FERPA

The Basic Rules

• Student educational records are considered confidential and may not be released without the written consent of the student.
• Faculty and staff may have access to information only for legitimate use in completion of their responsibilities as a university employee. “Need-to-know” is the basic principle, and these individuals have an obligation to protect educational records in their possession.
• Some information is considered public (sometimes called “Directory Information”). This information can be released without the student’s written permission. However, the student may opt to consider this information confidential as well. See more about Directory Information below.

If you are ever in doubt, do not release any information until you contact the Office of the Registrar at 219-989-2210 or registrar@pnw.edu. The Office of the Registrar is responsible for student record information.

Special Instructions for Faculty

To avoid violating FERPA rules, do not at any time:

• Use a part of or the entire Student Identification Number or Social Security Number of a student in a public posting of grades
• Link the name of a student with that student’s identification number or Social Security Number in any public manner
• Leave graded tests in a stack for students to pick up by sorting through the papers of all students
• Circulate a printed class list with student name and student identification number or Social Security Number or grades as an attendance roster
• Discuss the progress of a student with anyone other than the student (including parents) without the consent of the student
• Provide anyone with lists of students enrolled in your classes for any commercial purpose
• Provide anyone with student schedules or assist anyone other than university employees in finding a student on campus

Public Posting of Grades

The public posting of grades, either by the student’s name, institutional student identification number or social security number is a violation of FERPA. Using an assigned random number that only the student and instructor know would be an appropriate way to post grades. Even then, the order of posting should not be alphabetic.

What Are Education Records?

Any record directly related to a student and maintained by the university for use in the educational process is considered a student educational record, including:

• Personal information
• Enrollment records
• Grades
• Schedules

Education records include any records in whatever medium (handwritten, email, print, etc.) that is in the possession of any school official. This includes transcripts or other records obtained from a school in which a student was previously enrolled. A student has the right of access to these records.

What Are Not Education Records?

• Sole-possession records or private notes held by school officials that are not accessible or released to other personnel
• Law-enforcement or campus-security records that are solely for law-enforcement purposes and maintained solely by the law-enforcement unit
• Records relating solely to an individual’s employment by the institution that are not available for any other purpose
• Records relating to treatment provided by a physician, psychiatrist, psychologist or other recognized professional or paraprofessional and disclosed only to individuals providing treatment
• Records of an institution that contain only information about an individual obtained after that person is no longer a student, i.e., alumni records,
• Grades on peer-graded papers that have not been collected and recorded.

“Legitimate Educational Interest”

A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibility.

Outsourcing and Access to Education Records

Institutions are allowed to disclose education records without the student’s consent to contractors, volunteers and other non-employees performing institutional services and functions.

“Health and Safety” Exception

Institutions may take into consideration circumstances pertaining to the health and safety of a student or other individuals to disclose information from education records without a student’s consent. If the institution determines there is “articulable and significant threat” to the health and safety of the student or others, information from education records can be released “to any person whose knowledge of the situation is necessary to protect” the health and safety of the student or other individuals.

Letters of Recommendation

Statements made by a person making a recommendation that are made from that person’s personal observation or knowledge do not require a written release from the student who is the subject of the recommendation. However, if personally identifiable information obtained from a student’s education record is included in a letter of recommendation (grades, GPA, etc.), the writer is required to obtain a signed release from the student which:

• specifies the records that may be disclosed
• states the purpose of the disclosure, and
• identifies the party or class of parties to whom the disclosure can be made.

Since the letter of recommendation would be part of the student’s education record, the student has the right to read it – unless he/she has waived that right of access.

Students may use the online FERPA Letter of Recommendation form to request a PNW faculty or staff member to provide such a letter and indicate what type of information they would like to have included in the letter.

What Is Directory Information?

Institutions may disclose the following information on a student without violating FERPA if the student has not restricted their information.

• Name
• Email address
• Address (local and home)
• Telephone number (local and home)
• College/school and curriculum
• Enrollment status and credit-hour load
• Dates of attendance
• Classification
• Receipt or non-receipt of a degree
• Academic awards received (dean’s list, honors students)
• Participation in officially recognized activities
• Sports photograph
• Position, weight and height of athletes

Restricted Information

Students have the right to restrict disclosure of personally identifiable information the university has designated as directory information that may be released without the written consent of the student.

If a student does not want their name/address/phone number to appear in the Student and Staff Telephone Directory, they must contact the Office of the Registrar prior to the end of the first week of the semester.

Hammond Campus
Lawshe Hall
Room 130

Westville Campus
Schwarz Hall
Room 120

Students with photo identification may request in person that all of their directory information be restricted. For these students, it is important to note that no information is released without the students’ written consent. If a student elects to restrict all information, the Office of the Registrar will give the following response to all inquiries: “We have no information on this individual.”

What is Personally Identifiable Information?

Personally identifiable information includes but is not limited to:

• Student name
• Name of student’s parent or other family member
• Address of the student or the student’s family
• A personal identifier (PUID, SSN)
• Biometric record
• Other indirect indicators (birth date, place of birth, mother’s maiden name)
• Other information alone or in combination that would make the student’s identity easily traceable

Indiana Social Security Number Law

Internal use of Social Security Number information within the Purdue system for the purpose of conducting normal business is still permitted under that law. However, it is important to remember that Purdue data-handling guidelines address the usage and methods of exchanging sensitive and restricted data, in addition to just SSN information. These guidelines can be found at Purdue University’s Secure Data Restrictions.

What happens if non-compliance occurs?

The student has the right to file a complaint with the U.S. Department of Education in Washington, D.C.

This complaint may result in the loss of federal funding for financial aid and educational grants for Purdue University and the filing of civil litigation.

Action to terminate funding is generally taken only if compliance cannot be secured by voluntary means.

• Purdue University’s Access to Student Education Records (VIII.A.4).
• Purdue University’s University Regulations, Part 6, Rights and Privacy – Student Education Records
• Purdue University’s FERPA Training (PDF)

Call (765) 494-8219 or email ferpa@purdue.edu for FERPA assistance.

Office of the Registrar
Hovde Hall of Administration
610 Purdue Mall
West Lafayette, IN 47907-2040
Phone: (765) 494-8581
Fax: (765) 494-0570

This annual federally required training for instructors can be accessed by registering through the WebCert portal. PNW instructors will then see the course display in Brightspace under the “WebCert” tab in the MyCourses widget. Upon earning 100% on the FERPA quiz, instructors will receive an email notification with validation of completion.

Video Tutorial – How to Register for the FERPA Course