Drexel University (“Drexel”, “University,” “we,” “our” or “us”) values the privacy of personal information and personally identifiable information, including any information that could potentially be used to identify a particular person. The University’s commitment to protecting the privacy and confidentiality of personal information, and the framework established to do so is detailed in the Drexel University Privacy Program Plan.

This Privacy Notice (“Notice”) describes how Drexel University processes personal information about you in connection with your COVID-19 status. This Notice also sets out your rights in relation to this personal information.

Personal information we collect

When you perform certain activities, including but not limited to using the Drexel Health Checker; registering for a COVID-19 test, vaccine or booster; providing test result or vaccine information, and uploading supporting documentation; confirming a positive COVID-19 test result; submitting an optional medical or religious exemption request; or responding to contact tracing inquiries, we process personal information (“COVID-19 related information” or “the information”) about you. Personal information is information about you through which you can be identified, including information through which you can be identified by combining the information with other information.

It is important to note that we may be required by federal, state or local law, regulation or ordinance to collect and maintain certain personal information about you as a student, employee, visitor or contractor of the University. Failure to provide the information may prevent or delay your access to the University or University programs. We will inform you at the time your personal information is collected whether certain information is mandatory and the consequences of the failure to provide such personal information to the University.

Information you provide to us

We collect COVID-19 related information directly from you that may including the following:

1. Personal details (e.g., first and last name; date of birth; age; gender)
2. Contact details (e.g., Drexel email address; physical address including zip code and residence hall; phone number(s))
3. Identification numbers (e.g., Drexel University ID number)
4. Program and campus details (e.g., your Drexel college, school or program; dates on campus; enrolled course(s); course advisor; details of self-isolation (if applicable))
5. Health and safety information relating to your COVID-19 and vaccine status (e.g., test result(s); COVID-19 symptoms; exposure to COVID-19; pertinent travel; receipt of one or more doses of a vaccine; type of vaccine you received; dates vaccine received)
6. Documentation you submit as proof of negative test and vaccination (e.g., test result(s); images or scanned copies of your CDC vaccination record card, WHO booklet, letter from a physician verifying your vaccination; such documentation may contain additional personal information about you, such as date(s) and location of vaccination, vaccine lot number(s), patient number, or other personal information about you)
7. Religious or Medical Exemption information (e.g., if you choose to submit a request form for an exemption and provide information about your health or medical condition(s) or your religious beliefs, including supporting documentation from a physician or religious leader)

Information from third parties

Drexel may use a third party to conduct certain COVID-19 related functions including but not limited to contact tracing, testing or vaccine services. To ensure your information is kept up to date with us, the third party may provide information related to your exposure, testing and vaccine status to the University.

Sensitive information we collect

The information that we about you collect may include sensitive information, such as:

1. Health and medical information, including information relating to your COVID-19 and vaccination status and, if you choose to submit a request for a medical vaccine exemption, information about your health or medical status.
2. Information about your religious beliefs, if you choose to submit a request for a religious vaccine exemption.

How we use the information

Drexel University may use identifiable COVID-19 related information that we collect as described in this Notice for the following purposes:

1. To manage health and safety considerations. This includes:
   • processing information to protect the health and safety of our students, faculty and staff, alumnae, visitors, and third parties;
   • helping us learn more about the spread and impact of COVID-19 in the Drexel University community;
   • ensuring vaccination among community members;
   • managing and responding to incidents of COVID-19 that occur among our students, faculty and staff, and helping us offer the appropriate support resources to individuals with confirmed or suspected COVID-19 infection, such as testing, care treatment plans, and appropriate referrals;
   • determining whether to implement, waive or reduce COVID-19 testing requirements, quarantine periods, face covering requirements, or other public health protocols;
   • making decisions about medical or religious exemptions to the vaccination requirements;
   • coordinating and registering Drexel community members for COVID-19 tests, vaccines, and boosters, if necessary;
   • directing public-health-informed decisions related to living, learning, and working at Drexel University.
2. To communicate with you. This may include communicating with you about COVID-19 safety, testing, vaccine and booster considerations or responding to your questions or requests.
3. To comply with our legal obligations. This may include processing personal information for purposes of compliance with applicable federal, state and local laws, regulation or ordinances.

Any other use or disclosure of the COVID-19 related information will be de-identified, that is, the information will exclude names, email addresses, and phone numbers, as well as other personally identifiable information. This information will be used only for purposes of approved research.

Our use of the information is governed by applicable University policy, the Drexel Health Checker Consent and the Drexel University Privacy Program. Data requests and use cases will only be considered if they are related to public health.

How we share the information

Drexel University is deeply committed to privacy and no information you share will be sold to third parties or used for commercial purposes. Your COVID-19 related information will be processed only in accordance with this Notice.  We may contact you to follow up on the information you provide as described in this Notice.

How long we keep the information

The COVID-19 related information described in this Notice is retained in compliance with applicable federal, state or local laws, or University policy, including but not limited to the University Record Management Policy.

How we protect the information

Drexel University takes seriously the importance of maintaining the security of the COVID-19 related information we collect and maintain, and we endeavor to protect information from unauthorized access and misuse. We strive to ensure reasonable security measures are in place, including physical, administrative, and technical safeguards to protect your personal information.

Your information will be maintained by Drexel University in a secure manner, in compliance with applicable federal, state and local laws, regulations and ordinances with access limited to authorized Drexel representatives. All data is encrypted and stored securely.

How to exercise your rights

Where applicable, and subject our obligations under federal, state and local requirements, you may have the following rights with respect to your personal information:

1. To access the information that we have about you;
2. To request that we amend, delete or erase your information;
3. To request that we restrict the way we use your information or to opt-out of certain communications;
4. To object to the way we use your information subject to the processing your personal information on the basis of our legitimate interests;
5. To file a complaint regarding the processing of your information.

If you have questions or concerns about this Notice

If you have questions or concerns about this Notice, wish to exercise your rights, or seek to notify us of a change in your information or status, please contact covid19questions@drexel.edu. You may also contact the Drexel University Privacy Program Services team at privacy@drexel.edu.

Changes to this Notice

This privacy notice may be updated from time to time. We will post the date our notice was last updated at the top of this privacy notice.

Last update: 12/15/2022