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Symptom Tracker: Northwestern Privacy Statement

Effective as of August 18, 2020

Purpose of Privacy Statement

Northwestern University (“Northwestern,” “we,” or “us”) is committed to the safety of its students, staff, employees and visitors. In accordance with the COVID-19 Guidance from the Illinois Board of Higher Education, Northwestern is requiring all individuals entering campus to complete a COVID-19 screening questionnaire through Symptom Tracker: Northwestern (“Symptom Tracker”), available online (symptomtracker.northwestern.edu) or through the mobile application.

Symptom Tracker requires users to self-certify their current health condition as it concerns COVID-19 symptoms and possible exposure through responding to a series of “yes” / “no” questions. Users that report actual or potential COVID-19 symptoms or exposure will be contacted by Northwestern for further information and screening. Symptom Tracker is not a contact tracing technology. Therefore, it does not use wi-fi, geolocation or Bluetooth technology for contact tracing purposes.

Because Northwestern respects the privacy of your personal information, we have prepared this Privacy Statement to assist you in understanding the personal information that is collected when you use Symptom Tracker, how that information is used and shared, and how it is safeguarded.

We are closely monitoring COVID-19 and related local, state, and federal mandates and guidance, which remains a fluid situation. As a result, from time to time we may change this Privacy Statement. If we do, we will post an amended version online. Please review this Privacy Statement periodically. Please also refer to our Terms of Use which sets out the terms governing your use of Symptom Tracker.

For COVID-19-related campus updates and resources, as well as other applicable Northwestern policies and requirements for individuals, please visit https://www.northwestern.edu/coronavirus-covid-19-updates/.

What Personal Information Does Symptom Tracker Collect?

Through your use of Symptom Tracker, we may collect information about you from which you can be identified (“personal information”), including the following:

For employees and students of Northwestern: your Northwestern  user ID and password, which will allow us to link the information collected about you through the app to other information about you that Northwestern already maintains, such as information contained in Northwestern’s existing directories, including your first and last name, email address, and phone number.

For guests/visitors to Northwestern’s campus and buildings: your first and last name, email address, phone number, and host email address.

For all users of Symptom Tracker: certain COVID-19 health-related information in the form of your “yes” / “no” responses and, if you choose to provide it, your temperature.

How Do We Use Your Personal Information?

We use the personal information we collect through Symptom Tracker to control access to Northwestern campus and buildings through Symptom Tracker’s badge system in an effort to safeguard the health and wellbeing of the Northwestern community.

If Symptom Tracker presents you with a red badge (i.e., denied access), you will receive an email with further direction so Northwestern may verify Symptom Tracker’s badge determination, assess whether further health screening is required, and otherwise provide support.

We may also use the personal information we collect to communicate with you about Symptom Tracker or to inform you of any changes to Symptom Tracker, to maintain and improve Symptom Tracker, to protect our legal rights and the rights of others, to efficiently maintain University operations, and to comply with applicable law.

Who Do We Share Your Personal Information With?

Personal information collected through Symptom Tracker will not be shared with individuals or entities outside of Northwestern except for limited circumstances:

  • To service providers, agents, contractors, or business partners: We may share your personal information with our third party service providers, agents, contractors, or business partners in connection with services that these individuals or entities perform for, or in collaboration with Northwestern. For instance, we may share your personal information with Northwestern Memorial Hospital for purposes of providing technical support for Symptom Tracker, including the hosting of information collected through Symptom Tracker, as well as performing COVID-19 tests, and administering and improving Northwestern’s COVID-19 testing and tracing program.
  • As required by law or to protect our rights and interests or for the protection of others: We may disclose personal information to comply with applicable laws and regulations, such as to respond to a subpoena or similar legal process, to prevent fraud, to protect against misuse of the Symptom Tracker, and to establish, exercise or defend our rights and interests or to protect the rights or safety of the public. For example, we may share your personal information with relevant public health authorities, such as the Illinois Department of Public Health and the United States Centers for Disease Control and Prevention (CDC),  for public health purposes.
  • To other third parties with your consent: We may share your personal information to any other person or entity where you consent to the disclosure.

Except as described in this Privacy Statement, the Personal Information collected through Symptom Tracker will only be accessible to Northwestern employees on a need-to-know basis to facilitate the uses and purposes mentioned herein.  Where your personal information is shared with third parties, we will seek to share the minimum amount necessary.

Retaining Your Personal Information

We will only keep your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. We may also keep your records if legally required or to fulfill a legitimate interest.

Security

We maintain commercially reasonable security measures to protect the personal information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

Children’s Information

Symptom Tracker is intended for general audiences, and we do not intend to collect and we will not knowingly collect or solicit personal information online through Symptom Tracker from children under the age of 13.

How to Contact Us

To contact us for questions or concerns about this Privacy Statement or our practices related to Symptom Tracker, please call us at (847) 467-4111.