Miscellaneous

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

PURPOSE

Southern Illinois University Edwardsville, hereinafter referred to as the "University" or "SIUE", 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 University enacts the following Policy.
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 their 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 Department 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 their 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 (preferred name will be utilized where one is indicated).
  2. Address including local, home, permanent (student must opt-in for third party release).
  3. Telephone number including landline, campus, and mobile (student must opt-in for third party release).
  4. E-mail address including SIUE and non-SIUE (student must opt-in for third party release).
  5. Major field of study.
  6. Whether a student is currently enrolled.
  7. Full or part-time enrollment status.
  8. Class (freshmen, sophomore, etc.).
  9. Academic Level (undergraduate, graduate, professional).
  10. Dates of Enrollment.
  11. Degrees and awards received, including dates, honors, and level of distinction.
  12. Participation in officially recognized activities or sports.
  13. Weight and height of members of athletic teams.
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 themself.
  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 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 University Office of General Counsel.
  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 Office of 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.
  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 their 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. 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, or that they opt to have their address, email, and telephone number information shared as directory information with third parties. 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. The Office of the Registrar will be responsible for establishing a process for students to opt-in to having their address, email, and telephone information shared as directory information with third parties and unless a student opts in, this information will not be provided to third parties. This directory information hold, or the opt-in for address, email, and telephone number information will remain in effect until a written cancellation or opt-in change 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.
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 themself. 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 their right to inspect and review their 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 their right to see confidential letters of recommendation placed in their 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.
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.
ACCESS TO RECORDS
1. Right to Inspect or Review Educational Records
  1. The student has the right to physically review their 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 their 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.
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 they believe it is inaccurate, misleading, or other wise in violation of their privacy or other rights and to have inserted in the record their 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 they have 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 their 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 their designated representative, shall have five (5) working days from the time of the review to notify the student of their 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 their 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 perceived bias. Any disagreement as to the selection of the hearing officer will be resolved by the Vice Chancellor for the area that maintains the record at issue in the hearing, or their 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 their choice at their own expense, including an attorney, and to call witnesses on their behalf. The student shall be notified in writing of the decision within ten (10) working days following the hearing. Such decision is considered the final University decision on the matter. 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.
DESTRUCTION OF RECORDS

The University may destroy educational records when they are no longer necessary, subject to all applicable State and Federal laws and University policies, 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.
RIGHT TO FILE COMPLAINTS
1. If the student thinks their rights have been violated, they 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 their rights have been violated, written complaints can be filed with:
  
  U.S. Department of Education
  Student Privacy Policy Office
  400 Maryland Ave, SW
  Washington, D. C. 20202-8520
  [email protected]

Approved by Chancellor effective 9/5/24
This policy was issued on September 9, 2024, replacing the November 22, 2002 version.
Document Reference: 3G2
Origin: OP 11/78; OC 12/7/98; OC 11/15/02; OC 9/5/24

Policies & Procedures

Table of Contents

Miscellaneous

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