Author: Nadine Ashton

Employee Conflict of Interest

CCS administrative staff should avoid situations where their own interests materially conflict with their obligations to CCS or create the perception of a conflict. All decisions and actions by administrative staff in the course of their professional responsibilities are to be made consistent with their obligations to CCS.

Generally, a conflict of interest arises when an administrative staff member has a personal or financial interest in a transaction or event – or is a party to a transaction or event – that might adversely affect his or her judgment in performing professional or employment duties for CCS. Examples of potential conflicts of interest include, but are not limited to, the following:

1. Engaging in any business with, or employment by, an employer that is in competition or in conflict with any transaction, activity, or objective of CCS.

2. Engaging in business with or employment by a supplier of goods or services to CCS without prior approval of CCS.

3. Using equipment, supplies, or services owned or provided by CCS in conjunction with any external work, without obtaining prior agreement, in writing, from the department that owns the equipment/supplies.

4. Making use of any confidential information acquired through employment with CCS for personal profit or advantage, or the advantage of a third-party.

5. Publicly associating CCS or its prestige with an outside business interest for personal gain.

Administrative staff members who believe they have a financial, personal, or professional interest that is (or could potentially become) a conflict of interest must fully disclose the nature of the potential conflict in writing to the Director of Human Resources. All decisions concerning whether a conflict of interest exists are within the sole discretion of CCS.

Confidentiality

Due to the nature of the College’s work, you may be privy to confidential information. Certain information is required to be confidential by law, while other material must remain confidential in order to comply with contracts or good professional practice.

If you have access to confidential information, you must not disclose it to anyone inside or outside the College unless express authorization has been obtained from the College. If you have any questions about the confidentiality of the work you perform or the information that you receive, either in written or verbal form, please contact your supervisor or the director of Human Resources.

Family Educational Rights and Privacy Act (FERPA)

The Family Educational Rights and Privacy Act affords students the certain rights with respect to their educational records.

The Family Educational Rights and Privacy Act (FERPA) affords eligible students certain rights with respect to their education records. (An “eligible student” under FERPA is a student who is 18 years of age or older or who attends a postsecondary institution at any age.) These rights include:

1.  The right to inspect and review the student’s education records within 45 days after the day the College for Creative Studies (CCS) receives a request for access. A student should submit to the Registrar, a written request that identifies the record(s) the student wishes to inspect.  The Registrar will make arrangements for access and notify the student of the time and place where the records may be inspected. If the records are not maintained by the school official to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed.

2.  The right to request the amendment of the student’s education records that the student believes is inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.

A student who wishes to ask CCS to amend a record should write the Registrar, clearly identifying the part of the record the student wants changed and specify why it should be changed.

If CCS decides not to amend the record as requested, the Registrar will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.

3.  The right to provide written consent before CCS discloses personally identifiable information (PII) from the student’s education records, except to the extent that FERPA authorizes disclosure without consent.

FERPA permits the disclosure of PII from students’ education records, without consent of the student, if the disclosure meets certain conditions found in § 99.31 of the FERPA regulations. Except for disclosures to school officials, disclosures related to some judicial orders or lawfully issued subpoenas, disclosures of directory information, and disclosures to the student, § 99.32 of FERPA regulations requires the institution to record the disclosure. Eligible students have a right to inspect and review the record of disclosures. A postsecondary institution may disclose PII from the education records without obtaining prior written consent of the student —

  • To other school officials, including faculty, within CCS whom the College has determined to have legitimate educational interests. This includes Board of Trustees, a student serving on an official committee, contractors, consultants, volunteers, or other parties to whom the school has outsourced institutional services or functions, provided that the conditions listed in § 99.31(a)(1)(i)(B)(1) – (a)(1)(i)(B)(3) are met. (§ 99.31(a)(1))
  • To officials of another school where the student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer, subject to the requirements of § 99.34. (§ 99.31(a)(2))
  • To authorized representatives of the U. S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or State and local educational authorities, such as a State postsecondary authority that is responsible for supervising the university’s State-supported education programs. Disclosures under this provision may be made, subject to the requirements of §99.35, in connection with an audit or evaluation of Federal- or State supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs. These entities may make further disclosures of PII to outside entities that are designated by them as their authorized representatives to conduct any audit, evaluation, or enforcement or compliance activity on their behalf. (§§ 99.31(a)(3) and 99.35)
  • In connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid. (§ 99.31(a)(4))
  • To organizations conducting studies for, or on behalf of, the school, in order to: (a) develop, validate, or administer predictive tests; (b) administer student aid programs; or (c) improve instruction. (§ 99.31(a)(6))
  • To accrediting organizations to carry out their accrediting functions. (§ 99.31(a)(7))
  • To parents of an eligible student if the student is a dependent for IRS tax purposes. (§ 99.31(a)(8))
  • To comply with a judicial order or lawfully issued subpoena. (§ 99.31(a)(9))
  • To appropriate officials in connection with a health or safety emergency, subject to § 99.36. (§ 99.31(a)(10))
  • To a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense, subject to the requirements of § 99.39. The disclosure may only include the final results of the disciplinary proceeding with respect to that alleged crime or offense, regardless of the finding. (§ 99.31(a)(13))
  • Information the school has designated as “directory information” under § 99.37. (§ 99.31(a)(11)).  CCS defines the following as “directory information:”
  • Name
  • Dates of Attendance
  • Graduation Date
  • Major/Academic Program
  • Degrees, honors, and awards received

4.  The right to file a complaint with the U.S. Department of Education concerning alleged failures by CCS to comply with the requirements of FERPA. The name and address of the office that administers FERPA is:

Family Policy Compliance Office

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202

Information for Dual Enrolled High School Students

A student attending a postsecondary institution – at any age – the rights under FERPA have transferred to the student. However, in a situation where a student is enrolled in both a high school and a postsecondary institution, the two schools may exchange information on that student. If the student is under 18, the parents still retain the rights under FERPA at the high school and may inspect and review any records sent by the postsecondary institution to the high school.

Student Information Release Authorization

To release PII to a parent, another individual, or organization, the Student Information Release Authorization must be completed and signed. This form is available in the Academic Advising and Registration Office (AARO).

Request to Withhold Release of Directory Information

To request to withhold the release of directory information, the Request to Withhold Release of Directory Information must be completed and signed. This form is available in the Academic Advising and Registration Office (AARO).