Access to Student Education Records (VIII.A.4)

Volume VIII: Records
Chapter A: Records
Responsible Executive: Provost
Responsible Office: Office of the Registrar
Date Issued: November 1, 2011
Date Last Revised: February 1, 2021

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Policy Clarification

Office of the Registrar
765-496-0509 | ferpa@purdue.edu

Campus Specific Questions

Fort Wayne Office of the Registrar
260-481-6815 | registrar@pfw.edu

Northwest Office of the Registrar
219-989-2210 or 219-785-5342 | registrar@pnw.edu

West Lafayette Office of the Registrar
765-496-0509 | ferpa@purdue.edu

Statement of Policy

Purdue University complies with the Family Educational Rights and Privacy Act of 1974 (FERPA), as amended, the federal law that protects the privacy of Education Records of Students.

Annual Notification of Student Rights under FERPA

FERPA provides Students certain rights with respect to reviewing inspecting and requesting amendments to their own Education Records. The University will annually notify Students currently attending the University of these rights. The annual notice also will inform Students of:

The instances in which the University may Disclose Education Records or other Personally Identifiable Information without the Student’s prior written consent; and
How to submit a request to restrict the release of Directory Information.

Access to and Disclosure of Education Records

University Officials may have access to Education Records when their legitimate educational interest in those records has been determined by the respective Records Custodian. A University Official has a legitimate educational interest if their professional responsibilities to the University reasonably require access to that information. University Officials who have access to Education Records are obligated to carefully protect them and will be held accountable for safeguarding them. Violations may result in disciplinary action, up to and including termination of employment and applicable civil and criminal sanctions.

Education Records and Personally Identifiable Information will be released only with the signed consent of the Student, except when FERPA authorizes Disclosure without consent. When required by FERPA, Disclosures made without the Student’s signed consent will include a notice to the recipient that the information is released upon the condition that it will not be Disclosed to any other party without the prior written consent of the Student.

Reason for This Policy

This policy ensures that Purdue University protects the privacy of Student Education Records in accordance with federal law and regulations and complies with requirements imposed on recipients of federal funding under programs of the U.S. Department of Education.

Individuals and Entities Affected

This policy affects all faculty, staff, Students, Parents/guardians, Contractors, volunteers and third parties.

Exclusions

This policy does not give Students the right to prevent disclosure of their names or other identifiers in the classroom.

This policy does not prohibit faculty members or instructors from carrying out customary practices, such as group grading of team assignments and/or projects.

This policy does not give Students the right to inspect records maintained by the University at a campus at which the Student has not been enrolled.

Personally Identifiable Information related solely to a former Student’s activities as an alumnus of the University is not protected under this policy.

The following materials, information and records are excluded from the definition of Education Records and are not available to Students for inspection, review, challenge, correction or deletion:

Confidential letters and statements of recommendation placed in the Education Record prior to January 1, 1975, when they are used for the purpose(s) for which they were specifically intended.
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 regarding:
1. Admission to an educational institution,
2. An application for employment, and
3. The receipt of an honor or honorary recognition.
Financial records and statements of the Student’s Parents or any information contained therein.
Records of instructional, supervisory or administrative personnel or educational personnel ancillary thereto, kept in the sole possession of their creator and not accessible or revealed to any other person except a temporary substitute of the creator.
Records that 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 are not available without written consent to anyone other than the person(s) providing such treatment, except that such records can be personally reviewed by a physician or other appropriate professional of the Student’s choice.
Employment records made and maintained in the normal course of business that relate exclusively to the Student in his or her capacity as an employee and are not available for any other purpose; this exclusion does not apply to a Student who is employed by the University as a result of his/her status as a Student (i.e., interns, teaching assistants, research assistants, etc.).
Records that contain only information relating to a person after that person is no longer a Student at the University.
Records of a law enforcement unit of the University that were created by that law enforcement unit for the purpose of law enforcement.
Records regarding application for admission of a Student of one component or campus of the Purdue system who is seeking to enroll at another component or campus of the Purdue system unless the Student is accepted and attends the other component or campus of the Purdue system.

Responsibilities

Officers (See Appendix A)

Serve as Records Custodian or assign an employee to serve as Records Custodian for Education Records maintained in their unit.

Records Custodians

Maintain and protect Education Records under their responsibility.
Ensure FERPA and the University’s policies and procedures are followed when releasing Education Records.
Maintain accurate Disclosure Logs with the Education Records under their responsibility.
Ensure that Education Records and data containing Personally Identifiable Information of Students are retained in accordance with applicable laws, regulations and the University’s procedures on records retention.

Registrars

Administer this policy for their campus and establish mechanisms and procedures to promote overall compliance.

Students

Know and understand their rights regarding data and information in their own Education Records documented and maintained by the University.
Follow procedures outlined by the applicable Records Custodian for reviewing, inspecting and requesting amendments to their Education Records.
Follow procedures outlined by the campus Registrar for requesting to restrict the release of Directory Information.

University Officials

Protect Education Records to which they have been granted access.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

Attendance
Presence in person or by paper correspondence, videoconference, satellite, Internet or other electronic information and telecommunications technologies for Students who are not physically present in the classroom. The term also includes the period during which a person is working under a work-study, co-op program or participating in an internship.

Biometric Record
A record of one or more measurable biological or behavioral characteristics that can be used for automated recognition of an individual. Examples include fingerprints, retina and iris patterns, voiceprints, DNA sequence, facial characteristics and handwriting.

Contractors
Non-employees, including university legal counsel, performing institutional services and functions.

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 considers the following listed items to be Directory Information: Student’s name; local and home addresses; local and home telephone listings; email address; major field of study; enrollment status (e.g., undergraduate or graduate, full-time or part-time) and credit hour load; classification; Dates of Attendance; participation in officially recognized activities and sports; position, weight, height, and photograph of members of athletic teams; degrees, honors and awards received. The University reserves the right to amend this listing consistent with federal law and regulations and will publish any amendments.

Disclosure or Disclose
To permit access to or the release, transfer or other communication of Personally Identifiable Information contained in Education Records by any means, including oral, written or electronic, to any party except the party identified as the party that provided or created the record.

Disclosure Logs
Documents maintained with a Student’s Education Record by the appropriate university Records Custodian that record each request for and disclosure of Personally Identifiable Information from the Education Record of a Student, and that indicate everyone who has requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it. In accordance with FERPA, logs are not maintained for the following:

Disclosures to the Student.
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.
Disclosures to University Officials, when it has been determined that the official has a legitimate educational interest.
Disclosures of Directory Information.
Disclosures pursuant to judicial order or lawfully issued subpoena when the University is directed not to disclose the existence of the order or subpoena.

Education Records
Any records maintained in any form by the University that are directly related to a Student. The term does not include:

Records created after the individual is no longer in Attendance that are not directly related to the individual’s Attendance or studies.
Grades on peer-graded papers before they are collected and recorded by an instructor or faculty member.
The materials, information and records identified in the Exclusions section.

FERPA
Family Educational Rights and Privacy Act of 1974, as amended.

Parent
The biological or adoptive mother or father of a Student, or any other individual who stands in loco parentis of the Student.

Personally Identifiable Information
A Student’s name; the name of a Student’s Parent or other family member; the address of a Student or Student’s family; a personal identifier, such as the social security number or Student identification number, or any portion thereof, or Biometric Record; other indirect identifiers, such as the Student’s date of birth, place of birth and mother’s maiden name; other information that, alone or in combination, is linked or linkable to a specific Student that would allow a reasonable person in the University community who does not have personal knowledge of the relevant circumstances to identify the Student with reasonable certainty; or information requested by a person who the University reasonably believes knows the identity of the Student to whom the Education Record relates.

Records Custodian
The University employee responsible for Student records within the area where the record is located. See Appendix A.

Student
An individual who is or was enrolled and in Attendance at the University, and for whom the University maintains Education Records. For purposes of this policy, one is deemed to be enrolled and Attending once fees have been paid for a session (semester) or as of the first day of the session (semester) in which the student is enrolled, whichever occurs first.

University Officials
Members of the University faculty and staff and internal or external auditors. The term also includes Contractors, volunteers, lawyers and other non-employees performing institutional services and functions.

Registrar
The staff member who holds the position of registrar on the Fort Wayne, Northwest and West Lafayette campuses.

Website Address for This Policy

www.purdue.edu/vpec/policies/records/viiia4

History and Updates

February 1, 2021: Removed list of Students’ rights from Statement of Policy. Removed Procedures section and included information in the Statement of Policy section on Access to and Disclosure of Education Records. Updated Responsibilities section. Removed definitions no longer referenced in the policy: Alleged Perpetrator of a Crime of Violence, Alleged Perpetrator of a Non-forcible Sex Offense, De-Identified Record, Final Results, Financial Aid, and Health and Safety Emergency. Added language to the definition of Disclosure Log. Updated Appendix A.

November 28, 2018: Updated Contacts and Related Documents, Forms and Tools sections.

June 15, 2016: Interim status removed. Contacts and Appendix updated with Purdue University Northwest information.

February 4, 2015: Revisions were made to the Statement of Policy and Procedures sections to align more closely with current University practices and to reflect recent FERPA guidance that has, among other things, clarified the scope of an Education Record. Definitions redundant to the central Policy Glossary were removed and hyperlinks were updated throughout.

November 18, 2011: Policy number changed to VIII.A.4 (formerly VI.3.1) and website address updated.

November 1, 2011: This policy supersedes Executive Memorandum No. C-51, University Policy Regarding the “Family Educational Rights and Privacy Act of 1974,” issued on August 7, 2000, which was originally issued as Executive No. B-44, February 17, 1977.

Appendix A

The tables below identify the types of Education Records the University maintains and the Official or Records Custodian responsible for that record.

Table I: Offices on the Fort Wayne Campus

Classification	Location	Records Custodian
Academic Accountability and Student Success	Kettler Hall	Executive Director
Admissions	Walb Union 121	Associate Vice Chancellor of Admissions
Alumni Relations	Office of Development and Alumni Relations, Cole Commons	Director
Athletics	Hilliard Gates Center	Director
Bursar	Kettler Hall G57	Bursar
Career Services	Kettler Hall 109	Executive Director
Continuing Studies	Kettler Hall 144	Executive Director
Financial Aid	Kettler Hall 102	Director
Dean of Students	Walb Union 111	Dean
Graduate Studies	Liberal Arts Building 17	Director
Honors Program	Helmke Library 201	Director
Housing and Residential Education	Student Housing Clubhouse	Director
Registrar	Kettler Hall 107	Associate Vice Chancellor and Registrar
Student Employee Records Undergraduate and Graduate	Doermer School of Business Building 300A	Associate Vice Chancellor of HR and Institutional Equity
Testing Services	Kettler Hall 232	Director
Tutoring Center	Helmke Library, 2nd floor	Director
University Police	Support Services Building	Chief

Table I: Offices on the Fort Wayne campus

Table II: Fort Wayne Colleges, Schools and Divisions

College, School or Division	Location	Officer
Arts and Sciences	Liberal Arts Building 153	Dean
Continuing Studies	Kettler Hall 144	Executive Director
Doermer School of Business	Neff Hall 360	Dean
Engineering, Technology, and Computer Science	Engineering & Technology Building 243	Dean
Helmke Library	Helmke Library 114	Dean
Professional Studies	Neff Hall 250	Dean
Visual and Performing Arts	Visual Arts Building 102	Dean

Table II: Fort Wayne Colleges, Schools and Divisions

Table III: Offices on the Hammond Campus of Purdue University Northwest

Classification	Location	Records Custodian
Academic Records	Lawshe Hall	Registrar
Admissions	Lawshe Hall	Director
Student Accounts	Lawshe Hall	Bursar
Dean of Students	Student Union and Library	Dean
Educational Placement	Lawshe Hall	Director
Financial Aid	Lawshe Hall	Director
Graduate Studies	Lawshe Hall	Director of Graduate Studies
Career Services	Student Union and Library	Director
Student Employee Records Graduate, Undergraduate	Schneider Avenue Building	Asst. Vice Chancellor for Human Resources
University Village	Griffin Residence Hall main office	Director
Veterans Affairs	Lawshe Hall	Registrar

Table III: Offices on the Hammond campus of Purdue University Northwest

Table IV: Offices on the Westville Campus of Purdue University Northwest

Classification	Location	Records Custodian
Academic Records	Schwarz Hall	Registrar
Admissions	Schwarz Hall	Director
Bursar	Schwarz Hall	Bursar
Dean of Students	Library Student Faculty Building	Dean of Students
Educational Placement	Library Student Faculty Building	Director
Financial Aid	Technology Building	Director
Career Center	Library Student Faculty Building	Director
Student Employee Records Graduate, Undergraduate	Dworkin Student Services and Activities Complex	Associate Vice Chancellor, Human Resources
University Residences	N/A	N/A
Veterans Affairs	Schwarz Hall	Registrar

Table IV: Offices on the Westville campus of Purdue University Northwest

Table V: Northwest Colleges, Schools and Departments

College/School/Department	Hammond	Westville	Officer
College of Business	Anderson Building	Technology Building	Dean
Managerial Studies	Anderson Building	Technology Building	Department Head
Quantitative Business Studies	Anderson Building	Technology Building	Department Head
College of Engineering and Sciences	Gyte Building	Technology Building	Dean
White Lodging School of Hospitality & Tourism Management	White Lodging Center of Hospitality & Tourism Management	N/A	Director
Biological Sciences	Nils Bioscience Innovation Building	Schwarz Hall	Department Head
Mechanical and Civil Engineering	Potter Building	Technology Building	Department Head
Electrical and Computer Engineering	Gyte Building	Technology Building	Department Head
College of Humanities, Education and Social Sciences	Classroom Office Building	Technology Building	Dean
School of Education	Classroom Office Building	Technology Building	Director
Teacher Preparation	Classroom Office Building	Technology Building	Department Head
Behavioral Sciences	Porter Hall	Schwarz Hall	Department Head
Communication and Creative Arts	Porter Hall	Technology Building	Department Head
English	Classroom Office Building	Technology Building	Department Head
History and Philosophy	Classroom Office Building	Schwarz Hall	Department Head
Political Science, Economics, World Languages and Cultures	Classroom Office Building and Porter	Schwarz Hall	Department Head
Psychology	Porter Hall	Schwarz Hall	Department Head
College of Nursing	Classroom Office Building	Technology Building	Dean
College of Technology	Anderson Building	Technology Building	Dean
Computer Information Technology and Graphics	Anderson Building	Technology Building	Department Head
Construction Engineering and Management Technology	Anderson Building	Technology Building	Department Head
Electrical Engineering Technology	Anderson Building	Technology Building	Department Head
Mechanical and Mechatronics Engineering Technology	Anderson Building	Technology Building	Department Head
Organizational Leadership and Supervision	Anderson Building	Technology Building	Department Head
Honors College	Student Union and Library	Technology Building	Dean

Table V: Northwest Colleges, Schools and Departments

Table VI: Offices on the West Lafayette Campus

Classification	Location	Records Custodian
Academic Records	Hovde Hall	Registrar
Admissions	Schleman Hall	Director
Athletics	Mackey Arena	Director
Bursar	Hovde Hall	Bursar
Dean of Students	Schleman Hall	Dean
Educational Placement	Stewart Center	Director
Financial Aid	Schleman Hall	Director
Graduate Students and Postdoctoral Scholars	Young Hall	Director of Graduate Records
Medical Records	Student Health Center	Director
Center for Career Opportunities	Young Hall	Director
Student Employee Records Graduate, Undergraduate	2550 Northwestern Avenue, suite 1100	Vice President for Human Resources
University Residences	Residence Main Office	Manager
Veterans Success Center	Purdue Memorial Union	Director

Table VI: Offices on the West Lafayette campus

Table VII: West Lafayette Colleges, Schools and Divisions

College, School or Division	Location	Officer
Agriculture	Agricultural Administration Building	Dean
Business	Krannert	Dean
Education	Beering Hall	Dean
Engineering	Armstrong Hall	Dean
Exploratory Studies	Young Hall	Director
Honors	Honors College and Residences	Dean
Human and Health Sciences	Stone Hall	Dean
Liberal Arts	Beering Hall	Dean
Libraries and Information Studies	Stewart Center	Dean
Polytechnic Institute	Knoy Hall of Technology	Dean
Pharmacy and Pharmaceutical Sciences	Heine Pharmacy Building	Dean
Science	Mathematical Sciences Building	Dean
Veterinary Medicine	Lynn Hall of Veterinary Medicine	Dean

Table VII: West Lafayette Colleges, Schools and Divisions