Student Privacy and Release of Student Information

Purpose:

To describe the maintenance and confidentiality of student records and the circumstances under which the institution may release information in student records. The procedures for implementation of this policy are provided below.

Procedure and/or Process Definitions:

Directory information: student data which would not generally be considered harmful or an invasion of privacy if disclosed (see Directory Information Addendum).

Disclosure: when access is permitted, or student information contained in educational records is released orally, electronically, or in writing to any party other than the party identified as the party that provided or created the record.

Education record: data that contains information directly related to a student and is maintained by an educational agency or institution, or an individual acting on behalf of the institution.

FERPA shade: functionality within the Student Information System, which is placed on the student record if the student does not want directory information released.

Legitimate educational interest: when a college official (or someone acting on behalf of the institution, such as a consultant or volunteer) needs to review a student's educational record in order to fulfill their job; the information is relevant and necessary to complete a task; the task is an employment responsibility or properly assigned subject for the inquirer's determination; and the task or determination is consistent with the purpose for which the records, information, or data are maintained. An example of when an educational interest may exist is when one office needs to work with another office to address an educational issue or concerns of a student and information within the file is shared in order to resolve the matter. This may include work within the college between various units or outside of the college, such as in clinical settings, etc.

Personally identifiable information: information that would reveal the identity of a student or would make the student's identity easily traceable.

Procedures:

1. Review of records

   1. In order to review an educational record, a student or parent of a dependent student must submit in writing a request to review such record to the Registrar's Office. The request must identify the record(s) to review. If the request is from a parent, the parent must provide a copy of the most recent year's federal tax return documenting that the student, whose record is being requested for review, is indeed that individual's dependent.

   2. The Registrar's Office staff will respond to the inquiry within a reasonable amount of time, but within the forty-five (45) day requirement prescribed by FERPA, informing of the date, time, and place that the record(s) may be reviewed.

   3. If the record is not housed within the Registrar's Office, the staff will direct the student to the appropriate office in which the record is maintained.

2. Amendment of record(s)

   1. In order to amend information within a record, a student may submit JSRCC Form 11-0007, Student Request to Update Information, in order to update any demographic information.

   2. If the information is not covered by JSRCC Form 11-0007, Student Request to Update Information, the student will indicate in writing to the Registrar's Office or the unit that houses the record for which the student seeks to amend.

   3. The Registrar's Office, or the unit that houses the record, will review the request and arrange a meeting within a reasonable amount of time, but no more than forty-five (45) days. The student should bring documentation supporting the request for amending the record(s).

   4. Within ten (10) business days of the meeting, the Registrar's Office, or unit where the records is housed, will issue a decision regarding the request.

   5. If the student is dissatisfied with the decision, that student may appeal the decision to the executive officer to whom the unit reports.

   6. If after the appeal the college does not amend the record, the student may place a statement in the record.

      This procedure does not replace Reynolds Policy 1-12, Student Appeal of Academic and/or Administrative Decisions, whereby a student may grieve an administrative decision (related to that individual's student record).

3. Consent to disclose personally identifiable information to a third party

   In the event that a student authorizes the college to provide information to a third party (e.g., parent or agency), the student will:

   1. Complete the FERPA eform, found in the SIS application within the MyReynolds account, outlining the individual(s) that may receive the information, assigning those individuals a Passcode and identify the record(s) type(s) for which the information may be provided.

   2. The college official will comply with the request within ten (10) business days.

4. Release of information to volunteer, consultant, researcher, or agency for research or other functions

   If the college enters into an agreement with a volunteer, consultant, or agency, the college shall:

   1. Establish a memorandum of agreement to be signed by the consultant or agency.

   2. The memorandum of agreement shall include (but not be limited to):

      1. purpose of agreement;

      2. functions/service to be provided by third party;

      3. direct control (of college);

      4. requirements in order to maintain student privacy;

      5. provision on the retention of records; and

      6. length of service.

5. Record retention

   The disposal of student records follows guidelines set forth by the Records Management and Imaging Services Division of the Library of Virginia.

Other Information:

Family Educational Rights to Privacy Act (FERPA)

HB 1 Scholastic Records; prohibited access to directory information.

Directory Information Addendum

Reynolds Policy 1-12, Student Appeal of Academic and/or Administrative Decisions

JSRCC Form 11-0007, Student Request to Update Information