UW Privacy Office

Appropriate Collection and Use of Youth Data

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Annually, the University of Washington (“UW”) engages with over 94,000 youth in more than 200 programs. The Office of the Youth Protection Coordinator and the UW Privacy Office jointly developed the policy and related resources that appear on this page as a privacy framework for youth as a more vulnerable population.

Privacy Policy for UW Youth Programs 

The Privacy Policy for UW Youth Programs supplements and further interprets the privacy requirements in UW Administrative Policy Statements 2.2 (University Privacy Policy) and 10.13 (Requirements for University and Third Party Led Youth Programs).

Applicability

The Privacy Policy for Youth Programs applies to certain programs or events that primarily target youth and are controlled and operated by the UW, as described below.

For the purpose of the policy and related resources, “UW Youth Programs” independently make decisions about and/or determine the means and purpose of their program or event (including administration, operations, activities, personal data processing, etc.).

UW Youth Programs may include a variety of programs and events such as college readiness and tutoring programs, sports clinics, and summer camps, among others. UW Youth Programs must embrace privacy-by-design by aligning their practices with the policy and the related resources that appear below.

Notably, the policy does not apply to programs or events that involve:

  • A general audience with people of all ages (such as graduation ceremonies and football games);
  • Youth who are supervised by a parent, guardian, teacher, or other non-UW chaperone;
  • Students who are admitted to the UW or registered in courses offered by a UW academic program;
  • Personal data collected from individuals in the European Economic Area;
  • Human Subjects who participate in IRB-approved research;
  • Patients who receive healthcare services;
  • Only renting or making available UW facilities to non-UW organizations that primarily target youth; and/or
  • Non-UW organizations that jointly (with UW) or solely make decisions about and/or determine the means and purpose of the program or event (including its administration, operations, activities, personal data processing, etc.)

For studies or evaluations that are neither IRB-reviewed nor approved, please contact the Office of the Youth Protection Coordinator via email at uwminors@uw.edu for additional guidance.

If you are unsure whether your program or event must follow the policy and use the related resources that appear below, please consult the Frequently Asked Questions or contact the Office of the Youth Protection Coordinator via email at uwminors@uw.edu for assistance.

Privacy Guidelines for Engaging Youth Virtually

The Privacy Guidelines for Engaging Youth Virtually is intended to assist UW workforce members in safeguarding the privacy of youth when engaging with youth online or in virtual programs.

Privacy Resources for UW Youth Programs

To operationalize the youth-related privacy protections described in the Policy, UW Youth Programs must:

  • Align their practices with the policy;
  • Utilize the Privacy Notice for UW Youth Programs;
  • Utilize the Privacy Consent Form Template for UW Youth Programs; and
  • Explore privacy considerations in the Frequently Asked Questions.

Providing the Privacy Notice for UW Youth Programs 

Privacy notices create transparency about privacy practices, an important part of the relationship between a UW Youth Program and its constituents. UW Youth Programs must provide the Privacy Notice for UW Youth Programs to parents, guardians, and participants who have reached 18 years of age when personal data is first collected or as soon as feasible thereafter.

Steps for Using the Privacy Notice for UW Youth Programs

Step 1: Understand privacy-related commitments and obligations

  1. Read through the Privacy Notice for UW Youth Programs to understand the privacy-related commitments made to parents, guardians, and participants who have reached 18 years of age
  2. Ensure your data processing activities are consistent with the statements in the Privacy Notice for UW Youth Programs

Step 2: Provide the Privacy Notice for UW Youth Programs

  • Use the most current version of the Privacy Notice for UW Youth Programs by:
    • Download and print the Privacy Notice for UW Youth Programs [pdf] immediately before dissemination (it will be current as of the date of your download). You may also include the Spanish version of the notice [pdf].
    • Including a visible and prominent link to the Privacy Notice for UW Youth Programs on any webpage where personal data is collected in connection with a UW Youth Program; and/or
    • Including a visible and prominent link to the Privacy Notice for UW Youth Programs in the body of email messages through which your UW Youth Program collects personal data.
  • Keep the Privacy Notice for UW Youth Programs distinct and separate from other materials that your UW Youth Program may disseminate.
  • No action is required from individuals who receive or access the Privacy Notice or UW Youth Programs (it is informational only).

Step 3: Review and monitor

  • Document when and how the Privacy Notice for UW Youth Programs was provided or made available.
  • Continually assess and confirm that all personal data processing activities in your UW Youth Program align with the Privacy Notice for UW Youth Programs.

In addition to creating awareness about privacy practices, UW Youth Programs must provide opportunities for parents, guardians, and participants who have reached 18 years of age to make choices about certain data processing activities that warrant additional reflection.

UW Youth Programs must utilize the Privacy Consent Form Template for UW Youth Programs (click to download as a Word document). When obtaining consent, UW Youth Programs must ensure that individual choices are made affirmatively. Review the Frequently Asked Questions below for more information about affirmative consent.

Steps for Creating and Using a Privacy Consent Form

Step 1: Determine which data processing activities require consent

  • Read the Privacy Notice for UW Youth Programs and determine whether any data processing activities in your UW Youth Program require consent.
  • If any data processing activities require consent, proceed to Step 2. 
  • If no data processing activities require consent, no further action is required.

Step 2: Create a customized privacy consent form for your UW Youth Program

  • Read the Privacy Consent Form Template for UW Youth Programs which includes sample text that you can repurpose;
  • Delete any boxes with text describing data processing activities that do not occur in your UW Youth Program;
  • For any of the remaining boxes that contain bulleted descriptions of personal data, delete bullet points that do not apply to your actual data processing (if any);
  • Populate all yellow-highlighted placeholders based on the nature of your UW Youth Program’s data processing activities;
  • Make cosmetic and formatting revisions only (no substantive changes), as needed;
  • Delete template instructions contained in track comments; and
  • Finalize your UW Youth Program’s privacy consent form.

Step 3: Solicit consent using your UW Youth Program's finalized privacy consent form

When to solicit consent

  • Solicit consent when your UW Youth Program provides the Privacy Notice for UW Youth Programs; or
  • Any time after providing the Privacy Notice for UW Youth Programs but before engaging in the data processing activity described in your finalized privacy consent form (i.e., ‘just-in-time’ consent).

How to solicit consent

Your finalized privacy consent form must be distributed to parents, guardians, and participants who have reached 18 years of age through one of the approaches described below. Regardless of your selected distribution method, the text of your finalized privacy consent must be distinct and separate from any other materials your UW Youth Program may disseminate.

  • Paper: Print and manually distribute your UW Youth Program’s finalized privacy consent form. Collect completed and signed consent forms.
  • Email: First, make your finalized privacy consent form available online as a downloadable Word document or .pdf file. When sending your email solicitation, include a link to your UW Youth Program’s finalized privacy consent form. Ensure that individuals are not required to log into any account in order to access your finalized privacy consent form. Ask email recipients to download, print, sign, scan, and return their consent forms via email.
  • Webpage or Online Tool: Your webpage or online tool must display the text from your UW Youth Program’s finalized privacy consent form. Be sure that (a) individuals are not required to log into any account in order to access your consent solicitation, and (b) a date and time stamp are digitally affixed to each submission. Use the modified language that appears in italics below and, in place of the manual checkboxes in the Privacy Consent Form Template, use online check boxes that are unchecked as a default.

Before clicking “Submit” below, please confirm the following:

  • I have read and understood the Privacy Notice for UW Youth Programs available at https://www.washington.edu/privacy/notices/youth/;
  • I understand that I am not required to give my consent; and
  • I agree to the processing described above for which I marked “Yes, I give my consent.”

Participant’s name: __________________________

Parent or guardian’s name (if participant is not yet 18): __________________________

[Submit Button]

Step 4: Store and document consent obtained from individuals.

  • Securely store completed consent forms and online submissions.
  • Document when and how prior consent was solicited and obtained by your UW Youth Program

Step 5: Honor individual consent

  • Identify the population that has actually given consent and limit the related data processing activities to just that population.
  • Be sure an individual’s consent is honored throughout all aspects of your UW Youth Program’s personal data processing.

Glossary of Privacy Terms

See the UW Privacy Office’s Glossary of Privacy Terms for definitions of terms that appear in the Privacy Policy for UW Youth Programs, related resources, and this webpage.