This information should be used only to assist offices dealing with student information in understanding what records are included and excluded by the Family Educational Rights and Privacy Act of 1974 (FERPA). These guidelines are not intended as legal advice or to provide comprehensive information about University file management practices. Staff should consult the University’s Information Security Policy as well as the Policies on Student Files.
- “Student” includes any person for whom the University maintains an education record, whether or not that person is currently in attendance. Persons who have not been in attendance are not “students” entitled to review their records.
- "Education Records” are those records, files, documents, and other materials that contain information directly related to a student and that are maintained by the University. The form in which the information is maintained by the University does not matter; for example, computerized or electronic files, audio or video tape, photographic images, film, electronic mail, etc., containing such information are “education records.” Note especially that sending information by electronic mail will result in that mail message becoming an “education record.”
The following types of University records are not “education records”:
- “Sole Possession Records”: Personal notes, documents or records (including computerized files) that are kept by an individual University employee solely in her or his possession, are used only as a personal memory aid, and are not accessible or revealed to others, except to a temporary substitute. If information from such documents is transmitted to another University office via email, it will become an education record, therefore staff should consider the use of telephone calls for information from personal notes that are not currently an “educational record.”
- Employment Records: Records that relate to an individual who is employed by the University and that (a) are made and maintained in the normal course of business, (b) are not available for use for any other purpose, and (c) relate exclusively to the individual in that individual's capacity as an employee.
- Medical Records: Medical and psychiatric records created, maintained, and used in connection with the treatment of a student. Such records can be personally reviewed by a physician, psychologist, or other appropriate health professional of the student's choice. (Students who have received treatment from the University Health Services or from Counseling Services may contact those offices to inquire concerning access to patient information.)
- Alumni Records: Records that contain information relating to a person only after that person is no longer a student at the University.
Consent for disclosure of personally identifiable information is ordinarily required except for disclosures to:
- the student;
- school officials with legitimate educational interests, including any University employee acting within the scope of his/her University employment, and any duly appointed agent or representative of the University acting within the scope of his/her appointment;
- accrediting, testing and similar organizations;
- parents of dependent students;
- federal, state and local officials or authorities specified in Subpart D of the FERPA Regulations, 34 C.F.R. Part 99;
- individuals in connection with financial aid;
- comply with a subpoena or judicial order;
- appropriate parties in connection with an emergency when necessary to protect the health or safety of the student or other individuals (to be strictly construed);
- officials of another educational institution where the student has applied or attends the other institution;
- an alleged victim of a crime of violence or non-forcible sex offense of the results of any University disciplinary proceeding;
- the parent of a student under 21 years of age who has violated a law or policy regarding use or possession of drugs or alcohol about that disciplinary violation; and
- of information about registered sex offenders.
Also, the University does not have to permit a student to review education records that are:
- Financial records of the parents of a student.
- Confidential letters and statements of recommendation placed in the education records of a student (a) prior to January 1, 1975 and (b) after January 1, 1975, if the student has waived access to such letters and recommendations.
This exception will cover most communications among the Offices of the Dean of the College, Dean of Undergraduate Students, the Graduate School, and Counseling and Psychological Services.
 The University may provide information under this exception only if the parent has provided evidence that the student is his/her dependent under the Internal Revenue Service Code (e.g., by providing a copy of an income tax return where the student is claimed as a dependent). 34 C.F.R. §99.31.