University of Louisville
Digital Transformation Center
Privacy Policy for Noncredit Workforce Training Programs
1. Effective Date: To be established upon approval
1. Scope and Institutional Commitment
2. The University of Louisville Digital Transformation Center (DTC) is committed to protecting the privacy and personal information of individuals participating in its noncredit workforce training programs.
3. This Privacy Policy applies to all workforce training programs available for purchase or enrollment through dtctraining.louisville.edu, including free, paid, and grant-funded offerings, regardless of how participants are enrolled.
4. The policy addresses the collection, use, disclosure, and protection of personal information associated with registration, enrollment, instruction, assessments, credentialing, and related administrative activities.
5. DTC's workforce training programs are noncredit educational offerings and do not, by themselves, constitute enrollment in a University of Louisville degree or academic credit program.
6. As part of the University of Louisville, DTC operates in accordance with applicable University privacy, information security, and records management policies. This Privacy Policy supplements, rather than replaces, applicable institutional requirements.
2. Information We Collect
7. DTC collects information necessary to administer and deliver its noncredit workforce training programs, support participants, fulfill reporting obligations, and maintain appropriate program records.
8. Information collected may include the following categories.
9. Personal and Enrollment Information
10. Names, email addresses, contact information, account credentials, program selections, enrollment dates, and other information needed to establish and administer workforce training accounts.
11. Educational and Workforce Training Information
12. Course participation, instructional activities, assignment submissions, assessment results, progress, completion records, certificates, digital badges, and information related to educational or employment outcomes.
13. Payment and Transaction Information
14. When participants purchase workforce training programs, payment information is processed through authorized third-party payment providers. DTC may retain limited transaction records, including purchase details, payment status, amounts paid, and information necessary for financial reconciliation, refunds, and compliance.
15. Technical and Usage Information
16. Information associated with accessing and using the workforce training platform, which may include IP addresses, device and browser information, login activity, session information, and website usage data.
17. Demographic Information
18. Certain workforce training programs require participants to complete demographic surveys to support program evaluation, funding requirements, and performance reporting.
19. These surveys may request information concerning race, ethnicity, gender, veteran status, disability status, household income, or other characteristics relevant to the program.
20. Participants are not required to provide their names as part of these demographic surveys. Survey information is generally used and reported in aggregate form to evaluate program participation and demonstrate performance against established objectives.
21. Scholarship Eligibility Documentation
22. Some grant-funded workforce training opportunities are restricted to specific populations, including veterans, law enforcement personnel, first responders, or other designated groups.
23. Participants applying for these opportunities may be required to submit identifying documentation establishing their eligibility.
24. DTC uses this information to verify eligibility, administer scholarship awards, maintain required records, and satisfy applicable grant, financial, and audit requirements. Access to eligibility documentation is restricted to authorized personnel with a legitimate program-related need.
3. How We Use Personal Information
25. DTC uses participant information for legitimate educational, administrative, operational, and compliance purposes associated with its noncredit workforce training programs.
26. These purposes include:
27. Registration and Enrollment: Establishing participant accounts, processing enrollments, confirming eligibility, and providing access to workforce training programs.
28. Instruction, Assessment, and Credentialing: Delivering instructional content, documenting participation, evaluating learning, maintaining completion records, and issuing certificates or digital credentials.
29. Scholarship Administration: Reviewing eligibility documentation, determining qualification for funded opportunities, administering awards, and maintaining supporting records.
30. Program Evaluation, Grant Performance, and Reporting: Evaluating program participation, measuring workforce training effectiveness, tracking educational and employment outcomes, and documenting performance against established grant objectives.
31. Participant information may be used to prepare and submit required performance metrics, progress reports, and other documentation to state and federal funding agencies, sponsoring organizations, and authorized University officials.
32. Such reporting is conducted in accordance with applicable grant agreements, reporting requirements, University policies, and federal and state laws.
33. Participant Communications: Providing enrollment confirmations, instructional updates, account notifications, completion information, and other communications necessary to administer workforce training programs.
34. Additional Workforce Training Opportunities: Communicating with current and former participants about additional workforce training programs, certifications, professional development opportunities, and related DTC offerings.
35. Participants may unsubscribe from promotional communications. Unsubscribing does not prevent DTC from sending necessary administrative, enrollment, or program-related communications.
36. Financial Administration: Processing purchases, maintaining transaction records, administering refunds, and supporting financial reconciliation and compliance.
37. Program Improvement: Reviewing participant feedback and platform usage to improve workforce training content, delivery, accessibility, and participant experiences.
38. Legal and Institutional Compliance: Meeting applicable legal requirements, University policies, contractual obligations, records retention requirements, and authorized audit or oversight activities.
4. Consent and Participant Choices
39. DTC makes this Privacy Policy available to individuals accessing or enrolling in its noncredit workforce training programs.
40. Participants purchasing workforce training through the online platform are required to acknowledge the Privacy Policy during checkout.
41. This Privacy Policy applies to all participants regardless of whether enrollment involves a purchase, a free offering, or a grant-funded opportunity.
42. Certain information is necessary to establish accounts, administer workforce training, determine eligibility, issue credentials, or meet grant and legal requirements. Failure to provide required information may limit participation in specific offerings.
43. Participants may opt out of promotional communications through the unsubscribe instructions provided in those messages or by contacting DTC.
44. Where applicable law provides a right to withdraw consent or request deletion of personal information, DTC will review and address those requests in coordination with appropriate University offices.
45. Such requests may be subject to applicable legal exceptions, grant requirements, financial accountability obligations, and University records retention policies.
5. Disclosure and Sharing of Personal Information
46. DTC does not sell participant personal information.
47. Participant information is used primarily for the administration and delivery of DTC's noncredit workforce training programs.
48. DTC does not routinely disclose identifiable participant information to consortium universities, instructional partners, or external evaluators.
49. Information may be disclosed under the following circumstances.
50. Grant Administration and Reporting
51. DTC may provide aggregated or de-identified participation and performance information to state and federal funding agencies, sponsoring organizations, and authorized University officials.
52. In limited circumstances, identifiable information, such as a participant's email address, may be provided to an authorized grant sponsor when necessary to document scholarship awards, reconcile expenditures, verify participation, or meet applicable financial and grant accountability requirements.
53. Authorized University Operations
54. Information may be shared with authorized University personnel or offices when necessary for legitimate administrative, financial, compliance, security, or oversight responsibilities.
55. Third-Party Service Providers
56. DTC may provide limited information to authorized technology and service providers when necessary to operate the workforce training platform, process payments, communicate with participants, or issue credentials.
57. Legal and Security Requirements
58. Information may be disclosed when required by applicable law, legal process, authorized audits, University policy, or when necessary to protect the security and integrity of University systems and operations.
59. Any disclosure is subject to applicable legal requirements, University policies, and relevant contractual or grant obligations.
6. Payment Processing and Security
60. DTC uses authorized third-party payment processors, including Stripe and Authorize.net, to process payments for applicable noncredit workforce training programs.
61. Payment card information is processed through these providers and is subject to their applicable security practices and privacy policies.
62. DTC does not store participants' full payment card numbers or card security codes.
63. DTC may maintain limited transaction records necessary to document purchases, administer refunds, reconcile financial activity, and satisfy University accounting, audit, and compliance requirements.
64. Depending on the payment service, participants may be offered an option to save their payment information for future purchases.
65. DTC encourages participants not to select the option to save payment card information for future purchases unless they understand and wish to use that feature.
66. When a participant chooses to save payment information, the information is maintained by the applicable payment provider rather than directly by DTC.
67. Payment processing activities are subject to applicable University payment security requirements and Payment Card Industry Data Security Standard (PCI DSS) obligations.
7. Third-Party Services
68. DTC uses authorized third-party technology providers to support the delivery and administration of its noncredit workforce training programs.
69. These services may support online learning, payment processing, participant communications, website analytics, credential issuance, and other necessary operational functions.
70. When required to provide these services, limited participant information may be shared with the applicable provider.
71. Third-party providers may maintain their own privacy policies, security practices, and data processing arrangements. Information processed by these providers may be stored or handled in locations outside the participant's state or country of residence.
72. Digital Badges and Credly
73. DTC uses Credly to issue certain digital badges and workforce credentials.
74. When a participant earns an eligible credential, DTC may provide Credly with limited information necessary to issue the badge, including the participant's name, email address, credential information, and applicable completion details.
75. Credly sends participants an invitation to claim their digital badges and establish or access their own Credly accounts.
76. DTC does not create Credly accounts on behalf of participants.
77. Participants who choose to claim their badges are responsible for reviewing Credly's privacy policies and managing the privacy settings associated with their Credly accounts.
78. External Websites
79. The workforce training platform may contain links to external websites or services. DTC is not responsible for the privacy practices of independently operated third-party websites.
80. Participants are encouraged to review the privacy policies of external services before providing personal information.
8. Information Security
81. DTC takes reasonable steps to protect participant information collected and maintained in connection with its noncredit workforce training programs.
82. As part of the University of Louisville, DTC operates under applicable institutional information security, privacy, and records management requirements.
83. Access to participant information is restricted to authorized DTC personnel based on their job responsibilities and legitimate operational needs.
84. DTC does not routinely share identifiable participant information outside the department except as necessary for authorized University operations, grant administration, scholarship verification, credential issuance, legal compliance, or other circumstances described in this Privacy Policy.
85. DTC also relies on authorized third-party providers to maintain appropriate safeguards for information processed through their services.
86. Although DTC and its authorized providers take precautions to protect participant information, no electronic system or method of transmitting information can be guaranteed to be completely secure.
87. Suspected or confirmed information security incidents are addressed in coordination with appropriate University offices and applicable institutional procedures.
9. Cookies and Tracking Technologies
88. The DTC workforce training platform uses cookies and similar technologies to support website functionality, participant account access, session management, and the overall user experience.
89. These technologies may collect information about browser settings, device characteristics, website activity, and interactions with the workforce training platform.
90. DTC uses Google Analytics to understand website traffic, platform usage, and general website performance.
91. This information helps DTC evaluate how participants and visitors interact with its workforce training platform and identify opportunities for improvement.
92. DTC does not currently use Google advertising or remarketing campaigns in connection with its workforce training platform.
93. Google Analytics processes information in accordance with Google's applicable privacy practices. Additional information is available through Google's Privacy Policy at https://policies.google.com/privacy.
94. Participants may manage or restrict certain cookies through their browser settings. Disabling cookies may affect the functionality of some features of the workforce training platform.
95. Browser-based tracking preferences, including Do Not Track signals, may be handled differently depending on the technology providers and services involved.
10. Educational Records and FERPA
96. DTC maintains educational and workforce training records for participants enrolled through its online learning platform, dtctraining.louisville.edu.
97. These records may include enrollment information, course participation, assessment results, assignment submissions, completion records, certificates, digital badges, and other information associated with a participant's workforce training activities.
98. DTC workforce training participants are enrolled through the online learning platform and are not automatically registered as University of Louisville students through the University's official student information system.
99. Applicability of FERPA
100. The Family Educational Rights and Privacy Act (FERPA) provides certain privacy protections and rights concerning education records maintained by educational institutions receiving applicable federal funding.
101. Although DTC operates as part of the University of Louisville, participation in DTC's noncredit workforce training programs does not automatically establish student status or FERPA eligibility.
102. When FERPA applies to a participant's records, DTC handles those records in accordance with applicable FERPA requirements and University policies.
103. Access to Educational Records
104. DTC restricts access to participant educational and workforce training records to authorized personnel who require the information to perform legitimate educational, administrative, or program responsibilities.
105. Educational records are not routinely shared outside DTC except as authorized or required for University operations, grant administration, credential issuance, legal compliance, or other purposes described in this Privacy Policy.
106. Participant Rights
107. Participants whose records are protected under FERPA may have rights to inspect and review their education records, request amendments to records they believe are inaccurate or misleading, and exercise applicable rights concerning the disclosure of personally identifiable information.
108. Participants may contact DTC or the appropriate University office with questions concerning their educational records and applicable privacy rights.
109. Records Retention and Protection
110. Educational and workforce training records are maintained in accordance with applicable University records retention requirements, grant agreements, and federal and state laws.
111. Regardless of whether FERPA applies, DTC handles participant educational and workforce training information in accordance with applicable University privacy and information security requirements.
11. International Participants and GDPR
112. The University of Louisville Digital Transformation Center primarily provides noncredit workforce training programs to participants within the United States.
113. Although DTC does not actively recruit internationally, individuals residing outside the United States may independently access and enroll in available workforce training programs.
114. The European Union's General Data Protection Regulation (GDPR) establishes requirements governing the collection, processing, storage, and protection of personal information when its provisions apply.
115. As part of the University of Louisville, DTC handles personal information in accordance with applicable University privacy and information security policies and relevant federal, state, and international legal requirements.
116. International Data Processing
117. Personal information collected through the DTC workforce training platform may be processed or stored in the United States or other locations where authorized technology providers operate.
118. Participants accessing DTC workforce training programs from outside the United States should understand that their information may be transferred to and processed in jurisdictions with privacy laws different from those in their country of residence.
119. Privacy Rights
120. When GDPR or other applicable privacy laws provide participants with specific rights concerning their personal information, DTC will address requests in coordination with the appropriate University offices and in accordance with applicable legal requirements.
121. Depending on the applicable law and circumstances, these rights may include requesting access to personal information, correcting inaccurate information, requesting deletion, or objecting to certain processing activities.
122. Such rights may be subject to applicable legal exceptions, University records retention requirements, and other authorized obligations.
12. Children's Privacy and Age Requirements
123. The University of Louisville Digital Transformation Center provides noncredit workforce training programs designed primarily for adult learners pursuing professional development, career advancement, and workforce credentials.
124. Participation in DTC workforce training programs is generally intended for individuals 18 years of age or older.
125. Individuals under the age of 18 may be permitted to enroll by exception, subject to program eligibility requirements, DTC authorization, and any applicable parental or legal guardian consent requirements.
126. DTC does not knowingly collect personal information from children under the age of 13 without appropriate authorization and compliance with applicable legal requirements, including the Children's Online Privacy Protection Act (COPPA), when applicable.
127. When minors are authorized to participate in DTC workforce training programs, their personal information is collected, used, and protected in accordance with applicable University policies and federal and state privacy requirements.
128. If DTC becomes aware that personal information from a child under the age of 13 has been collected without appropriate authorization, DTC will take appropriate steps to address the information in accordance with applicable law and University policies.
129. Parents or legal guardians with concerns about information collected from a minor may contact DTC using the contact information provided in this Privacy Policy.
13. Privacy Policy Updates and Changes
130. The University of Louisville Digital Transformation Center may periodically review and update this Privacy Policy to reflect changes in its noncredit workforce training programs, operational practices, technology platforms, University policies, or applicable legal requirements.
131. When updates are made, the revised Privacy Policy will be published on dtctraining.louisville.edu with an updated effective date.
132. When changes materially affect how participant personal information is collected, used, or disclosed, DTC will provide additional notice when required by applicable law or University policy.
133. Participants are encouraged to periodically review this Privacy Policy to remain informed about how their personal information is handled.
14. Contact Information and Privacy Inquiries
134. Participants with questions or concerns about this Privacy Policy, the collection or use of their personal information, or the handling of their workforce training records may contact the University of Louisville Digital Transformation Center.
135. DTC will review privacy-related inquiries and coordinate with the appropriate University offices when additional guidance or action is required.
136. Requests involving access to personal information, correction of records, or other applicable privacy rights will be addressed in accordance with University policies, applicable legal requirements, and records retention obligations.
137. Digital Transformation Center
University of Louisville
Email:[email protected]
Website:https://louisville.edu/servicecenters/digital-transformation-center
Workforce Training Platform: https://dtctraining.louisville.edu