To: Vice Presidents, Chancellors, Deans, Directors and Heads of Schools, Divisions, Departments, and Offices

Re: University Policy Regarding the "Family Educational Rights and Privacy Act of 1974" (as amended)

Purdue University herewith notifies all students and staff of the official University policy regarding student rights and institutional responsibilities under the "Family Educational Rights and Privacy Act of 1974", which has been amended from time to time. This statement of University policy is effective as of August 7, 2000.

1. Policy Statement on Protection of Rights and Privacy of Students

   1. Definitions: As used in this policy, the following terms have the following meanings.

      Alleged Perpetrator of a Crime of Violence: A student who is alleged to have committed acts that, if proven, would constitute any of the following offenses or attempts to commit the following offenses: arson; assault offenses; burglary; criminal homicide (manslaughter and murder); destruction, damage, or vandalism of property; kidnapping or abduction; robbery; and/or forcible sex offenses.

      Alleged Perpetrator of a Nonforcible Sex Offense: A student who is alleged to have committed acts that, if proven, would constitute statutory rape or incest.

      Dates of Attendance: The period of time during which a student attends or attended the University. The term does not include specific daily records of attendance.

      Directory Information: Information contained in an Education Record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. The University currently considers the following listed items to be Directory Information: student's name, local and home address, local and home telephone listing, electronic mail address, school, curriculum, classification, enrollment status and credit hour load, dates of attendance, degrees, awards, and honors received, participation in officially recognized activities, sports photograph, and weight, height, and position of members of athletic teams. The University reserves the right to amend this listing consistent with federal law and regulations and will notify students of any amendments by publication in the annual edition of University Regulations.

      Disclosure Logs: Documents maintained with a studentŐs Education Record by the appropriate University records custodians which records for each request for and each disclosure of Personally Identifiable Information from the Education Records of a student which indicates everyone who has requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it (other than those enumerated in E).

      Education Records: Any records maintained in any form by the University that are directly related to a student.

      FERPA: Family Educational Rights and Privacy Act, as amended.

      Final Results: The name of the student, the violation committed and any sanction imposed by the University against the student.

      Parent: Includes a natural parent of a student, a guardian, or an individual acting as a parent in the absence of a parent or guardian.

      Personally Identifiable Information: A studentŐs name; the name of a studentŐs parent or other family member; the address of a student or studentŐs family; a personal identifier, such as the social security number or student number, or any portion thereof; a list of personal characteristics that would make a studentŐs identity easily traceable; or other information that would make a studentŐs identity easily traceable.

      Student: One who is presently enrolled and attending or has been enrolled and attended the University and for whom the University maintains records. For purposes of this policy, one is deemed to be enrolled once fees have been paid for a session (semester) or the first day of the session (semester) in which the student is enrolling, whichever occurs first.

      Student Conduct Code: Regulations governing student conduct as set forth in University Regulations.

      University: Purdue University West Lafayette; Purdue University Calumet; Purdue University North Central; Indiana University Purdue University Fort Wayne; Indiana University Purdue University Indianapolis; or Purdue University Statewide Technology.

      University Officials: Members of the University faculty and staff and internal or external auditors.

   2. Rights of Students.
      1. Students of the University have a right to:
         1. Be provided a list of the types and location of educational records maintained by the University and the titles and addresses of the officials responsible for those records (see appropriate appendix for each campus);
         2. Inspect and review Education Records (except as excluded in G below), within 45 days of a written request being presented to the authorized custodian of the records in question;
         3. Receive a response from the University to reasonable requests for explanations and interpretations of Education Records;
         4. Obtain a copy of Education Records (except as excluded in G below), for which students may be required to pay the reproducing costs of ten cents per page. (This cost does not apply to official transcripts.);
         5. Request amendments to their Education Records to insure that they are not inaccurate, misleading, or otherwise in violation of privacy rights, and if the University refuses to make such amendments, the student shall have an opportunity for an administrative hearing to challenge the content of the record on the same grounds and to insert a written statement or explanation commenting upon the information in the record;
         6. Inspect and review only such parts of educational material documents as relate to him/her or to be informed of such specific information;
         7. Receive a copy, if desired, of all records supporting enrollment or transfer to another school, and have an opportunity for an administrative hearing to challenge the content of these records;
         8. Be notified, upon request, of the names of all individuals providing confidential letters and statements as requested by the student, regarding admission, application for employment, or the receipt of an honor or honorary recognition;
         9. Revoke, in writing, any previously executed waiver of rights under FERPA, with respect to any actions occurring after revocation;
         10. Inspect the Disclosure Logs kept permanently with the studentŐs Education Record; and
         11. File complaints with the Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue S. W., Washington, D.C. 20202-4605.

      2. A student does not have the right to inspect the records maintained by the University at a campus at which the student has not been enrolled.

   3. Disclosure of Education Records. Education Records or other Personally Identifiable Information (other than Directory Information) may not be disclosed without the student's prior written consent except in the following instances:
      1. To the student;
      2. To University Officials when their legitimate educational interest in those records has been determined by the respective records custodian. (In making that determination, the custodian shall assume that a "legitimate educational interest" has been demonstrated if he or she is assured that the official requires the information to assist in pursuing student and University educational or vocational objectives);
      3. To officials of other schools in which the student seeks or intends to enroll, provided the student may upon request have a copy of the records so transferred and an opportunity for a hearing;
      4. In connection with determining eligibility, amounts, and conditions, or enforcing terms of financial aid for which the student has applied or that which he or she has received;
      5. To parents of a dependent student, as defined in section 152 of the Internal Revenue Code of 1986;
      6. To comply with a judicial order or lawfully issued subpoena, provided the University makes a reasonable effort to notify the student of the order in advance of the compliance therewith, unless such notification is not required by FERPA;
      7. To appropriate parties in connection with an emergency if the knowledge of such information is necessary to protect the health or safety of the student or other individuals;
      8. To law enforcement agencies and to certain other governmental authorities and agencies as are enumerated in and required or permitted by FERPA;
      9. To a court in connection with legal action by the University against a student or a studentŐs parent or by a student or studentŐs parent against the University;
      10. To a victim of an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense. Such a disclosure may only include the Final Results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may disclose the Final Results of the disciplinary proceeding regardless of whether the University concluded a violation was committed;
      11. In circumstances where the University has determined through its disciplinary proceedings that a student is (a) an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense; and (b) with respect to the allegation made against the student, the student has committed a violation of the student Conduct Code. Such a disclosure may only include the Final Results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may not disclose the name of any other student, including a victim or witness, without the prior written consent of the other student. This paragraph applies only to disciplinary proceedings in which the Final Results were reached on or after October 7, 1998;
      12. To the parent of a student who is under the age of 21 at the time of the disclosure where a student has violated any Federal, State or local law, or any of the rules or policies of the University, governing the use or possession of alcohol or a controlled substance and where the University has determined that the student has committed a violation of the Student Conduct Code with respect to that use or possession;
      13. To accrediting organizations to carry out their accrediting functions; and
      14. To organizations conducting studies for, or on behalf of, educational agencies or institutions to:
          1. Develop, validate, or administer predictive tests;
          2. Administer student aid programs; or
          3. Improve instruction.
             
             

          Disclosures made pursuant to this paragraph are subject to the requirements that (i) the studies are conducted in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization; and (ii) the information is destroyed when no longer needed for the purposes for which the study was conducted.

   4. Disclosure of Directory Information. The University hereby gives notice that the categories of information defined herein as Directory Information may be released without written consent of the student. Students may request, by reporting in person to the Office of the Registrar, that any or all of the above listed categories of Directory Information not be released without their consent. Such requests shall apply only to subsequent actions by the University and shall remain in place until removed by written request of the student. Students requesting that information be withheld from the printed student and staff telephone directory must make such a request prior to the end of the first week of the fall semester. In addition, students living in University Residences must contact their hall manager to restrict access to Directory Information published by University Residences. Student employees must contact the Department of Personnel Services to restrict access to any employment-related Directory.

   5. Disclosure Logs. The appropriate University records custodian shall for each request for and each disclosure of Personally Identifiable Information from the Education Records of a student, maintain a record kept with these records for as long as the Education Records are maintained which indicates the persons who have requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it. However, this requirement does not apply to:
      1. Disclosures to a parent of a dependent student;
      2. Disclosures pursuant to the written consent of the student, when the consent is specific with respect to the party or parties to whom the disclosure is to be made;
      3. Disclosures to University Officials, when it has been determined that the official has a legitimate educational interest; and
      4. Disclosures of Directory Information.

   6. Notice to Recipients of Education Records. In cases where the University discloses Personally Identifiable Information from the Education Records of a student under paragraphs C (2) - (4), (6) - (8), (10), (13), and (14), the recipient shall be informed that the information is released upon the condition that it will not be disclosed to any other party (except to its officers, employees, or agents in the case of a recipient institution, agency or organization, but still only for the purpose for which the disclosure was made), without the prior written consent of the student.

   7. Records Excluded from the Definition of Education Records. The following materials, information, and records which are excluded from the definition of Education Records are not available to students for inspection, review, challenge, correction, or deletion:

      1. Confidential letters and statements of recommendation which were placed in the Education Records prior to 1 January 1975, if they are not used for purposes other than those for which they were specifically intended;

      2. Confidential letters and statements of recommendations, used solely for the purposes for which they were specifically intended, if the student has waived the right to inspect and review recommendations:
         1. regarding admission to an educational institution,
         2. regarding an application for employment, and
         3. regarding the receipt of an honor or honorary recognition;

      3. Financial records and statements of the student's parents or any information contained therein;

      4. Records of instructional, supervisory, or administrative personnel or educational personnel ancillary thereto, which are in the sole possession of the maker thereof and are not accessible or revealed to any other person except a substitute;

      5. Records which are created or maintained by a physician, psychiatrist psychologist or other recognized professional or paraprofessional acting or assisting in that capacity, and are used only in providing treatment to the student, and not available to anyone other than persons providing such treatment, except that such records can be personally reviewed by a physician or other appropriate professional of the student's choice;

      6. Records made and maintained in the normal course of business which relate exclusively to the individual in his or her capacity as an employee and are not available for any other purpose; this exclusion does not apply to an individual who is employed by the University as a result of his/her status as a student (i.e., interns, graduate assistants, etc.);

      7. Records which contain only information relating to a person after that person is no longer a student at the University; and

      8. Records of a law enforcement unit of the University that were created by that law enforcement unit for the purpose of law enforcement.

   8. Student Rights to Inspect and Challenge Education Records. The University shall provide to students the opportunity to challenge the content of Education Records to insure that they are not inaccurate, misleading, or otherwise in violation of privacy rights, and to correct, delete, or insert written statements of explanation into such records. This does not give a student a right to contest or challenge an assigned grade, which shall be handled through the University Grade Appeals System. Although disagreements may be settled through informal meetings and discussions, either the student or the University may request an administrative hearing to resolve the dispute.

      If a hearing is held, it shall:

      1. Be conducted and decided within a reasonable period of time following the request, and the student shall be given notice of the date, time, and place reasonably in advance of the hearing;

      2. Be conducted, and the decision rendered, by the authorized custodian of the record in question (or other University official designated by the president), provided that person does not have a direct interest in the outcome;

      3. Afford the student a full and fair opportunity to present evidence relevant to the issues, and to be assisted or represented by individuals of the studentŐs choice at the studentŐs own expense, including an attorney; and

      4. Insure that the decision is rendered to the student in writing within a reasonable time after the conclusion of the hearing, is based solely upon the evidence presented at the hearing, and shall include a summary of the evidence and the reasons for the decision.

   9. Periodic Review. Education Records and Personally Identifiable data should be screened periodically to ensure that only those required or necessary will be retained. However, records and data shall not be destroyed if there is an outstanding request to inspect and review them. Additionally, the Disclosure Log and any statements of explanation shall be maintained as long as the Education Records to which they pertain are maintained.

   10. The Registrar of Purdue University is designated to assist with the interpretation and implementation of FERPA.

Steven C. Beering
President

Appendix

Academic Records	Hovde Hall	Registrar
Admissions	Schleman Hall	Director
Alumni Association	Purdue Memorial Union	Director
Bursar	Hovde Hall	Bursar
Dean of Students	Schleman Hall	Dean
Educational Placement	Stewart Center	Director
Financial Aid	Schleman Hall	Director
Medical Records	Student Health Center	Director
Center for Career Opportunities	Stewart Center	Director
Student Employee Records Graduate, Undergraduate	Freehafer Hall	Director of Personnel Services
University Police	205 South Intramural Drive	Chief
University Residences	Residence Main Office	Manager
Veterans Affairs	Hovde Hall	Registrar

Students may have records in the following offices and maintained by the administrative officer listed below:

School or Division*

Agriculture	Agricultural Administration Building	Dean
Consumer and Family Services	Stone Hall	Dean
Education	Beering Hall	Dean
Engineering	Engineering Administration Building	Dean
Graduate	Young Graduate House	Dean
Liberal Arts	Beering Hall	Dean
Management	Krannert	Dean
Nursing	Johnson Hall of Nursing	Dean
Pharmacy and Pharmacal Sciences	Heine Pharmacy Building	Dean
Science	Mathematical Sciences Building	Dean
Technology	Knoy Hall of Technology	Dean
Undergraduate Studies Program	Schleman Hall	Director
Veterinary Medicine	Lynn Hall of Veterinary Medicine	Dean

*Some departments maintain records separate from the school or division. Departments which have separate records, their location and the person responsible for the record, may be obtained from the office of the dean of the school in which the department is located or from the custodian listed above for non-academic departments.