Participants in the Verizon Technician Training Program (“VTT”) are non-credit students of Pace University, and management of their student record is guided by Pace University’s FERPA policy. Absent an applicable exception under FERPA, Pace University will obtain prior written consent from a participant before disclosing personally identifiable information (“PII”) from the participant’s education record to Verizon.
Pace University will obtain written, FERPA-compliant consent from each participant prior to sharing any PII with Verizon. Such consent will:
- Clearly describe the information to be disclosed;
- Specify that the purpose of disclosure is limited to program evaluation and participant survey follow-up and, only for participants who affirmatively opt in as described below, outreach regarding potential job opportunities at Verizon;
- State that participation is voluntary and not a condition of enrollment or program completion; and
- Permit the participant to withdraw consent at any time without penalty. Consent shall be obtained in a stand-alone disclosure separate from other acknowledgements and must include explicit written authorization to share contact information with Verizon solely for the purposes described in this Policy Statement.
Any disclosure of participant contact information to Verizon for recruiting or outreach regarding potential job opportunities at Verizon shall be conditioned on a separate, affirmative opt-in by the participant, and participants must be able to participate in and complete the VTT program without providing such opt-in.
The participant consent language included in the VTT application shall make clear that applicants are not required to consent to sharing PII with Verizon in order to participate in the program.
Subject to the consent requirements above, Pace University may disclose to Verizon participant PII, including a participant’s name, email address, phone number, and program completion status, solely for the purposes described in this Section. Pace University shall retain ownership and control over all participant data. Verizon receives no rights, title, or interest in such data.
Verizon shall:
- Use participant PII obtained from Pace University only for the limited purposes of:
a. conducting follow-up surveys and evaluating program outcomes; and
b. solely for participants who affirmatively opt in, contacting such participants regarding potential job opportunities at Verizon.
- Not use participant PII for solicitation, advertising, or marketing activities unrelated to the purposes above.
- Not combine participant PII with other datasets or re-identify de-identified data.
- Not derive, infer, or attempt to create participant profiles, behavioral analyses, or datasets beyond the limited purposes expressly authorized in this Statement of Work.
Verizon shall not disclose participant PII obtained from Pace University to any third party other than Verizon subcontractors or service providers performing services on Verizon’s behalf in connection with the limited purposes authorized by this Statement of Work, without Pace University’s prior written approval. Verizon may disclose participant PII obtained from Pace University to such subcontractors or service providers as reasonably necessary to carry out the authorized purposes described in this Statement of Work, provided that Verizon gives Pace University prior written notice before any such subcontractor or service provider is granted access to such participant PII, and further provided that each such subcontractor or service provider is bound by a written agreement containing confidentiality, data security, retention, and breach-notification obligations no less protective than those set forth in this Statement of Work. Verizon shall remain responsible for the acts and omissions of any such subcontractor or service provider. For clarity, this paragraph governs only participant PII obtained by Verizon from Pace University and does not restrict Verizon’s collection, use, or disclosure of information that a participant independently provides directly to Verizon outside the Pace-administered VTT program flow, including in connection with a separate job application, recruiting process, or other direct interaction initiated by the participant.
Verizon shall implement administrative, technical, and physical safeguards to protect participant PII from unauthorized access, disclosure, or loss, consistent with industry-standard practices for protecting educational records under FERPA and applicable state privacy laws. Verizon shall not intentionally store participant PII obtained from Pace University outside the United States without Pace University’s prior written notice and an opportunity to object; provided, however, that incidental transmission, routing, or encrypted backup or disaster-recovery processing outside the United States in the ordinary course of Verizon’s systems shall not, by itself, constitute a breach of this provision.
In the event of a data breach or suspected breach involving participant information, Verizon shall notify Pace University’s Office of Information Technology and Office of University Counsel within seventy-two (72) hours and cooperate in mitigating any potential harm.
Verizon shall permanently delete all participant PII obtained from Pace University within ninety (90) days of completing follow-up communications and, if applicable, recruiting or outreach communications with the participant.
