g. in order to register program participants with local authorities, or in order to arrange host family accommodations for program participants) or to process the information on our behalf.
- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you on our behalf. This group includes vendors that help us provide our services and programs to you (like postal and email delivery services that help us stay in touch with you, customer email support services that help us communicate with you, or travel providers with whom we book ground and air travel for our program participants), those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), and those that help us understand and enhance our services (like analytics providers).
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request. We will strive to limit the scope of information that is furnished under these circumstances to only that which is necessary to satisfy the specific request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of American Councils, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
How Long We Keep Information
We keep the personal data that you share with us via AIS Forms and other sources for as long as it is necessary for us to provide you with our program services, for as long as it is necessary for us to administer alumni and other outreach activities, and for as long as it is required for us to meet our oversight and reporting requirements and responsibilities.
Your personal data is retained for as long as there is a basis for its collection and use, until such time as consent it withdrawn (if the legal basis for its use is consent), or until effective opposition to data processing is filed in cases where the legal basis for its use is the legitimate interest of American Councils. The Data processing period may be extended if the processing is necessary to establish and assert any claims or defend against them, and after that time only if and to the extent required by law.
How We Protect Personal Data
We take precautions to protect your personal data both online and offline when it is submitted to us via AIS Forms.
All information that we collect from you via AIS Forms is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the web page. The database in which all the information you submit to us via AIS Forms is stored is also encrypted for additional security.
While we use encryption to protect personal data transmitted online, we also protect your personal data offline. Only employees and business partners who need your personal data to perform a specific job, such as program staff, program recruiters, and travel administrators, are granted access to your personal data and only to your personal data that is needed to complete their jobs. Access to data stored in AIS Forms and the database is subject to authentication with unique username and password. Users are only allowed to access information that relates to their areas of responsibility. The computers and servers on which we store personal data are kept in a secure environment.
American Councils' employees, third-party business partners, and others that have access to personal data are also provided with guidance in its use and protection. They will use the information exclusively for American Councils' activities and the management of American Councils' program and other operations.
You can do the following at any time by using the contact information given on AIS Forms or below:
- See what personal data we have about you
- Change or correct any personal data we have about you if it is inaccurate or incomplete
- Submit a request that personal data we have about you be deleted
- Express any concern you have about our use of your personal data
For Residents of the European Economic Area (EEA)
Under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation" or "GDPR"), each resident of the European Economic Area (EEA) whose personal data is processed by American Councils has the following rights to:
- Be informed and to request access to personal data processed by us
- Request correction or update of personal data if it is inaccurate or incomplete
- Request the deletion of personal data
- Request that we temporarily or permanently process all or part of your personal data
- Object, at any time, to the processing of personal data by us
- Request an electronic copy of personal data or to transfer it for use by third parties
- Refuse to be the subject of automatically made decisions
- Not be subject to decisions based solely on automatic decision making, including profiling, if a decision may cause legal effects for the user or have a similar effect
- Withdraw consent at any time without affecting the lawfulness of the processing carried out through consent before its withdrawal
- File a complaint to the European Data Protection Supervisor (EDPS) if it considers that the processing of personal data violates the provisions of GDPR
Why We Transfer Personal Data Across International Borders
What to Know About Links to and From Other Websites
AIS Forms may contain links to other affiliated and unaffiliated websites or be linked to by such websites for your convenience and information. Please be aware that we are not responsible or liable for any content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personal data.
Data Protection Contact
Gregg Detkos, Manager
AIS Development and Operations
ATTN: AIS Operations
American Councils for International Education
1828 L St NW Ste 1200
Washington DC 20036-5136
Controllers and Responsible Companies
American Councils is the controller for all of the processing activities across all of our services and programs.