| PURDUE UNIVERSITY RELEASE OF STUDENT EDUCATIONAL RECORDS Frequently Asked Questions The following guidance is provided in accordance with the Family Educational Rights and Privacy Act of 1974 (FERPA). FERPA regulations contain, in part, provisions related to the permissible disclosure of information from student educational records. The questions and answers contained in this document describe common situations in which institutions may, but are not necessarily required to, release student educational records. Also described are situations in which student educational records may not be released. Further questions related to FERPA or this document may be referred to the Office of the Registrar (46133). What is an "educational record?" FERPA defines an educational record as a record that is directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution. Educational records are records maintained in any way, including, but not limited to, handwriting, computer media, print, video or audio tape, film, microfilm and e-mail. There are some exceptions to the definition of educational records, primarily related to law enforcement records, medical records, alumni records, and employment records. What is "directory information?" With certain exceptions, directory information is the only student information that may be released without the written, signed, and dated consent of the student. At Purdue University, directory information includes: name; local address; local telephone number; school; curriculum; classification and credit hour load; dates of attendance; degrees, awards, and honors received; participation in activities and sports; and weight, height, and position of members of athletic teams. Although FERPA regulations begin once a student is attending an institution of higher education, the Graduate School applies these regulations as soon as a student submits an application. What is a "restricted directory listing?" A student may choose to restrict the release of his or her directory information by requesting a restricted directory listing (RDL). A student may request to restrict only local telephone number (option P); only local address and telephone number (A); only honors and degrees awarded (H); only school, field of study, and classification (S); or all of his or her directory information listing (R). If a student has requested to have all of his or her information restricted, the response to an inquiry about that student should be "There is no information available for that individual." Do not say phrases such as "This person is restricted" or "This student's information is blocked," which indicate there is, in fact, information on the individual. How can I tell if a student has a restricted directory listing? Always check to see if a student has a restricted directory listing before answering any questions. A student's restricted status is displayed on screens 0, 1, 2, 3, 6, 7, A, C, R, U, and X in the Student Information System (SITP) and on screen 1 of the Registrar Subscription System (RESS). Restricted status is identified through the following displayed messages: **RESTRICTED** is displayed when no information at all may be released; **RESTR-ADDR** means that the local address and telephone number may not be released; **RESTR-HONORS** means that honors and degrees awarded may not be released; **RESTR-SCHOOL** means that the school, field of study, or classification may not be released; and **RESTR-PHONE** means that the local phone number may not be released. Access to these screens is controlled. If you require information on a student's restricted status and do not have access to these screens, contact the Office of the Registrar (Customer Services, 48581). How "legal" are signed consents to share information with a third party? FERPA allows disclosure of nondirectory information with a written, signed, and dated consent that specifies records that may be disclosed, states the purpose of disclosure, and identifies a party or class of parties to whom disclosure may be made. An example may be a student signing and dating a consent form for his or her instructor to disclose specific grade information to an honor society or potential employer. What student information may I release to a parent or spouse? Unless the student qualifies for dependent status under IRS regulations, only directory information for a nonrestricted student may be released to a parent or spouse. If a parent calls and claims the student is a dependent, refer the parent to the Office of the Registrar (Record Services, 46155). Noncustodial parents have the same rights as custodial parents in the case of a separation or divorce. Even with evidence of dependency, the release of educational records to a parent is only permissible, not required. Encourage the parent or spouse to ask the student for the information, or to obtain a signed release from the student to disclose the particular record(s). If students are 21, how much information about them may we share with their parents, should they make an inquiry? Regardless of the student's age, only directory information for a nonrestricted student may be shared with the parent unless the student is claimed as a dependent as defined by the IRS, or unless the student provides written, signed consent to release the specified information to his or her parents. What do I say to an angry parent or spouse who wants to know educational record information about his or her nondependent student (e.g., grades, schedule information, etc.)? In a pleasant, but firm, tone of voice explain to the parent or spouse that our policy on the privacy of student educational records, based on federal law, will not allow us to disclose the information. You may refer the caller to the Office of the Registrar (Record Services, 46155), or you may contact the Office of the Registrar, and a staff member will contact the parent or spouse to discuss the situation. How do I tell parents or spouses that their student did not graduate? How do I tell a potential employer that the student did not graduate? Degree awarded information is directory information. Thus, for a nonrestricted student, informing a parent or spouse or an organization that "no degree was awarded" to this individual is permissible. Do not provide information on why the degree was not awarded or what degree requirements were not met. Encourage the caller to discuss the situation with the student.
What rights do parents or spouses have to obtain information related to a student's disability services? Records pertaining to a student's disability services are considered educational records. The parent or spouse may receive information about the services available, but the records pertaining to a particular student's services received are treated the same as other educational records. Without the student's signed consent, these records may not be released to a parent unless the student is a dependent as defined by the IRS. How can I confirm the identity of a student over the phone or electronically? The preferred method for confirming identity is the student's personal presentation of a valid Purdue University Identification card, driver's license, or passport (picture ID). Over the phone or electronically, a student's identity may be verified if you ask a full series of verifying questions: full name; local and home addresses; guardian name and address; date of birth; student identification number; school; course load, course numbers, and course titles; grade received in a particular course. If you have access, go into the student's academic record to ask questions about the student's historical information, if needed. If you have any doubt of a caller's identity as the student, you may ask for a written request from the student. Never release information if you doubt the identity of the caller. Should I keep records of disclosures of student information? All requests and disclosures from the educational records of a student must be recorded indicating the parties who have requested or obtained the information and their legitimate interests in obtaining it. This requirement does not apply to disclosures to a parent of a dependent, disclosures pursuant to the written consent of the student, disclosures to a school official with a legitimate educational interest, or disclosures of directory information. What information about a student should I keep and not keep? Remember that any records made in conjunction with the student are considered educational records and are subject to review by the student. In deciding whether to keep a particular record on a student, refer to your departmental guidelines, if any. Consider the format in which your department or school maintains records and what records you need to do your job. In a student's advising file, for example, it is wise to keep the most recent progress report and the final candidate certification record, if applicable. Do FERPA regulations apply after a student graduates or leaves the University? Yes, all FERPA regulations apply during the lifetime of the student, but only to records created while the individual was a student (e.g., transcripts). What information may I release to a friend of a student who says the student gave him or her permission to receive the information? Only directory information of a nonrestricted student may be released. Nondirectory information may be released with a signed statement from the student authorizing the release of specific information to a designated individual, but release of this nature is not practiced on a routine basis.
What may I tell someone who calls me asking for a student's schedule for the purpose of contacting that individual because of an emergency? For a restricted student, tell the caller there is no information available on that individual. For a nonrestricted student, tell the caller that you cannot release the student's schedule information and refer the caller to the Office of the Dean of Students (41747). May I give grade point averages or grade information to an employer inquiring about a student, if that employer or our Center for Career Opportunities already has a copy of the student's resumé? GPA or grade information may be released to an employer or potential employer only if the student has signed a statement allowing the release of resumé information to an employer or potential employer AND the student's resumé contains the specific index or grade information requested. Additional information about any educational records or personally identifiable information may not be supplied without the written consent of the student. Verification of specific information supplied by the student on the resumé may be permissible. May I include nondirectory information in a letter of recommendation for a student? You may include this information only if the student provides written consent for the individual writing the letter of recommendation to release such information. If a former student has applied for a position in my department, may I view his or her record? No. Accessing a Purdue student's record on-line for noneducational purposes, such as potential employment, is not permissible. Request a transcript from the student as part of an employment process. May I request a data file of students' names and local addresses for mail merge purposes? For legitimate educational purposes, you may request a data file instead of lists or labels, but remember to destroy the file immediately after its use. Data files of this type of information become quickly outdated, as students move, change schools, restrict their directory listing, or, in those unfortunate cases, when students die. May my department post pictures of students? Purdue University does not currently define photographs as directory information. Therefore, the personally identifiable record of a photograph may be posted only with the written consent of the student. May I release information about a student to a faculty member interested in that student's previous grade(s) in a particular course(s)? No. For individual students, specific grade information should only be accessed by his or her adviser for the purpose of advising. However, researching the academic achievement of a cohort of students during their progression through a particular course series may be permissible for program of study planning purposes. What student grade information may an adviser provide to an instructor? An adviser may not disclose individual student grades for previous coursework to a professor. In the classroom, the professor's role is that of instructor, not academic adviser. The adviser may disclose to an instructor whether or not a student has met the stated prerequisites for the instructor's course, but not grade information. If the professor has concerns about the student's academic performance in the current course, discussion is encouraged between the professor and the student, with advice from the student's academic adviser. Summary information for students in a particular course may be disclosed through the Office of the Registrar's research area or through your department's student DSS contact. What information may I release regarding the application status of a student? Although application materials are not addressed by FERPA regulations, the Graduate School treats application status as nondirectory information and releases this information accordingly. If a student makes an inquiry regarding his or her application status, has been properly identified, and has been accepted for admission, the Graduate School will respond to the student's inquiry. However, if the application has been denied or still is being processed, the student will be referred to the department, and the Graduate School will give no response. What may I tell faculty about the students in their classes, and how do I explain that to them? Summary information about a particular class (e.g., average GPA) and directory information for nonrestricted students (e.g., school, credit hour load) may be provided to the faculty member. For individual nondirectory information, the faculty member who is not serving in a role as an adviser should be encouraged to ask the student directly for the desired information. May I give a faculty member the name and home address of the top 10% of students in his or her class, so he or she can send each student a congratulatory letter? If the request is considered to be of legitimate educational benefit to the student, it may be acceptable to provide the information to the faculty member. Contact the Office of the Registrar (Data Services, 46125) or the Graduate School (42600) for data request procedures. It is preferable if the faculty member asks the students for their home addresses for the purpose of mailing letters to the students after grades are posted. May I post students' grades using full student identification numbers or names? No. You may not use the student's full student identification number and should not use a portion of the student identification number when posting grades. Randomly assigned, unique identification numbers are a preferred method. How should I distribute students' exams, papers, grades, etc.? This should be done confidentially. Take care that the student's grade does not appear on the front page of the exam or paper; use envelopes or enter grade information on the last page. Do not allow any student access to other students' grade information; do not pass your grade book around the class for students to view their and their peers' grades. Using the web is fine as long as student identifiable information is not associated with the grades listed. Consider assigning each student a random number, and keep the master list confidential. What rights do students have regarding their information being displayed on the web? Student information should be handled as confidentially on the web as it is off the web. Do not post SID numbers with grades on the web or post any other personally identifiable, nondirectory information without the student's written consent.
May Social Security numbers or student identification numbers be left out on desks in semi-public areas overnight? Any personally identifiable educational records should not be kept in open view when unattended. This could allow the inappropriate disclosure of confidential student information. This information should be kept in a secure environment (e.g., locked drawer) when unattended. What should I do if one of my students requests to review his or her educational records? Any educational records you maintain on a student are subject to the student's inspection. A student has a right to inspect and review his or her educational records within 45 days of a written request being presented to the authorized custodian of the records in question. (See University Regulations, Part 6, Section IX for a listing of custodians of student records.) Once a student makes a request to see his or her educational records, no records may be removed from his or her file. Educational record requests can be referred to the Office of the Registrar (46155). As an instructor, am I obligated to release information about an athlete's academic performance when requested by the Department of Intercollegiate Athletics? Student athletes sign a form authorizing instructors to release information about their academic performance to academic officers in the Department of Intercollegiate Athletics. Release of such information by faculty is helpful for advising purposes, but is voluntary on the part of the faculty member. May I release the names of current or past study abroad participants to the media? Only with signed consent from the student can this information be released. Participation in study abroad is tied to the academic record of the student, which is nondirectory information. May I release contact information of a student who is currently abroad? Only contact information listed by a nonresident student, such as local address and phone number, may be released without signed consent from the student. If the student has not requested a restricted directory listing and lists his or her address abroad as the local address, this would be considered directory information and may be released. Are there any special circumstances or legal issues of privacy pertaining to international students? FERPA does not distinguish between international and noninternational students; the privacy of all students' records is protected. There may be special processes (e.g., international certifications) that occur pertaining to international students. Are there any situations when we must disclose information? A situation in which we must disclose information from an educational record is when the student requests information pertaining to him or her. There are certain exceptions to the information we must disclose to the student including, but not limited to, parents' financial records and confidential letters of recommendation, if the student has waived his or her right to inspect those letters. Information from a student's educational record must also be disclosed in certain cases involving subpoenas.
Concerning the handling and storage of medical information and psychological reports, when is it an "educational record" and when is it a "medical record?" While some medical records may also be considered educational records, all records maintained by the University containing medical information about a student should be treated confidentially and only released with written, signed permission from the student. What may I release to a scholarship organization requesting the names and local addresses of students from a specific region eligible for a particular scholarship? Do not release the information to the organization. Instead, ask for information about the scholarship and provide the information to the students yourself, or refer the query to the Division of Financial Aid (45050), the Office of the Registrar (46125), or the Graduate School (42600). Other avenues are available to address the needs of students and organizations without releasing student information outside the University. For example, student local address information may be released to Printing Services, where labels may be printed and affixed to the organization's materials. The materials could then be mailed to the students. May I obtain the GPA of a student in order to nominate that student for an award when the nomination form requires the student's GPA? Unless you have access to student information in your professional role (e.g., as an adviser), and in that role you have the responsibility of considering nominees for awards, you will need to ask the student for a signed statement releasing the information for the stated purpose. With a signed release from the student, you may contact the student's adviser or the Office of the Registrar (Record Services, 46155) to obtain the student's grade index. What information may I provide to a scholarship donor requesting enrollment, aid, and grade information? You may release scholarship criteria information to a scholarship donor if the student has signed a release statement that specifies the information that may be disclosed to the scholarship donor. Should I have work-study students handling student information? If work-study students in your area are assigned duties that require the handling of student information, provide training to the student workers on the privacy of student educational records. Have each student sign a statement that he or she understands and will follow the policy on the privacy of student educational records. (Contact the Office of the Registrar, 46155, for a sample statement.) Who should I call for student telephone numbers and for student academic records? If your request is for a legitimate educational benefit to the student, you may contact the Office of the Registrar (Record Services, 46155 or Data Services, 46125), or the Graduate School (42600). Who can I call for more information on student privacy? Call the Office of the Registrar for questions related to:
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