Student privacy procedures to protect personally identifiable information
Checking for Records Release Permission
Before disclosing any personally identifiable information pertaining to the student’s educational records to a parent, spouse, or other third party;
- CCS Faculty should check with their department’s Program Manager to verify if a student has a Records Release Form on file.
- CCS Staff should contact the Academic Advising & Registration Office (AARO)
Only Directory Information, defined in the CCS FERPA Policy, can be released IF the student has not requested to withhold what is outlined in the CCS FERPA Policy.
Has the student requested to WITHHOLD Directory Information?
If a student has requested to “withhold” Directory Information, then that information cannot be released to any parent, spouse, or third party, nor can information be provided to potential employers, on letters of recommendation, or in public areas on campus that display personal identifiable information.
- To check for Directory Withholding information contact the Academic Advising & Registration Office. Directory Information is defined in the CCS FERPA Policy.
Releasing education records within the institution
If the “school official” has a “legitimate educational interest”, to review a student’s records in order to fulfill their professional responsibility, a request for records should go through the Registrar and the “need” will be documented to verify the release of records.
Following FERPA guidelines on campus
Faculty and Staff must ensure they are in compliance with FERPA on a daily basis. Here are a few notes to help you stay in compliance. Always contact the Registrar’s Office if you have questions:
- Make sure you only access student records for “legitimate educational interests” and determine if it is truly “needed” to fulfill your job responsibilities or tasks. Never use your access for means beyond your legitimate job responsibilities.
- Always check student privacy status before releasing records or directory information
- Keep students’ educational records private and secure, regardless of format:
Printed or written records: discard of properly or secure in file cabinet
Electronic records: Refer to the I.T. Data Protection Requirements for acceptable and recommended electronic communication/storage.
Video or Photo: do not discuss student individual records or share non-directory information in unsecure on online video meetings/recordings. If confidential information is to be stored on removable media or in the cloud, see the I.T. Data Protection Requirements regarding the proper storage.
- Do not circulate, post, or share attendance sheets, class lists, or other items that include students’ personally identifiable information (for example: a list grouping student’s name with any of the following: student ID#, grades, email, or any indication of course progress or academic level). Students should not see any educational records of other students.
- Never list student non-directory information in publications, postings, websites, etc.
If you realize a FERPA violation has occurred, contact the Registrar immediately at 313-664-7671 or email firstname.lastname@example.org.
Photos and Videos under FERPA
As with any other “education record,” a photo or video of a student is an education record… when the photo or video is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution.
Factors that may help determine if a photo or video should be considered “directly related” to a student are the following:
- The educational agency or institution uses the photo or video for disciplinary action (or other official purposes) involving the student (including the victim of any such disciplinary incident);
- The photo or video contains a depiction of an activity*:
- that resulted in…the institution’s use of photo or video for disciplinary action (or other official purposes)…
- that shows a student in violation of local, state or federal law;
- that shows a student getting injured, attacked, victimized, ill, or having a health emergency.
- The person or entity taking the photo or video intends to make a specific student the focus of the photo or video (e.g., ID photos, recording of a student presentation); or
- The audio or visual content of the photo or video otherwise contains personally identifiable information contained in a student’s education record.
Examples of situations that may cause a video to be an education record:
A classroom video that shows a student having a seizure is directly related to that student because the depicted health emergency becomes the focus of the video.
A video recording of a faculty meeting during which a specific student’s grades are being discussed is directly related to that student because the discussion contains PII from the student’s education record.
Letters of Recommendation
Students who request a letter of recommendation from faculty or staff that require details which fall under the definition of education records or personal identifiable information (PII), can have information provided that falls under “Directory Information”, if the student has not requested “Withhold Directory Information”. If a student has made the request to “withhold” directory information, then they must submit in writing to the faculty/staff a form of consent, agreeing to the release of information for the letter of recommendation.
Faculty/Staff who agree to write a letter of recommendation on behalf of a CCS student must verify the following pertaining to letters of recommendation under FERPA – The Family Educational Rights and Privacy Act:
- If including information defined as “Directory Information”, verify the student has not “withheld directory information” in the Registrar’s Office.
- If including information beyond what CCS has defined as “Directory Information” (like grades, GPA, class status, etc), the student must submit permission to release the information in writing to the Faculty/Staff, including the following:
- Date and specified time period for release information
- Purpose of Recommendation
- Who the Recommendation is to
- Description of personal/educational information intended to be released
- Confirm if student has waived right to view the letter of recommendation
- Retain original copy of written permission to release*
*It is recommended that a copy of the permission is filed in the Academic Advising & Registration Office. A Letter of Recommendation Release form is available for use.
Dual Enrolled Students
Faculty and Staff must follow FERPA guidelines for students dual enrolled in college courses. See the FERPA General Guidelines posted to the CCS Website or contact the Registrar with questions. As with any current student, a dual-enrolled student may complete a FERPA Release form to request information be disclosed to the person(s) listed on the form.