Article IX. Student Records Section

9.01 Privacy of Student Education Records

1. GLB Act of 16 CFR part 314 Safeguarding Information. As a result of regulations promulgated in May 2000, colleges and universities are deemed to be in compliance with the privacy provisions of the GLB Act if they are in compliance with the Family Educational Rights and Privacy Act (FERPA). Doane College is in compliance with FERPA. Guidelines for FERPA are published in Doane’s Student, Faculty, and Staff Handbooks.
   
   Doane is also subject to the provisions of the Act related to the administrative, technical, and physical safeguarding of customer information. The College is required to implement and maintain a written information security program that contains administrative, technical and physical safeguards appropriate to size and complexity. The following is the administrative response to Safeguarding Customer Information. Members of the President’s Cabinet are designated individuals responsible for coordinating the information security program. All reasonable steps have been taken to identify the foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in unauthorized disclosure, misuse and alteration, destruction, or other compromise of such information.

Employees have been notified of FERPA requirements and follow established procedure for safeguarding confidential customer information. Doane’s information systems, including processing, storage, transmission, and disposal are secured by firewalls, packet shapers, sniffers, and virus protection. Detecting, preventing, and responding to attacks, intrusions, security holes, attempted breaches, and other system failures are the highest priority for network administrators.

1. A statement of conduct that addresses the monitoring and disclosure of customers’ electronic activity governs Doane technology personnel. Doane College reviews and oversees service providers and takes steps to retain providers that are capable of maintaining appropriate safeguards for customer information. The President’s Cabinet periodically reviews and adjusts the College’s security program based on any material changes to operations, or any other circumstances that are known to have or that may have a material impact on Safeguarding Customer Information.
   
   Family Educational Rights and Privacy Act (FERPA)
   The Family Educational Rights and Privacy Acts of 1974 (commonly referred to as “FERPA” or the “Buckley Amendment”) is designed to protect the confidentiality of students’ educational records and to give students access to their records to assure accuracy. FERPA outlines four rights with respect to students Education Records. They are:
   1. ACCESS TO EDUCATION RECORDS: students have the right to inspect and review their Education Records within 45 days of the day the College receives a written request for access, anytime after their matriculation.
      1. REQUEST FOR AMENDMENT OF EDUCATION RECORDS: students have the right to request amendment of Education Records if they believe the records are inaccurate, misleading or in violation of their privacy rights. DISCLOSURE OF EDUCATION RECORDS: this right protects confidentiality of student records and requires the student’s signature to release academic records, such as transcripts. Some exceptions exist such as school officials who’ve been determined to have a legitimate educational interest, or information determined to be directory information. Examples of directory information include: name, addresses, e-mail, telephone numbers, major and/or minor fields of study, degree sought, expected date of completion of degree requirements and graduation, degrees conferred, awards and honors (e.g. Dean’s list), full or part time enrollment status, dates of attendance, or photograph.
   2. COMPLIANCE: students have the right to submit complaints concerning the College’s compliance with the requirement of FERPA to:
      
      Family Policy Compliance Office
      U.S. Department of Education
      400 Maryland Ave., S.W.
      Washington, DC 20202-4605
      
      e-mail address: ferpa@ed.gov
      
      For more information on FERPA, and to see the entire FERPA Policy, please visit the Registrar’s Web page on the Doane Web site. Questions and concerns can be sent to the Registrar at registraroffice@doane.edu or 402.826.8251.
2. Summary of Federal Law
   Federal law applies to public schools that receive federal education funds. In order to continue to be eligible to receive federal monies, schools must comply with FERPA. The following is a highlight of FERPA, which generally gives a parent certain rights with respect to his or her child’s education records. When students reach age 18 or enroll in college, these rights are transferred to the student:
   1. Students have the right to inspect and review the student’s education records maintained by the school. Schools do not have to provide copies of the records but must make the records accessible.
   2. Students have the right to request that a school correct records which they believe to be inaccurate or misleading. If the school decides not to amend the record, the student then has the right to a formal hearing. After a formal hearing, if the school still decides not to amend a student’s record, the student has the right to place a statement with the record setting forth his or her view about the contested information.
3. Generally, schools must have written permission from a student in order to release any information from a student’s education record. However, FERPA allows schools to disclose those records, without consent, to the following parties or under the following conditions:
   1. School officials with legitimate education interests.
   2. Other schools to which a student is transferring.
   3. Specified officials for audit or evaluation purposes.
   4. Appropriate parties in connection with financial aid to a student.
   5. Organizations conducting certain studies on behalf of the school.
   6. Accrediting organizations.
   7. Directory information.
   8. To comply with a judicial order or lawfully issue subpoena.
   9. Appropriate officials in cases of health and safety emergencies.
   10. State and local authorities, within the juvenile justice system, pursuant to specific Nebraska law.

Students have the right to write to the Family Policy Compliance Office of the United States Department of Education to file a complaint related to the privacy of education records and FERPA. If a student discovers an error in the records, it should be pointed out to the official in charge of the record. The Vice President for Academic Affairs is the hearing officer to resolve disagreements. A hearing will be conducted and decided within 14 days following a written request by the student.

Doane College personnel have access to student records. Federal law and College policy make it possible for a limited number of individuals and groups to have access to records, but they must leave their names and the interest they have in the record. Doane College may disclose appropriately designated “directory information” without written consent, unless the student advises Doane College to the contrary in accordance with Doane College’s procedures.

The primary purpose of directory information is to allow Doane College to include this type of information from student education records in certain school publications. Examples include:

1. A playbill, showing a role in a drama production.
2. The annual yearbook.
3. Honor roll or other recognition lists.
4. Graduation programs.
5. Sports activity sheets, such as for football, showing weight and height of team members.

Directory information, which is information that is generally not considered harmful or an invasion of privacy if released, can also be disclosed to outside organizations without the student’s consent. Outside organizations include, but are not limited to, companies that manufacture class rings or publish yearbooks. If students do not want Doane College to disclose directory information from their education records without prior written consent, the Registrar’s Office must be notified in writing.

Students have a right to receive copies of their records at a cost of $5 per transcript. Student records retained by some offices are periodically destroyed. For specific information on types of information maintained, the location of records, persons in charge of records, and destruction of records, the student should consult the Directory of Records maintained with the Doane College Policy on Access To and Release of Student Records. Students have the right to file complaints with the FERPA Office concerning alleged failure by the College to comply with the Act. Questions concerning FERPA may be referred to the Student Leadership Office.