Policies & Procedures

Miscellaneous

Policy on Release of Student Information and Access to Student Records, SIUE - 3G2

1. PURPOSE
   
   

   Southern Illinois University Edwardsville, hereinafter referred to as the "University", maintains individual records and information about students who are legitimately enrolled, for the purpose of providing educational, vocational, and personal services to the student. For the purpose of complying with federal regulations regarding the maintenance of confidentiality of student educational records, as required by the Family Educational Rights and Privacy Act of 1974, as amended, (20 U.S.C. par. 1232g) the Board of Trustees of Southern Illinois University enacts the following policy.
   
   

2. DEFINITIONS
   
   
   1. "Student" is defined as a person who is or has been enrolled at Southern Illinois University Edwardsville in a course of study either on campus or off campus. For purposes of this policy, any student attending SIUE will be considered to be an adult and to have sole control over the release of his or her information, except as provided in this policy. The term "enrolled" is defined as having been duly admitted as a student, registered, and paid appropriate fees.
      
      
   2. "Educational Records" means (1) those records which are directly related to a student, and are maintained by SIUE or by any party acting for SIUE; (2) the term does not include:
      
      
      1. Personal records of instructional, supervisory, and administrative personnel which are not revealed to other individuals.
         
         
      2. Records of a law enforcement unit of an educational institution which are (1) maintained apart from the educational records, (2) maintained solely for law enforcement purposes, and (3) are not disclosed to individuals other than law enforcement officials of the same jurisdiction.

         For purposes of this policy, the SIUE Police Office will be treated as an outside agency and will therefore be required to comply with all formal regulations relating to the disclosure of information from student's educational records, as set forth in this policy.
         
         

      3. Employment records, so long as they are maintained separately from any educational record.
         
         
      4. Records of a physician, psychologist, or other recognized professional or paraprofessional acting in his or her professional capacity which are used only in connection with treatment and are not disclosed to individuals other than those providing the treatment; provided, that these records can be personally reviewed by a physician or other appropriate professional of the student's choice and so designated within the appropriate record.
         
         
      5. Records which are created, maintained, or developed after that person is no longer a student at SIUE, such as alumni files.
         
         
   3. "Student Information" means any information contained in an educational record as defined in II.B.
      
      
   4. "Personally Identifiable Information" (P.I.I.) includes:
      
      
      1. The name of a student, the student's parents, student's spouse, or other immediate family member.
         
         
      2. The address of the student.
         
         
      3. Student's identification number.
         
         
      4. A list of personal characteristics which would make the student's identity easily traceable.
         
         
      5. Other information that would make the student's identity easily traceable.
         
         
   5. "Directory Information" includes:
      
      
      1. Student name.
         
         
      2. Student local address and telephone number.
         
         
      3. Student home address and telephone number.
         
         
      4. E-mail address.
         
         
      5. Major field of study.
         
         
      6. Classification.
         
         
      7. Dates of attendance.
         
         
      8. Full or part-time status.
         
         
      9. Attempted hours.
         
         
      10. Degrees and awards received.
          
          
      11. The most previous educational agency or institution attended prior to enrollment at Southern Illinois University Edwardsville.
          
          
      12. Participation in officially recognized activities or sports.
          
          
      13. Weight and height of members of athletic teams.
          
          
      14. Date of birth.
          
          
3. BASIC POLICY REGARDING DISCLOSURE OF INFORMATION FROM EDUCATIONAL RECORDS
   
   
   1. Disclosure not requiring prior consent.
      
      

      The appropriate recordkeeping office shall obtain the written consent of the student before disclosing "personally identifiable information" from the educational records of a student, except in the case of "directory information" as delineated in (II.E.) or disclosure to:
      
      

      1. The student himself/herself.
         
         
      2. University personnel who have a legitimate educational interest to permit their functioning or research. The sufficiency of the interest will be determined by the head of the unit from which the records are sought.

         Student information supplied to any SIUE personnel or unit is provided on the basis that it is needed to permit their necessary functioning. All members of the faculty, administration, and clerical staff must respect confidential information about students which they require in the course of their work. They are bound by the conditions outlined in this policy statement relative to the release of student information. All institutional personnel should be alert to refer promptly to the appropriate office, requests for transcripts, certifications, or other information which that office typically provides.
         
         

      3. Officials of other schools or school systems in which the student seeks or intends to enroll, if there is a legitimate interest. The sufficiency of the interest will be determined by the head of the unit from which the records are sought. A copy of any information sent will be provided to the student upon written request.
         
         
      4. Faculty or students conducting student characteristic research providing the research project has written approval of the academic unit executive officer sponsoring the research and providing guarantees are made that no "personally identifiable information" will be published or released and such information will be destroyed when no longer needed for the purpose for which it is collected.
         
         
      5. Certain state and federal representatives specified by Title 20, par. 1232g for the sole purpose of evaluation and auditing of governmentally funded programs in which the University participates, with the guarantee that the identity of the students shall be protected.
         
         
      6. State and local officials as directed by State Statute adopted prior to November 19, 1974, as approved by the General Counsel of the University.
         
         
      7. Authorized organizations conducting studies for, or on behalf of, state or federal educational agencies or institutions for the purpose of developing, validating, or administering predictive tests, administering student aid programs, and improving instruction, with the guarantee that the identity of the student shall be protected and such information will be destroyed when no longer needed for the purpose for which it is collected.
         
         
      8. Appropriate parties in connection with financial aid for which the student has applied or received.
         
         
      9. Accrediting organizations to carry out their accrediting function, with the guarantee that the identity of the student shall be protected.
         
         
      10. Appropriate persons in connection with an emergency, if knowledge of such information is necessary to protect the health or safety of a student or other persons.
          
          
      11. Comply with a judicial order or subpoena. The sufficiency of the order or subpoena will be determined by the General Counsel.

          Disclosure without consent can only be effected with written notice given the student in all cases as soon as practically possible.
          
          

   2. Disclosure Requiring Prior Consent
      
      
      1. Except as listed in "A" above, all requests for student information other than "directory information" must be accompanied by a written consent of the student.
         
         
      2. The written consent required by this section must be signed and dated by the student giving the consent and shall include (a) a specification of the records to be disclosed, (b) the party or parties to whom the disclosure is to be made, and (c) the purpose or purposes of the disclosure.
         
         
      3. When a disclosure is made pursuant to this section, the appropriate recordkeeping office shall, upon request, provide to the student a copy of the records which are disclosed.
         
         
      4. Student information will not be released to parents of students without the student's written consent. Exceptions to this procedure can be made if the Office of the Registrar is provided with appropriate documentation certifying the student as dependent as defined by the Internal Revenue Code. In the case of divorced parents, Illinois law requires the consent of both parents and the student before academic information may be released to the noncustodial parent. (750 ILCS 5/513).
         
         
      5. Disclosure of information will be effected only with written agreement of the third party not to effect further disclosure.
         
         
      6. The written consent of the student shall be filed in his permanent record.
         
         
   3. Disclosure of Directory Information
      
      

      Directory information may be released by the University at any time. The University must publish information relating to what constitutes directory information at least once each academic year in the campus student newspaper or other designated publication with wide circulation. Enrolled students must be given a reasonable period of time to inform the University in writing, through the Office of the Registrar, that they do not wish their directory information to be released without their prior written consent. The Office of the Registrar will be responsible for identifying or withholding directory information which the student requests not to be released and for informing all University recipients of that information that such information is not to be released. This directory information hold will remain in effect until a written cancellation is filed by the student with the Office of the Registrar.
      
      

      The procedural requirements of this section do not apply to the disclosure of directory information from the educational records of an individual who is no longer in attendance at the University. Thus, the University (or appropriate recordkeeping office) is not required to give public notice of the above to former students.
      
      

      All recipients of student information will be bound by this policy. Lists of student information are never knowingly provided to any requesting party for a commercial or political purpose.
      
      

   4. Records of Disclosure Made

      Records of disclosure are not required to be kept in the record of a student when the disclosure is initiated by the student himself/herself. The institution shall maintain a record within the student's educational record, indicating all individuals, agencies, or organizations which have requested or obtained access to a student's educational record which will indicate specifically the legitimate interest that each person, agency, or organization has in obtaining same.
      
      

      Subject to the provisions herein, the University may disclose "personally identifiable information" from the educational records of a student only on the condition that the party to whom the disclosure is made will not further disclose the information without the student's written consent, except in the case of disclosure of "directory information".
      
      

      The University shall, except for the disclosure of "directory information", inform the party to whom disclosure is made of the obligation to receive the student's consent before further disclosure to other parties.
      
      

   5. Waiver of Right to Inspect and Review Educational Records
      
      
      1. The student may waive his or her right to inspect and review his/her educational records. The waiver, in order to be valid, must be in writing and signed by the student. The University (or each appropriate recordkeeping office) may not require a waiver of rights, but it may request said waiver.
         
         
      2. If a student has waived his/her right to see confidential letters of recommendation placed in his/her record after January 1, 1975, the waiver will be effective only if: (a) the applicant or student is, upon request, notified of the names of all individuals providing the letters or statements; (b) the letters or statements are used only for the purpose for which they were originally intended, and (c) such waiver is not required by the University as a condition of admission to or receipt of any other service or benefit from the University.
         
         
      3. A waiver may be revoked, but the revocation must be in writing and signed by the student. Revocation of waiver will affect only documents received after its execution.
         
         
4. IDENTIFICATION AND DESCRIPTION OF STUDENT INFORMATION
   
   
   1. Academic Records
      
      

      The Office of the Registrar, (The Office of the Registrar at the School of Dental Medicine for students enrolled in the School of Dental Medicine), retains the official academic record of a student. It is a cumulative history of a student's admission, registration, and academic participation and performance. Certain biographic and demographic information is also kept for identification for enrollment and research­related purposes. For information concerning these records, contact the Office of the Registrar, (the Office of the Registrar at the School of Dental Medicine for students enrolled in the School of Dental Medicine.) Academic records may also be maintained in academic units, departments, and schools or colleges. For information concerning these records contact the head of the academic unit, department, or schools or colleges in question. The Office of Institutional Research also maintains some academic records.
      
      

   2. Financial Records
      
      

      Offices within the business area maintain certain financial records which relate to the payment and accounting of tuition, fees, and other charges. They also maintain records which record student loans and grants. For information concerning these records, contact the Bursar's Office.

      For billing purposes, the Office of the Registrar, (The Office of the Registrar at the School of Dental Medicine for students enrolled in the School of Dental Medicine), maintains a record of financial aid received and tuition and fees paid. For information concerning these records, contact the Office of the Registrar (the Office of the Registrar at the School of Dental Medicine for students enrolled in the School of Dental Medicine).
      
      

      The Office of Student Financial Aid, (or the Office of Student Affairs for the School of Dental Medicine), maintains records of students receiving loans, grants, and aid along with scholarship information and some academic information. It also maintains records pertinent to student employment including the family financial statement. For information concerning these records, contact the Director of Student Financial Aid, or the Director of Student Affairs for students enrolled in the School of Dental Medicine.
      
      

      The Housing Office maintains records of housing accounts. For information concerning these records, contact the Director of Housing.
      
      

   3. Medical Counseling/Clinical Records

      The University Health Service maintains medical records of students. Only information pertinent to the health of the individual is contained therein. For information concerning these records, contact the Director of Health Service.

      Counseling Services maintains counseling records pertinent to services rendered by that office. For information concerning these records, contact the Director of Counseling Services.
      
      

   4. Disciplinary Records
      
      

      The Office of the Vice Chancellor for Student Affairs (or The Office of the Dean of the School of Dental Medicine for students enrolled in the School of Dental Medicine), maintains records of disciplinary action which has been taken against a student with documentation pertaining thereto. That office also maintains only the academic information necessary to permit its functioning. For information concerning these records, contact the Vice Chancellor for Student Affairs, or the Dean of the School of Dental Medicine for students enrolled in the School of Dental Medicine.
      
      

   5. Placement Records
      
      

      The Career Development Center creates a record for those persons who wish to avail themselves of its services, with the student's voluntary participation. This information is distributed to potential employers. It consists of self­completed resumes and various personal references. For information concerning these records, contact the Director of the Career Development Center.
      
      

5. ACCESS TO RECORDS
   
   
   1. Right to Inspect or Review Educational Records
      
      
      1. The student has the right to physically review his records in the presence of a designated University representative.
         
         
      2. Requests for review are required to be submitted in writing to the appropriate office.
         
         
      3. That office shall comply with the request within a reasonable time, but in any case, compliance shall be effected not more than thirty (30) days after the receipt of the request.
         
         
      4. Where requested by the student concerned, a written interpretation of the record shall be provided by qualified University personnel and said interpretation filed in the educational record.
         
         
      5. Original records cannot be removed from University premises. A copy will be provided if requested, but only if not providing a copy will preclude review of the educational record by the student.
         
         
      6. Copies of transcripts from other educational institutions will be provided only if the original source of those transcripts is no longer available or going to the original source would cause undue hardship as determined by this University.
         
         
   2. Limitations on Right to Inspect or Review
      
      
      1. The student may not inspect the following records:
         
         
         1. Financial records and statements of his parents.
            
            
         2. Confidential letters or statements of recommendation, placed in records before January 1, 1975, so long as they were solicited with an understanding of confidentiality and are used only for the purpose for which they were written.
            
            
         3. Confidential letters of recommendation and confidential statements of recommendation placed in the educational records of the student after January 1, 1975, are subject to the student's right to inspect and review unless the student has signed a "written waiver of the student's right to access" after being notified of the names of those persons making confidential recommendations, and that such recommendations are used solely for the purpose for which they were intended.
            
            
      2. Reports that involve two or more persons are considered confidential to protect the identity of the other person(s), but review is permitted as to that portion relating to the student concerned.
         
         
6. CHALLENGING CONTENTS OF A STUDENT'S EDUCATIONAL RECORD
   
   
   1. Purpose
      
      

      A student has the right to challenge the content of a record on the ground that he/she believes it is inaccurate, misleading, or other wise in violation of his/her privacy or other rights and to have inserted in the record his/her written explanation of its contents. Academic grade review procedures are covered by separate policy. (A hearing may not be requested by a student to contest the assignment of a grade; however, a hearing may be requested to contest whether or not the assigned grade was recorded accurately in the educational records of the student.)
      
      

   2. Procedure
      
      

      To initiate such a challenge, the student shall, within sixty (60) days after he/she has inspected and reviewed the record in question for the first time, file with the University office responsible for maintaining such record a written request for correction, on a form specified by the University. Within thirty (30) days following receipt of such request, the head of such office, or his/her designated representative, shall review the record in question with the student, and either order the correction or deletion of such alleged inaccurate, misleading, or otherwise inappropriate data as specified in the request, or notify the student of the right to a hearing, at which the student and other persons directly involved in the establishment of the record shall have an opportunity to present evidence to support or refute the contention that the data specified in the request is inaccurate, misleading, or otherwise inappropriate. The head of the office, or his/her designated representative, shall have five (5) days from the time of the review to notify the student of his/her decision. If the student desires a hearing on the decision, the student shall exercise said option in writing within ten (10) days of said notice, and file the request for a hearing with the head of the office.
      
      

   3. Hearing
      
      

      The student shall be given written notice, sent to his/her last known local address of the time and place of such hearing, not less than ten (10) days in advance. The hearing will be conducted by a University representative who does not have a direct interest in the outcome. The student is permitted to challenge the hearing officer as to qualification and/or prejudice. Any disagreement as to the selection of the hearing officer will be resolved by the Chief Officer for Student Affairs, or designee. The hearing must occur no later than forty­five (45) days from a request for same.
      
      

      The student shall have the right to attend the hearing, to be advised by an individual of his/her choice at his/her own expense, including an attorney, and to call witnesses in his/her behalf. The student shall be notified in writing of the decision within ten (10) days following the hearing. Such decision is final, subject to appropriate review by the Chancellor, President and Board of Trustees at the request of either party. The decision reached shall be based solely upon the evidence presented at the hearing and shall include a written summary of the evidence and reasons for the decision, the same of which shall be filed in the student's official record.
      
      

7. DESTRUCTION OF RECORDS
   
   

   The University may destroy educational records when they are no longer necessary, with the following limitations:
   
   

   1. Educational records may not be destroyed if there is an outstanding request to inspect and review them.
      
      
   2. Explanations placed in the record by the student and the record of requests and disclosures of information must be maintained as long as the educational record to which they pertain is maintained.
      
      
8. RIGHT TO FILE COMPLAINTS
   
   
   1. If the student thinks his or her rights have been violated, he or she should first file a complaint with the head of the office which maintains the records in question.
      
      
   2. After exhausting all the internal remedies available within the University, if the student still thinks his or her rights have been violated, written complaints can be filed with:

      The Family Educational Rights & Privacy Act Office
      Department of Health, Education and Welfare
      330 Independence Avenue, S.W.
      Washington, D. C. 20201
      

      The Office shall notify the complainant and the University of the receipt of the complaint and an investigation will follow.

Approved by Chancellor effective 11/15/02
This policy was issued on November 22, 2002, replacing the November 20, 2002 version.
Document Reference: 3G2
Origin: OP 11/78; OC 12/7/98; OC 11/15/02