Privacy and Release of Student Education Records University Policy

The Ohio State University – University Policies policies.osu.edu/ Page 1 of 8

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

Responsible Office Office of the University Registrar

POLICY

Issued: 01/01/1974

Revised: 07/01/2015

The university is committed to protecting education records of students to the extent required by law.

Purpose of the Policy

To comply with the Family Educational Rights and Privacy Act of 1974 (FERPA), as amended, which sets forth

requirements designed to protect the privacy of student education records.

Definitions

Term

Definition

Custodian

Individual or unit that maintains any student-identifiable records.

Directory

Information

Term defined under FERPA; which allows certain information about students to be published or released by the

institution without consent of the student.

Education

record(s)

A. The meaning of "education records" is, with certain exemptions as listed below, those records, files, documents,

and other materials that contain information directly related to a student, and are maintained by any employee or

contractual agent of the university.

B. The following categories of information are exempted and are not considered to be "education records:"

1. Records made by university personnel that are in the sole possession of the maker and are not routinely

accessible or revealed to any other person.

2. Records created and maintained by the Office of Public Safety for law enforcement purposes.

3. Medical and counseling records used solely for treatment. (Medical records may be personally reviewed by

a physician of the student's choice.)

4. Post-enrollment records related to a former student that do not pertain to an individual’s previous

attendance (alumni records). Records that pertain to an individual’s previous attendance as a student,

regardless of when they were created or received by the institution, are education records.

Family

Educational

Rights and

Privacy Act

of 1974

(FERPA)

Federal law governing access to records maintained by educational institutions and the release of information from

those records. FERPA requires the institution to send a notice to enrolled students annually.

Policy Details

I. Generally

A. All records pertaining to students that are maintained by units are official university records, and as such,

remain the property of the university.

B. Each unit must keep, pursuant to the university Records Retention Schedule

, a record of requests and

disclosures of student record information except when the request is from the student, a university official with

a legitimate educational interest, someone requesting directory information, or related to a request with

consent from the student. Students have the right to review this record of requests and disclosures of student

record information.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 2 of 8

II. Annual Notice

A. The University Registrar provides students with an annual notice of rights with respect to their education

records and a link to this policy.

III. Right to Inspect and Review

A. Students are granted the right to inspect and review their education records, except the following:

1. Financial records of parents.

2. Confidential letters and statements of recommendations for admission, employment, or honorary

recognition placed in education records after January 1, 1975, for which students have waived their right of

access.

IV. Waiver of Access of Rights

A. Students may waive their right of access to confidential letters and statements of recommendation. Even if the

student signs a waiver, upon request, the names of all persons making confidential recommendations will be

made available to the student.

B. Employees or contractual agents of the university may not require a student to waive her or his right of access

for receipt of university benefits or services.

V. Right to Challenge Information in Education Records

A. Students have a right to challenge the content of their education records if they consider the information

contained therein to be inaccurate, misleading, or inappropriate.

B. This process includes an opportunity for amendment of the education records or insertion of written

explanations by the student into such records.

C. The right to challenge grades does not apply under FERPA unless the grade assigned was inaccurately

recorded, under which condition the record will be corrected.

VI. Release Without Consent

A. The university may release the following information without obtaining consent:

1. Requests from faculty and staff of The Ohio State University who have a legitimate educational interest on

a "need to know" basis, including student employees or contractual agents of the institution, if necessary to

conduct official business, as authorized by the University Registrar. Legitimate educational interest includes

performing a task related to the regular duties of the employee or contractual agent, the student's education,

the discipline of a student, a service or benefit for the student, or maintaining safety and security of the

campus.

2. Requests in compliance with a lawful subpoena or judicial order.

3. Requests in connection with a student's application for or receipt of financial aid.

4. Requests by parents of a dependent student, as defined in Section 152 of the Internal Revenue Code of

1954.

5. In the case of emergencies, the university may release information from education records to appropriate

persons in connection with an emergency, if the knowledge of such information is necessary to protect the

health or safety of a student or other persons.

6. The results of any disciplinary proceeding conducted by the university against an alleged perpetrator of a

crime of violence to the alleged victim of that crime.

7. Requests by state authorities and agencies specifically exempted from the prior consent requirements by

FERPA.

8. To authorized federal officials who have need to audit and evaluate federally-supported programs.

9. Information submitted to accrediting organizations.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 3 of 8

10. Organizations conducting studies on behalf of the university, if such studies do not permit the personal

identification of students to any persons other than to representatives of such organizations and if the

personal identification data is destroyed when no longer needed.

11. Requests for directory information (see Directory Information).

B. The university reserves the right to verify the accuracy of any information contained in what purports to be an

official university document (e.g., a transcript or diploma) or information that is provided to a third party.

C. Degrees (any honors, majors, minors, and specializations) are considered public information since they are

conferred in a public ceremony and may be released without consent.

VII. Consent for Release Required

A. In all other circumstances, the university may release certain information from an education record only with

consent.

B. Unless covered under Release Without Consent, consent must be obtained from students for the release of

information from education records, specifying what is to be released, the reasons for release, and to whom,

with a copy of the record sent to the student if she or he desires. See Consent for Release under Procedures.

VIII. Directory Information

A. FERPA requires the university to designate which information about students will be considered directory

information. Directory information may be published and/or released without consent.

B. The Ohio State University has designated the following information about students as public (directory)

information:

1. Name

2. Permanent address (does not include home/local, physical, or dorm address)

3. Official university email address

4. Home telephone (does not include dorm or cell phone)

5. Program of study (including college of enrollment, major, and campus)

6. Enrollment status (e.g., full-time, part-time, withdrawn)

7. Dates of attendance

8. Names of honors awarded (e.g., Latin honors, dean’s list, scholarships-with the amount excluded)

9. Previous educational agencies or institutions attended

10. Participation in officially recognized activities and sports

11. Weight and height of members of intercollegiate athletic teams

C. The university publishes student directory information on the web via Find People. Student directory

information on the web contains name, email address, major, and college.

D. Students have the right to have this directory information withheld from the public if they so desire. Each

student who wants all directory information to be withheld (including items to be published in the online “Find

People”) must notify the University Registrar by following Withholding Directory Information under

Procedures.

E. The university receives many inquiries for directory information from a variety of sources, including friends,

parents, relatives, prospective employers, other institutions of higher education, honor societies, licensing

agencies, government agencies, and the news media.

1. Each student is advised to carefully consider the consequences of a decision to withhold directory

information.

2. The university, in all good faith, will not release directory information requested to be withheld, and any

requests from persons or organizations outside the university will be refused unless the student provides

written consent for the release.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 4 of 8

IX. Accountability

A. It is the responsibility of all faculty, staff, student employees, students, and contractual agents of the university

to be informed of and follow the requirements under FERPA to protect student information.

B. Employees who violate this policy may be subject to disciplinary action, including and not limited to

termination of employment and/or potential criminal prosecution under applicable federal, state, and local laws.

C. Students who violate this policy are subject to disciplinary action under the Code of Student Conduct

and/or

potential criminal prosecution under applicable federal, state, and local laws.

D. Other individuals and entities to whom this policy applies who violate this policy are subject to appropriate

sanctions, including and not limited to termination of the relationship and/or potential criminal prosecution

under applicable federal, state, and local laws.

PROCEDURE

Issued: 01/01/1974

Revised: 07/01/2015

I. Annual Notice to Students

A. The annual notice is sent from the University Registrar to enrolled students at the start of each autumn semester

to explain the rights of students with respect to records maintained by the university.

B. The notice also outlines the university's procedures to comply with the requirements of FERPA.

C. Copies of FERPA, the federal regulations adopted pursuant to it, and the annual notice are available for persons

to examine in the Office of the University Registrar, 281 W. Lane Ave., Columbus, OH 43210-1230.

II. Student Inspection and Review of Education Records

A. Student requests to review education records must be made separately, in writing, to each unit maintaining

records. Each unit must respond to requests to review and inspect as soon as possible and no later than 45 days.

B. Information contained in education records will be fully explained and interpreted to students by university

personnel assigned to, and designated by, the appropriate unit.

C. Students have the right to review only their own education records. When a record contains information about

more than one student, disclosure cannot include information regarding the other student(s).

III. Hearing to Challenge Record

A. Students challenging information in their education records must submit, in writing, a request for a hearing to

the appropriate unit maintaining the record, listing the specific information in question and the reasons for the

challenge.

B. Hearings will be conducted by an impartial university official, serving as the hearing officer, who does not have

a direct interest in the outcome of the hearing.

C. Students will be afforded a full and fair opportunity to present evidence relevant to the reasons for the

challenge, as referenced in Right to Challenge Information in Education Records in Policy Details.

D. The hearing officer will render a decision, in writing, noting the reason and summarizing all evidence presented

within a reasonable period of time after the challenge is filed.

E. Should the hearing be in favor of the student, the record will be amended accordingly. Should the request be

denied, an appeal may be made, in writing, and submitted to the University Registrar within 10 days of the

student's notification of the decision of the hearing officer. The appeal will be heard by an appeals board of

three impartial senior university officials and a decision rendered, in writing, within a reasonable period of time.

F. Should the appeal be in favor of the student, the record will be amended accordingly. Should the request be

denied, the student may choose to place a statement with the record commenting on the accuracy of the

information in the record and/or setting forth any basis for inaccuracy. When disclosed to an authorized party,

the record will always include the student's statement and notice of the board's decision, as long as the student's

record is maintained by the university.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 5 of 8

IV. Complaints, Concerns or Suggestions

A. Any student who has reason to believe that the university is not complying with FERPA or this policy should

inform the University Registrar in writing.

B. The University Registrar will promptly review all such allegations.

C. The university governance group overseeing implementation of this policy is the University Senate Council on

Enrollment and Student Progress.

V. Training

A. All employees should seek out the appropriate university-provided FERPA training based on their role.

1. Online training is available to the university community.

2. Additional information and training may be requested by contacting the University Registrar.

VI. Handling Requests for Release of Education Records

A. When faculty, staff, student employees, or contractual agents of the university receive a request for information

contained in an education record, they must follow the procedures contained in this policy and the FERPA

training.

1. Only requests for information listed in Release Without Consent in Policy Details may be released without

consent.

2. All other requests for information may only be released with consent by following Granting and/or

Obtaining Consent for Release.

B. All questions about handling requests for release of education records should be referred to the University

Registrar.

VII. Granting and/or Obtaining Consent for Release

A. When the release of information in an education record requires student consent, the student must complete the

Authorization to Release Information

and return the completed form to the University Registrar.

VIII. Withholding Directory Information

A. Students requesting to withhold directory information must so indicate to the University Registrar by

completing a request to withhold release of directory information available from the Student Center in Buckeye

Link.

B. At least 10 days should be allowed for processing of these requests.

IX. Maintaining and Disposing of Education Records

A. Student education records must be maintained and stored according to the Institutional Data policy.

B. Student education records must be retained and destroyed according to the university Records Retention

Schedule.

X. Type, Location, and Custodian of Student Education Records

A. The Ohio State University does not maintain education records in one central office. Education records are

maintained in the respective colleges and schools (including their placement offices), the Graduate School and

graduate departments, each extended campus office (for extended campus students), and the University

Registrar. Other education records are maintained in the Office of Admissions (for enrolled and former

students; applicants are excluded), Office of Student Life (disciplinary records), Office of Student Financial Aid

(financial and related information, student employment), Athletic Department (intercollegiate sports), Office of

International Affairs, Office of Academic Affairs (academic misconduct), and other offices.

B. Questions regarding individual student records, including access to them, should be directed to the appropriate

location. See list below.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 6 of 8

C. Custodians of Student Education Records

Unit

Location

Responsible Party

Academic Affairs

203 Bricker Hall

Vice provost

Accounts Receivable

2nd Floor Student Academic Services Building

Assistant treasurer

Admissions

1st Floor Student Academic Services Building

Director

Agricultural Technical Institute

Academic Affairs

Assistant director

Air Force Aerospace Studies

353 Converse Hall

Chair

Alumni/Advancement

1480 W. Lane Ave.

Vice president

Arts and Sciences

164 Denney Hall

Assistant dean

Athletics

St. John Arena

Assistant director

Business

201 Fisher Hall

Dean

Counseling & Consultation Service

Floor Younkin Success Center

Director

Dental Hygiene

3070 Postle Hall

Assistant director

Dentistry

1159 Postle Hall

Associate dean

Disability Services

150 Pomerene Hall

Director

Diversity & Inclusion

Floor Student Academic Services Building

Director of recruitment

Education & Human Ecology

127 Arps Hall

Dean

Engineering

122 Hitchcock Hall

Associate dean

Extended Education

152 Mount Hall

Associate director

Fees, Deposits & Disbursement

Floor Student Academic Services Building

Assistant treasurer

Financial Aid

Floor Student Academic Services Building

Director

Food, Agriculture & Environmental Science

100 Agricultural Administration Building

Dean

Graduate School

247 University Hall

Assistant dean

Health & Rehabilitation Services

106 Atwell Hall

Director

Health Services

Wilce Health Center

Director

Honors Office

Honors House

Director

ID Card Services

3040 Ohio Union

Director

International Affairs

322 Oxley Hall

Director

Law

112 Drinko Hall

Associate dean

Libraries

Main Library

Director

Lima Campus

Public Service Building

Associate dean

Mansfield Campus

Ovalwood Hall

Associate dean

Marion Campus

Morrill Hall

Associate dean

Medicine

209 Meiling Hall

Dean

Military Science

253 Converse hall

Chair

Naval Science

110 Converse Hall

Chair

Newark Campus

Founders Hall

Associate dean

Nursing

240 Newton Hall

Dean

Optometry

A425 Starling-Loving Hall

Associate dean

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 7 of 8

Unit

Location

Responsible Party

Orientation

1240 Lincoln Tower

Assistant dean

Pharmacy

217 Parks Hall

Dean

Placement Offices

College Offices

Director

Public Health

250 Cunz Hall

Director

Public Policy & Management

300 Fisher Hall

Director

Residence & Dining Halls

250 Morrill Tower

Director

Social Work

309 Stillman Hall

Dean

Student Activities

Ohio Union

Director

Student Advocacy Center

1120 Lincoln Tower

Director

Student Conduct

33 W. 11

Ave.

Director

Student Loan Services

Floor Student Academic Services Building

Assistant treasurer

Transportation & Traffic Management

2500 Kenny Road

Director

Undergraduate Student Academic Services

Denney Hall

Dean

University Registrar

Floor Student Academic Services Building

Registrar

Veterinary Medicine

0004 Veterinary Hospital

Assistant dean

Responsibilities

Position or Office

Responsibilities

University Registrar

1. Provide students with an annual notice of their rights and a link to this policy.

Have available for examination copies of FERPA, the federal regulations adopted pursuant to it, and the

annual notice.

3. Review all written allegations that the university is non-compliant with FERPA.

4. Process student requests to withhold release of directory information within 10 days.

Council on Enrollment

and Student Progress

Oversee implementation of this policy.

Units

1. Maintain student education records.

Keep records of requests and disclosures of student record information except in certain circumstances

detailed in this policy.

3. Respond to students’ written requests to review and inspect education records as soon as possible and

no later than 45 days.

4. Assign and designate university personnel to explain and interpret information contained in education

records to students.

5. Conduct hearings (by an impartial university official) upon receipt of a student’s written request to

challenge a record.

6. Conduct appeals board hearings (three impartial senior university officials) upon receipt of a student’s

written appeal to challenge hearing officer determination.

7. Amend records pursuant to the outcomes of challenges and appeals.

8. Obtain student consent whenever releasing information from education records, unless an exception

applies.

9. Maintain and store student education records according to the Institutional Data policy.

10. Retain and destroy student education records according to the university Records Retention Schedule.

Students

If applicable:

1. Submit a written request to review and inspect records to the unit maintaining the record.

2. Submit a written request for a hearing to challenge her or his record to the unit maintaining the record.

3. Submit a written appeal to the University Registrar within 10 days of the notification of the decision.

4. Submit a statement to be included with the record commenting on the accuracy of the information

and/or setting forth any basis for the inaccuracy.

5. Inform the University Registrar in writing of allegations of university noncompliance with FERPA.

Privacy and Release of

Student Education Records

University Policy

Applies to: Employees, students, contractual agents of the institution, parents of dependent students, individuals

requesting access to student information.

The Ohio State University – University Policies policies.osu.edu/ Page 8 of 8

Position or Office

Responsibilities

6. Complete the Authorization to Release Information and return the form to the University Registrar.

7. Complete a request to withhold release of directory information available from the Student Center in

Buckeye Link and allow 10 days for processing.

8. Direct questions regarding student education records to the unit maintaining the specific record (see list

above).

Employees (including

contractual agents)

1. Be informed of and follow the requirements under FERPA to protect student information.

2. Seek out appropriate university-provided FERPA training based on role.

3. Follow procedures contained in this policy and FERPA training when receiving requests for information.

4. Refer all questions about handling requests for release of education records to the University Registrar.

Hearing officer

1. Conduct hearings upon receipt of a student’s written request to challenge a record.

2. Render a written decision to a challenge within a reasonable period of time noting the reason and

summarizing all evidence.

Appeals board

Hear appeals and render written decisions within a reasonable period of time after the challenge is filed

Resources

Training:

FERPA, available on Carmen

University policies:

Institutional Data policy, go.osu.edu/idp

Records Retention Schedule, library.osu.edu/documents/records-management/general-schedule.pdf

Forms:

Authorization to Release Information, registrar.osu.edu/policies/ferpa_authorization_release_information.pdf

Request to withhold release of directory information, Buckeye Link, buckeyelink.osu.edu/

Additional information:

FERPA regulations and recent guidance, AACRAO, aacrao.org/resources/compliance/ferpa

U.S. Department of Education, 1-800-872-5327, 2.ed.gov/policy/gen/guid/fpco/ferpa/index.html

Contacts

Subject

Office

Telephone

E-mail/URL

Policy interpretation; referral to area

responsible for maintaining record(s).

Office of the University Registrar

614-292-9330

[email protected]

registrar.osu.edu

History

Issued: 01/01/1974

Revised: 09/01/1976

Edited: 11/01/1979

Revised: 01/01/1981

Revised: 04/01/1983

Revised: 01/01/1993

Revised: 02/01/1996

Revised: 08/01/2003

Revised: 10/07/2008

Revised: 01/01/2009

Revised: 01/07/2011

Edited: 01/02/2013

Edited: 01/28/2013 Procedure section only

Edited: 05/17/2014

Revised: 07/01/2015