Colorado Succeeds Personal Information Privacy Policy

Colorado Succeeds (“Succeeds”) recognizes the importance of protecting the personally identifiable information of its clients, customers, partners, and employees that Succeeds may gather and use as part of its regular business operations (“Personal Information”). Personal Information may include, but is not limited to, names, physical addresses, email addresses, telephone numbers, and other private identifying information.

Recognizing the responsibility to keep Personal Information private, Succeeds hereby establishes the following policy to protect the confidentiality of Personal Information in its possession.

Collection, Handling, and Storage of Personal Information:
Succeeds will only collect Personal Information through fair and legal means, including by providing notice to individuals who submit to Succeeds their Personal Information. Such notice shall describe the purpose for which the information is being collected and shall provide the individual with the opportunity to withhold any private information they so choose. 

Once collected, Succeeds will take reasonable precautions to store and handle the Personal Information in order to preserve its confidential and private nature. Personal Information shall be stored electronically within Succeeds’ private and secure computer networks that may only be accessed by authorized personnel through the use of a confidential password. Personal Information shall not be stored on any personal and unsecured networks, computers, or other electronic devices. If Personal Information has been converted into a hard-copy format, the authorized personnel who is using the information in hard-copy shall ensure that: (i) the information is kept within his or her control at all times; (ii) the information is not displayed publicly; and (iii) the hard-copy of the Personnel Information is destroyed (by shredding or another other method approved by the Chief Privacy Officer) once there is no longer a need for the hard-copy.    

Using Personal Information for Authorized Purposes:
Succeeds will only use Personal Information for such activities and uses that are legitimately related to the purpose for which the Personal Information was gathered. In addition, when possible, Succeeds will employ reasonable efforts to narrow the scope of its use of Personal Information. For example, Personal Information will only be shared with, and used by, those authorized personnel, contractors, or other third-parties who have a legitimate reason to access and use the Personal Information in connection with an Authorized Purpose.

Student Personal Information:
In the event that Succeeds obtains any Personal Information of students from the Colorado Department of Education, a public school district, or a public school (“Student Data”), then the access, storage, and use of the Student Data shall be subject to the terms and conditions provided in the Student Data Privacy Addendum, which is incorporated and attached hereto. This Personal Information Privacy Policy along with the Student Data Privacy Addendum are designed to ensure that Succeeds’ collection, storage, and use of Student Data is compliant with the Family Education Records Protection Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), the Children’s Internet Protection Act (“CIPA”), and the Protection of Pupil Rights Amendment (“PPRA”). Under certain circumstances, Succeeds will implement and use a FERPA waiver in order to ensure that Succeeds’ collection, storage, and use of Student Data is in full compliance with FERPA.

All personnel and contractors who will have access to, or use, Student Data, shall meet with Succeeds’ Chief Privacy Officer for a training on the Student Data Privacy Addendum, FERPA, COPPA, CIPA, and PPRA prior to accessing or using Student Data.   

Disclosures and Distributions of Personal Information to Third Parties:
Succeeds will not disclose or distribute Personal Information to third parties unless: (i) an individual has authorized Succeeds to share their Personal Information with third-parties; or (ii) there is a legitimate reason to share the Personal Information with the third-party in connection with the Authorized Purpose for which the Personal Information was gathered; or (iii) the disclosure is required by law; or (iv) the disclosure will be used to protect the life, body, or property of a person.

Exclusions:
Personal Information does not include publicly available information. To the extent Succeeds aggregates or analyzes Personal Information in a manner by which the output is de-personalized, then that output is not considered Personal Information and Succeeds’ use of that output is not covered by this policy.   

General Provisions:
Succeeds shall comply with all relevant laws, and contract obligations with regard to the protection of Personal Information. Succeeds will promptly respond to any requests from an individual with regard to their Personal Information that is in the possession of Succeeds.

Succeeds shall distribute this policy to its officers, directors, employees, and all contractors, or other third parties who might be provided with access to Personal Information. According to its discretion, Succeeds shall review, update, and modify this policy.

All questions or concerns regarding this policy should be directed to the Chief of Staff, Shannon Nicholas, who is hereby designated as Succeeds’ “Chief Privacy Officer” who is responsible for the implementation of this policy.