16-4 Family Educational Rights and Privacy

1.0 Policy

1.1   It is the policy of the University to comply with the Family Educational Rights and Privacy Act of 1974 (FERPA).  Generally, FERPA gives students and former students the following rights:  (1) to inspect and review their education records, (2) to request that the institution correct education records that the student believes are inaccurate or misleading, and (3) to control the disclosure of the student's education records.  This policy provides measures intended to protect these rights and to otherwise ensure compliance with FERPA.

2.0 Office of the Registrar

2.1   The Office of the Registrar shall be responsible for implementing this Policy.  Any questions regarding an individual student's rights, the University's responsibilities, or any other matter under FERPA shall be addressed by the Office of the Registrar.

3.0 Requests to Inspect or Correct Education Records

3.1   Any request by a student or, if applicable, a student's parent, to review or correct the student's education records shall be submitted to the Office of the Registrar, which shall arrange for such inspection or correction as permitted by FERPA.  The Office of the Registrar shall maintain appropriate records of all requests for inspection or correction of education records.

4.0 Confidentiality of Education Records

4.1   With some exceptions, FERPA prohibits the University from disclosing a student's personally identifiable education records to third parties without the student's written consent.  A record is personally identifiable to a student if it expressly identifies the student on its face by name, address, ID number, or other such common identifier.  A record is also personally identifiabl if it includes other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty.

4.2   Notwithstanding Section 4.1, the University may disclose directory information without the student's consent.  Director information is information in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed.  Within those parameters, the Registrar, in consultation with the Chief Privacy Officer and the General Counsel, may select the specific facts about a student to be included in directory information. A student shall be given the opportunity to opt out and block the release of their own directory information.  A student who wishes to opt out must file the appropriate form with the Office of the Registrar.

4.3   All University faculty, staff and students have an obligation to protect the confidentiality of a student's personally identifiable education records as required by FERPA.

4.4   All faculty as well as all staff who have authorized and systematic access to education records in the course of performing their employment responsibilities must be committed to maintaining the confidentiality of personally identifiable education records.  For that reason, all such persons are required to sign annually a statement affirming that they will comply with FERPA's non-disclosure requirements.  The Office of the Registrar, in consultation with the General Counsel, shall approve the statement and shall otherwise implement this requirement as appropriate.  The currently approved statement shall be made available on the Registrar's website.

5.0 Training

5.1   The University shall make available FERPA training materials to University personnel.  Participation in FERPA training is strongly encouraged for all personnel, especially faculty and student advisors.

6.0 Duration and Effective Date

6.1   This University Policy is revocable at any time at the discretion of the President and without notice.

6.2   This University Policy is effective immediately.

Signed by President M. Roy Wilson  December 21, 2016