Family Educational Rights and Privacy Act of 1974

(F.E.R.P.A) ADMINISTRATIVE AFFAIRS BOARD APPROVED MAY 2, 1995

• I. General Guidelines
• II. Student Applicant Records
• III. Student Academic Records
• IV. Student's Personal File
• V. Student Medical and Psychological Records
• VI. Student Development Files
• VII. Student Financial Aid Office Records
• VIII. Student Financial Records
• IX. Student Data Stored on Computer Files
• X. Student Records on Microfilm
  

  I. General Guidelines Governing Keeping of Student Records
  

  A. Records are kept in the various offices of the College in the interest of its students and alumni. It is the intention of the College that the data entered and the documents kept in each student file as well as any subsequent release of information contained within it should be determined by what is in the best interest of the student. Hope College determines to reflect this attitude in its records-keeping policies and consequently has adopted the following guidelines for the creation and maintenance of student records in its offices.
  
  
  B. The College supports the Family Educational Rights and Privacy Act of 1974, and this statement of policy incorporates the rights accorded and the privacy guaranteed the student by this Act.
  
  
  C. Records information is classified in two categories, public and confidential.
  Public or directory information includes the following data:
  • name
  • local and permanent address
  • telephone number
  • name of parent or guardian
  • dates of attendance
  • high school attended
  • teacher certification
  • degrees and dates of degrees
  • awards and honors received
  Unless the student requests in writing that such public information be withheld, public/directory information is available to anyone. It should be noted, however, that the College does try to exercise some restraint in the release of public information and tries to insure that such information is not released indiscriminately, without regard for the student's welfare. All other information collected and stored on a student is considered to be confidential. The confidentiality of this information is guaranteed the student and will be released only upon the written consent of the student.
  D. The College wishes to eliminate any aura of secrecy and mystery about a student's record. Faculty and College personnel are encouraged to be open and forthright with students and therefore are urged to share with the student all evaluative statements entered into a student's file.
  E. The College will open to students all official educational records and all documents entered in their files after January 1, 1975. For records created and documents filed prior to January 1, 1975, the College will protect the confidentiality extended to third parties entering information on the student and will allow inspection of such documentation only upon the written consent of the person entering the information or document.
  F. Upon review of his/her file, a student may challenge the accuracy of anything contained in the record. The request to challenge any item of information must be submitted in writing to the administrative head of the office in which the record is kept. Upon receipt of such a request, the administrative officer will arrange for a hearing where the challenge will be heard and adjudicated. Should the student be unsuccessful in his/her challenge of an item of information, he/she will be allowed to enter his/her own version of the item in question in his/her file.
  G. A student may waive his/her right to know what is contained in a document in his/her file. A waiver form is available in the Registrar's Office, and the completed form will be attached to the pertinent document. This provision is particularly relevant to letters of recommendation.
  H. When subpoenas are received for student records, the college will notify students involved of the receipt of the subpoena and of the particular records being subpoenaed. This notification is sent to the last permanent address on file for the student. Students are notified, further, that if nothing is heard form them within ten days of the receipt of notification of the subpoena, the records will be forwarded to the party issuing the subpoena.
  II. Student Applicant Records
  A. Definition: A file is created by the Office of Admission for those students who apply for admission to Hope College. This file is under the supervision of the Director of Admissions. There are three types of applications; the file contents will vary accordingly as follows:
  1. Non-degree Seeking
  Non-degree seeking application requesting name, address, basic bio- demographic information.
  2. Readmit
  Readmit application requesting basic bio-demographic information and approval/denial conditions of admission by Registrar, Dean of Students, and Director of Financial Aid.
  3. Degree-Seeking
  
  a. Degree-seeking application for admission requesting basic bio-demographic information and a recommendation by the high school counselor.
  b. Required essays.
  c. High school and/or previous college transcript(s).
  d. Aptitude score reports (ACT, SAT).
  e. Letters of reference from counselors, teachers, pastors, etc.
  f. Pertinent correspondence including letter of admission.
  g. Interview reports.
  h. Admission committee evaluation comments.
  i. Other documents provided by the student or relevant to the applicant's situation.
  If applicants enroll at Hope, their applicant files become their personal files and are subsequently sent to the Office of the Registrar.
  B. Access to Student Application File
  1. Access is granted to non-degree seeking and readmit applicants at any time.
  2. Access is granted to degree seeking applicants if the student is offered degree seeking admission. This access is provided from the time of admission until the file is destroyed. Files of admitted applicants who do not enroll at Hope College are destroyed four years after the applied for enrollment date.
  3. Access is granted to college staff and faculty who either are involved in the recruitment process or who require access to fulfill their college responsibilities. The Director of Admission shall determine "need for access" for these personnel.
  4. Access by others is restricted to those who have received written authorization by the applicant, or who have obtained a court order or subpoena.
  C. Release of Information in the Student Applicant File
  1. Public information is available on request, but is not released indiscriminately. This information may be withheld at the applicant's request.
  2. Confidential information shall be released only with the applicant's written authorization.
  
  III. Student Academic Records
  A. Definition: Student academic records are kept by the Registrar and are defined as information contained on the student's permanent record or transcript and those documents which support the information on that transcript. Transcripts are a complete, unabridged copy of a student's academic work. Official transcripts bear the signature of the Registrar and the seal of the College. The following information is contained on the permanent record or transcript:
  Public Information:
  • Name of the student
  • Legal permanent address at time of admission
  • Date of admission to Hope College
  • Dates of attendance
  • High school attended
  • Previous college or university attended
  • Teacher certification
  • Major
  • Degrees and dates of degrees
  • Graduation honors (cum laude,etc.)
  
  Confidential Information:
  • Grades
  • Semester and cumulative gradepoint average
  • Social Security Number
  B. Access to Academic Records
  1. Access is given to the student.
  2. Access is given to faculty and administrative staff to assist them in the ischarge of their responsibilities.
  3. Access is given to certain governmental agencies as specified in the Family Educational Rights and Privacy Act of 1974.
  4. Access is given to all others, whether this access be in person or transcript form, only upon the written consent of the student.
  5. A record of access to the student's academic records will be kept by the Office of the Registrar and will be filed in the student's personal file.
  C. Release of Academic Records Information
  
  1. Unless a written request to the Registrar is received that directory information not be released, public or directory information is available upon request, but this information will not be released indiscriminately.
  2. Confidential information will be released upon the written authorization of the student.
  3. A transcript of the student's academic record is released only to the student and to those whom the student authorizes. The following policies apply to the issuance of transcripts:
  
  • If possible, transcripts are issued the same day or the day following the receipt of the request.
  • Transcripts are withheld at the request of the Business Office if the student has not met his/her financial obligations to the College.
  IV. The Student's Personal File
  A. Definition: The student's personal file is kept by the Registrar and is defined by its enclosures which are as follows:
  
  1. Reports from the student's faculty advisor which record the advisor's communication and dealings with the student.
  2. Reports from the Dean of Students' staff on their contact with the student and the nature of his/her progress.
  3. The student's discipline record. If included in the student's record, this report will be a summary received from the Dean of Students' Office.
  4. Pertinent data from the Admissions Office:
  
  a) application;
  b) letters of reference;
  c) high school principal or counselor reference letter and previous institutions attended;
  d) high school transcript;
  e) previous college transcripts;
  f) letter of admission;
  g) pertinent correspondence or other documents which the Admissions personnel deem worthy to be kept in the file.
  
  5. All documents which verify or substantiate information contained on the permanent academic record.
  6. Correspondence which a faculty member or administrator wishes to enclose.
  7. Correspondence received by the College from the student which has been requested to be kept in the file.
  8. A dated and signed record of access to the student's academic records and personal file.
  
  B. Access to the Student's Personal File
  
  1. A student will be given access to his/her personal file. Documents in the file dated prior to January 1, 1975, will be open to his/her inspection only if prior approval of the party who entered the document is received. All documents submitted after January 1, 1975, excepting those to which the student has waived his/her right to access, will be open to the student.
  2. Faculty and administrative personnel have access to the student's personal file if such information is necessary in the discharge of their respective responsibilities.
  3. Access will be denied all others unless authorized in writing by the student.
  
  C. Release of Information in Student's Personal File
  
  1. Public information is available upon request but may be withheld if the student so requests.
  2. Confidential information is released only upon the written consent of the student.
  
  V. Student Medical and Psychological Records*
  A. Definition: Medical Records -- For admission to Hope College, the student is required to submit to the College on a standardized form a report from his/her physician of his/her record. This report is kept on file by the Health Clinic and is to be used only in connection with a student's request for medical care.
  Psychological Records -- The Counseling Center student records are in the sole possession of the Counseling Center under the supervision of the Director of Counseling and therefore cannot be specifically defined.
  B. Access to Medical Records
  
  1. Access to medical records is limited to Health Clinic staff.
  2. The student is granted access to their medical records upon written request for a review of the record, or for a copy of the record. For a review of the medical record, contact the Assistant Dean for Health and Counseling.
  
  C. Release of Information in Medical Records.
  

  These records are strictly confidential, and no information from these records is to be released without the expressed written consent of the student. The student may discuss the purpose of releasing the record or any other concerns related to the record with the medical staff of the Health Clinic.
  

  D. Access to Psychological Records
  

  1. Access to psychological records is limited to Counseling Center staff.
  2. The student may request permission to reveiw the information in their Counseling Center record.
  3. The student has the right to have his/her psychological record examined by another mental health professional of his/her choice.
  

  E. Release of Information in Psychological Records
  
  These records are strictly confidential and no information from these records is to be released without the expressed written consent of the student. For psychological records, the Director of Counseling or a designee shall determine how the record is to be released; whether it is copied and forwarded, summarized or reviewed to offer a professional opionion, or reviewed with a third party.

  *The information under Student Medical and Psychological Records is pending final approval of the Administrative Affairs Board (04-04-2003).

  
  VI. Student Development Files
  A. Housing File
  
  1. Definition: The housing file is created to hold housing documents of a student who lives on campus. The file is created by the Associate Director of Housing and Residential Life. The file's purpose is to provide a record of housing materials and a place where student requests and College responses can be kept. Included in this file are the following:
  
  a. Housing cards
  b. Room Condition sheets with Resident Directors
  c. Housing Agreement forms with Resident Directors
  d. Room Change forms
  e. Off-campus/commuter requests
  All forms listed above are signed and completed by students.
  
  2. Access to the file
  
  a. Students have access during normal business hours.
  b. Access to other persons is limited to those individuals who are working directly with housing issues.
  c. There is no release of information to third parties unless the student is under the age of 18.
  
  B. Judicial File
  
  1. Definition: The judicial file is created to hold information, incident reports, and decision letters about student behavior accused of violating a College policy.
  A hard copy of each record exists consisting of:
  
  a. Hearing cover sheet
  b. Preliminary Hearing Form
  c. Incident Report
  d. Letter outlining the results of the hearing are placed in the file and a copy is also filed alphabetically.
  
  A computer file exists which contains a summary of all incidents. The record includes student plea, verdict, and sanction if necessary. The file also tracks completion of community service hours.
  
  
  2. Access to the file
  
  a. Students have access to their files during normal business hours.
  b. Students have copies of the materials in their files.
  c. Access to other persons is limited to the Dean of Students, Vice President of Student Development,Director of Housing and Residential Life, Hearing officers, and support staff as designated by the Dean of Students. If other persons are requesting information students must sign a release.
  d. Members of the Student/faculty Judicial Board will be informed of files which exist should a student be found guilty of a violation which is heard by the Board.
  
  C. Residential Life Employment Files
  
  1. Definition: The Residential Life employment file is created to hold Resident Assistant application, references, letter of appointment, and Resident Assistant Contract.
  2. Access to the file
  
  a. Students have access to all materials in the file with the exception of references if they waived their right to see them during normal business hours.
  b. Access to other persons is limited to the Dean of Students, Director of Housing and Residential Life, Associate Director of Housing and Residential Life, and Resident Directors.
  
  D. Counseling and Health Center Files
  
  Files kept by the Counseling and Health Center on students are not required to be covered by FERPA. Each office adheres to strict professional and legal standards of access.
  
  E. Career Services Files
  
  1. Definition:
  
  a. Education students pursuing teacher certification have credential files which contain information for the Department of Education regarding their application and academic work. Additionally, the credential file contains information applicable to pursuing a teaching position. These materials include:
  
  • Authorization form which allows students to choose if they want to waive the right of access to these documents; additionally, they may sign a release granting access to these records by third parties.
  • Information sheet
  • Student Teaching Evaluation
  • Faculty Coordinator Report from student teaching
  • Letters of Recommendation
  • Resume
  
  b. Placement files exist for those candidates seeking non-teaching related opportunities and contain the following documents: authorization form, letters of recommendation, and resume. This material is used by students/alumni as a part of the job application process.
  
  2. Access to the files
  
  a. Students/alumni have access to all the materials in the file with the exception of references for which they have waived the right of access.
  b. Access to files by third parties is granted:
  1) if students/alumni sign the consent form granting access to records,
  2) if the third parties are found on the authorization form in their file.
  
  VII. Student Financial Aid Office Records
  A. Definition: A file is created by the Office of Financial Aid for those students who apply for financial aid from Hope College. This file is under the supervision of the Director of Financial Aid. The file is defined by its contents which normally are as follows:
  
  1. The student's financial aid application(s).
  2. Copies of correspondence from both the student and the parent(s).
  3. Copies of both the student's and the parents' federal tax returns.
  4. Student loan applications.
  5. Audit trail documentation as to the disbursement of aid to the student's account.
  6. All other supporting documentation related to the determination of the student's financial aid eligibility.
  7. Interview Logs documenting pertinent conversations or counseling sessions with either the student or the parent(s).
  
  B. Access to Student Financial Aid File
  
  1. In the case of a dependent student (dependent as defined by the IRS), both the student and his/her custodial parent(s) or legal guardian have access to all materials contained within the student's file.
  2. In the case of a self-supporting student over the age of 18, only the student has access to materials contained within the student's file.
  3. Access to others is limited to the staff of the Financial Aid Office, to those whom the student, custodial parent(s), or legal guardian so authorize by written consent, or to those individuals who have obtained a court order or subpoena.
  
  C. Release of Information in the Student Financial Aid File
  
  1. All information in this file, other than directory information listed above, is strictly confidential and is released to other persons or agencies outside of the college only upon the written authorization of the student or his/her custodial parents or legal guardian.
  2. The following information will be available from the Financial Aid Office to personnel in the Admissions Office and other faculty and staff who are involved in admissions or who have a specific need to know in connection with their college responsibilities:
  
  a. Whether or not an application for financial aid has been filed and whether or not the application has been fully completed.
  b. Whether or not a need determination has been made and information as to the amount of demonstrated financial need.
  c. After a financial aid award letter has been sent, the specific amount and packaging of aid. If a partial award has been made, the amount of unmet need will also be furnished.
  d. After a letter has been sent indicating that financial aid is not to be granted, the fact that this decision has been made.
  e. Whether or not the offer of financial aid has been accepted or declined.
  
  The faculty and staff members who need this information must initiate and justify their request to receive this information. It is also understood that persons who receive this information must be judicious in the use of said information.
  
  VIII. Student Financial Records
  
  A. Definition: Student financial records are kept in the Student Accounts Office and are defined to be that information pertaining to the financial activity generated by the student. Also, long distance phone records are held in the Student Account Office. Information recorded in these records are:
  
  • Name of the student
  • Social Security number
  • Charges and payments
  • Federal and institutional loans
  • Documentation and correspondence with students, parents, or staff.
  • Long distance phone numbers called by the student
  
  B. Access to Financial Records
  
  1. Access is given to the student.
  2. Access is given to College staff and faculty to assist them in fulfilling their responsibilities.
  3. To assist the custodial parent(s) or legal guardian in the payment of a student's account, access is given to the parent(s) of the student, unless the student has requested with a written request to restrict parent(s) from access to the financial records.
  4. Parent(s) of independent students do not have access to financial records.
  5. Access to phone records is restricted to the student and college staff.
  
  C. Release of Financial Information
  
  1. Directory information is released upon request but is not released indiscriminately.
  2. Confidential information is released only to authorized college personnel, to the student, to the student's custodial parent or legal guardian, or to anyone whom the student authorized to have such information.
  
  IX. Student Data Stored on Computer Files
  
  A. Definition: Biographical, academic and financial data of enrolled students are stored in the computer. The file contains approximately 100 data elements per student. These elements are listed in the Hope Student Information System Data Elements Dictionary on file in the Registrar's Office. Most of the elements are taken from the application for admission to Hope College and the other supporting documents submitted by the student for admission consideration. A listing of the data elements and the data stored is periodically sent to students for their information and update. The Registrar is responsible for the maintenance of the computerized student information system.
  B. Access to Computerized Information
  
  1. The same policies which apply to the accessing of the permanent record card and personal file apply to accessing computerized information.
  2. The student will be informed periodically of all the information about him/her which is stored in the computer and will be given opportunity to correct any inaccurate data.
  
  C. Release of Computerized Information.
  
  1. Directory information is released upon request but is not released indiscriminately.
  2. Confidential information is released only to authorized college personnel, to the student him/her self or to anyone whom the student authorizes to have such information.
  
  X. Student Records on Microfilm
  
  For the purposes of security and paper storage reduction, the Registrar transfers to microfilm the permanent academic record and the student's personal file. The permanent academic record is presently kept in storage; the contents of the personal file are kept for five years after a student's termination at the College. Once the file is microfilmed the actual contents of the file are then destroyed.
  This statement is prepared in compliance with the Family Education Rights and Privacy Act of 1974 and every student is provided a copy upon request. Questions relative to any of the records in the offices listed should be directed to the administrative person who has supervision over the file created.
  
  Jon J. Huisken
  Dean of Academic Services and Registrar
  2/1/95