COP 03-1701: Student Records Procedures

Purpose Statement

The purpose of this policy document is to describe the manner in which the Family Educational Rights and Privacy Act (FERPA) regulations are implemented at Florida SouthWestern State College (College).

Guidelines

The purpose of this policy document is to describe the manner in which FERPA regulations are implemented at the College. This document identifies the custodians of records, delineates directory information, and summarizes the students’ rights regarding student records. When appropriate, this policy identifies specific laws and regulations.

1. Introduction
   The College respects each student’s right to privacy and releases, provides access to, and maintains a student’s record in accordance with all applicable state and federal regulations.
2. Custodians of Student Records
   The College has designated the Registrar as the official custodian of general student records. The Director of Financial Aid has been designated as the official custodian of student financial aid records. The information contained in a student’s record becomes the property of the College and is not released without the written permission of the student.
3. Policies Governing Student Records
   1. Directory Information
      • Under the terms of FERPA, the College has established the following as directory information:
        1. Student's name
        2. Major
        3. Date(s) of enrollment
        4. Degree(s) and honors earned with dates awarded
        5. Participation in officially recognized activities or sports
        6. Enrollment status (e.g., full-time or part-time student status)
        7. Previous colleges attended
        8. Photographs
        9. Awards
      • Although the above directory information may be available for release to the general public, the College does not routinely release such information to third parties. FSW does share information with certain college partners, which may act as agents of the College authorized to release student information in the performance of their contracted duties. These partners include: National Student Clearinghouse, BankMobile, Parchment, CareerSource, Florida public universities, and Independent Colleges and Universities of Florida (ICUF).
        
        Under FERPA, students have the right to inform the College that any or all of the student’s directory information is not to be released. The College honors the student’s request to restrict the release of “Directory Information” as stated previously. To withhold information, a student must notify the Office of the Registrar in writing. Status of disclosure is binding and all records are noted: “CONFIDENTIAL”. No information is to be released without the written consent of the student.
   2. Solomon Amendment
      Under a 1997 rule adopted by the United States Department of Defense, the College, if requested, must provide to the U.S. military the student's name, address, telephone number, date of birth, level of education, current major and degrees received for all students age 17 or older.
   3. Notification of Access and Review of Student Records
      FERPA affords students certain rights with respect to their education records. These rights are:
      1. The right to inspect and review their education record within 45 days of the College receiving a request for access. The student should submit to the Registrar or other appropriate College official a written request that identifies the record(s) the student wishes to inspect. The College official arranges for access and notifies the student of the time and place where the student may inspect the records. In the case where a request is presented to a College official who does not maintain the requested records, the College official advises the student of the correct official to whom the request should be addressed.
      2. The right to request the amendment of their education records if the student believes the record is inaccurate or misleading. The student should submit to the Registrar or other appropriate College official a written request clearly identifying the part of the record the student wants changed, and specifying why it is inaccurate or misleading. The College official notifies the student if it is decided to amend or not to amend the record as requested by the student. The College official advises the student of their right to a hearing regarding the request for amendment and provides additional information regarding the hearing procedures to the student.
      3. The right to request the non-disclosure of personally identifiable information contained in their education record, except to the extent that FERPA authorizes disclosure without consent. Students should contact the Office of the Registrar for more information. One exception that permits disclosure without consent is the disclosure to school officials with legitimate educational interests. A school official is a person employed by the College in an administrative, supervisory, academic, research, or support staff position (including law enforcement unit personnel), a person or company with whom the College has contracted (such as an attorney, auditor, or collection agent), a person serving on the District Board of Trustees, or a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another school official in performing their duties. A school official has legitimate educational interests if the official needs to review an education record to fulfill their professional responsibility. Upon request, the College discloses education records without consent to officials of school(s) to which the student seeks or intends to enroll.
      4. The right to file a complaint with the U.S. Department of Education concerning alleged failures by the College to comply with the requirements of FERPA.
   4. Notification of Social Security Number Collection and Usage
      In compliance with Florida Statute 119.071(5), the College collects and uses student social security numbers (SSNs) only for the following purposes in performance of the College’s duties and responsibilities. To protect student identity, the College will protect all social security numbers from unauthorized access, never release social security numbers to unauthorized parties, and assign each student/employee a unique identification number (Banner ID#). This unique ID number is used for all associated employment and educational purposes at the College.
      1. Office of the Registrar
         Federal legislation relating to the Hope Tax Credit requires all postsecondary institutions to report student SSNs to the Internal Revenue Service. This IRS requirement makes it necessary for colleges to collect the SSN of every student. A student may refuse to disclose his or her SSN to the College, but the IRS is then authorized to fine the student in the amount of $50.00.
         
         In addition to the federal reporting requirements, the public school system in Florida uses SSNs as a student identifier (Florida Statutes 1008.386). In a seamless K- 20 system, it is beneficial for postsecondary institutions to have access to the same information for purposes of tracking and assisting students in the smooth transition from one education level to the next. All SSNs are protected by the Family Educational Rights and Privacy Act (FERPA) and are never released to unauthorized parties.
      2. Financial Aid Office
         The Office of Financial Aid requires students to submit their social security numbers on various forms to correctly identify applicant’s, match each applicant’s financial aid record with the student record, and help coordinate state aid programs with federal and institutional aid programs.
      3. Human Resources Office/Payroll Office
         The SSN is used for legitimate employment business purposes in compliance with:
         1. The Application and Employment Packet: completing and processing the Federal I-9 (Department of Homeland Security)
         2. Completing and processing payroll documents: Federal W4, W2 and W9 for 1099 reporting (Internal Revenue Service); Federal social security taxes (FICA); processing and distributing Federal W2 (Internal Revenue Service); direct deposit files
         3. Completing and processing quarterly unemployment reports (FL Dept. of Revenue)
         4. Completing and processing Florida Retirement Contribution reports (FL Dept. of Revenue)
         5. Workers Comp Claims (FCCRMC and Department of Labor)
         6. Completing and processing federal and state employee and educational reports
         7. Completing and processing 401a, 403b and 457b contribution reports
         8. Completing and processing group health, life and dental coverage enrollment
         9. Completing and processing various supplemental insurance deduction reports
         10. Providing your Social Security number is a condition of employment at the College.
   5. Enrollment Verifications
      Students needing official verification of their enrollment should submit a completed Enrollment Verification Request to the Office of the Registrar at least one week before the verification is needed. Enrollment Verification requests are only processed for the current or previous semesters. Future semester enrollment verifications are only processed after the last day to drop with a refund for that semester, in line with the College’s academic calendar. Students are encouraged to contact the National Clearinghouse for official enrollment verifications.

Procedures