Security and Privacy of Educational Records
The following material is Harding University's Student Education Records Policy.
Harding's student education records policy is designed to meet the provisions of the Family Educational Rights and Privacy Act of 1974, as amended, 20 USC 1232(g) (FERPA). Harding University, with its primary campus in Searcy, Ark., (the University) is committed to the policy and will follow the procedures.
FERPA defines regulations with regard to the maintenance of student records. It is incumbent on those of us who have access to Harding's database to conform to the FERPA regulations and protect the privacy of our fellow employees, our students and the parents of our students.
According to FERPA, education records are records (in handwriting, print, tape, film or other medium) maintained by the University, an employee of the University, or an agent of the University which are directly related to a student, except as may be provided otherwise. Education records do not include sole possession records, employment records, admission records, alumni records, campus security records, and counseling records. These exceptions are carefully defined in Harding's policy.
One must be especially careful when distributing information which is personally identifiable. For example, the average GPA of Harding freshmen can be released because it is not information about individuals. However, releasing a list of each freshman's GPA would be in violation of the law. Therefore, we must be very careful when we are dealing with records which contain "personally identifiable information." According to FERPA, personally identifiable information is any data or information that relates to a record of an individual. This includes the following:
- Individual's name,
- The name of the individual's parents or other family members,
- The individual's address,
- The individual's social security number,
- Any other number or symbol which identifies the individual,
- A list of the individual's personal characteristics,
- Any other information which would make the individual's identity known and can be used to label a record as the individual's.
University employees are bound by the FERPA policy to limit the disclosure of information contained in a student's education records to the following circumstances:
- with the student's prior written consent;
- as an item of directory information (see the definition of directory information which follows) which the student has not refused to permit the University to disclose;
- under FERPA provisions which allow the University to disclose information without the student's prior written consent.
The University designates personally identifiable information contained in a student's education records listed below as "directory information" in order that the University may, at its discretion, disclose the information without a student's prior written consent:
- Name;
- Campus address;
- Permanent Address;
- Telephone number;
- Date and place of birth;
- Major field of study;
- Participation in officially recognized activities and sports;
- Weight and height of members of athletic teams;
- Dates of attendance;
- Degrees, achievements, academic awards and honors;
- The most recent previous educational agency or institution attended;
- Social clubs; and
- Academic clubs and societies.
In addition to these items, by enrolling at the University, the student consents to the University photographing her or him for promotional and identification purposes.
The student has the right to further restrict the release of directory information if he or she chooses to do so. After the student has received the Family Educational Rights and Privacy Act notification at registration, he or she will have two (2) weeks to notify the FERPA administrator in writing that he or she requests to prevent disclosure of directory information.
The University maintains education records in order for faculty and staff to perform their proper functions to serve the student. To carry out their responsibilities, these officials will have access to student education records for legitimate educational interests.
To establish who are University officials having access to Education Records, the University will apply the criteria listed below. A University official is:
- A person appointed as a member of the University board of trustees.
- A person approved by and under contract to the University board of trustees in an academic or research faculty position.
- A person under contract to the University board of trustees to serve in a University administrative position.
- A person employed by the University as a temporary substitute for an administrative staff member or faculty member for the period of his or her performance as a substitute.
- A person employed by the University or under contract to the University board of trustees to perform a special administrative task. These would be persons such as secretaries, clerks, attorneys, auditors and consultants for the period of their performance as an employee or contractor.
- A person charged with the responsibility of faculty athletic representative to the governing bodies of athletic conferences in which the University has membership, (herein called athletic conference).
- A person under contract to assist faculty or staff persons in his or her official duties. This would involve student workers and graduate assistants. This person has access only to those education records necessary to perform his or her duties under such contract.
Legitimate educational interest defined. University officials who meet the criteria listed above will have access to personally identifiable information contained in student education records if they have a legitimate educational interest in doing so. A "legitimate educational interest" is the person's need to know in order to:
- Perform an administrative task outlined in the official's position, description or contract approved by the University board of trustees;
- Perform a supervisory or instructional task directly related to the student's education;
- Perform a service or benefit for the Student such as health care, counseling, job placement or financial aid; or
- Perform a task relating to athletic conference compliance, rules and regulations.
University officials may not disclose personally identifiable information contained in a student's education records except directory information or under the circumstances listed above except with the student's prior written consent.
If you have any further questions about Harding's student education records policy or the FERPA regulations, please contact Harding's FERPA administrator, Mr. Tod Martin, Registrar.
Please be especially cautious when you are releasing material to off-campus people or organizations including churches and civic groups.
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