FERPA Procedures | National Park College

NPC FERPA Procedures

Included in this guide are standard operating procedures for National Park College as related to the Family Educational Rights and Privacy Act (FERPA).

Policy Statement: The College will support and comply with the Family Education Rights and Privacy Act of 1974.

Definitions

The following definitions apply to the FERPA procedures written herein:

Directory information - information contained in the education record that would generally not be considered harmful or an invasion of privacy if disclosed. Directory information at NPC includes:
1. Name
2. Address
3. Email Address
4. Phone Number
5. Date of Birth
6. Photograph
7. Academic Major
8. Full-time or part-time enrollment status
9. Academic and non-academic honors
10. Other academic institutions attended
11. Degree obtained and date conferred
12. Participation in officially recognized activities and sports
13. Height and weight of members of athletic teams
14. Leadership positions
15. Dates of attendance
Education record - any record (handwritten, printed, typed, filmed or preserved in any other medium) that is maintained by NPC that is directly related to a student.
Legitimate educational interest - a school official exercises “legitimate educational interest” if the official needs to review an education record in order to perform his or her professional responsibilities.
Personally identifiable information - includes a student's name or address, or the name or address of the student's parents or family members, a personal identifier such as a student's social security number, other direct identifiers such as the student's date of birth, place of birth and mother's maiden name or any other information that alone or in combination can be linked to a specific student in a way that would allow a reasonable person in the school community, who does not have personal knowledge of the student, to identify the student with reasonable certainty.
School official - a person employed by NPC in an administrative, supervisory, academic or research, or support staff position; a person or company with whom NPC has contracted; a person serving on the Board; or a student serving on an official committee or assisting another school official in performing his or her tasks.
Student - any individual who is currently enrolled or has previously been enrolled at NPC (formerly NPCC; includes GCCC and QTI).
Valid consent - consent is considered valid when the student has submitted a signed request using a handwritten signature or authenticated electronic method, such as the school-issued email or an approved service affiliated with the College, such as FAFSA or Parchment.

Procedures and Responsibilities

Annual Notice of Students' Rights under FERPA - NPC publishes an annual notice on FERPA in the Student Handbook as well as on the NPC website that summarizes student records privacy rights. In addition, the Registrar emails an annual notice to all students on the first day of classes each fall term.
Students Request for Access to Education Records - In accordance with FERPA guidelines, students have the right to inspect and review their education record upon written request to the appropriate records custodian. The written request must specifically identify the records requested. NPC will comply with all requests within 45 days of receipt of the request.
1. Students may contact the Registrar or the appropriate records custodian as outlined in the NPC Records Retention Schedule. The college will utilize appropriate identification methods, such as a valid photo ID and/or verification questions, to identify the student or parent of a dependent child requesting access.
2. NPC Leadership will determine costs for copies of records.
3. NPC is not required to permit a student to inspect or review the following:
  1. Financial records of the student's parents
  2. Letters of recommendation if the student has waived rights to access
  3. Admission records if the application was denied
4. Records that are not considered “education records” as outlined in FERPA guidelines
5. If the record includes information on more than one student, NPC will redact all information pertaining to other students prior to student inspection.
6. Students with outstanding financial obligations will not receive copies of their academic transcript or diploma until those obligations are satisfied. The student retains the right to review this information with the Registrar.

Requests to Amend Education Records - Students have the right to request an amendment of student records if they believe information is inaccurate or misleading. This request process does not include appeals for grade changes, which follow the academic grade appeals process. NPC will review the request and render a decision within a reasonable period. If the request is denied, the college will notify the student of options for appeal.
Disclosure of Personally Identifiable Information - NPC requires signed, dated written consent from a student to disclose personally identifiable information from an education record, except as otherwise noted in FERPA guidelines.
1. The consent to disclosure must specify the records for which consent is granted, the purpose for the disclosure, and the identity of the person or organization to which the record can be disclosed. Students can provide consent to disclosure of information by submitting the NPC Consent to Release Information form to the Registrar's Office. The consent will remain in effect until rescinded in writing.
2. Consent may be submitted electronically when the consent identifies and authenticates the student as the source of the consent and indicates the student's approval of the requested disclosure.
  1. Acceptable forms of electronic consent include: a handwritten signature that is faxed or scanned to the college as part of an entire document; marks, initials, or checkboxes provided through an online form that is accessible only after inputting one's NPC login credentials and is tied to the NPC account; an email from the NPC student email address or consent provided through the student portal; and any paper or online form that complies with one of the criteria above.
  2. Unacceptable digital/electronic signatures include: a graphic image placed on a document and not verified by secure software; typewritten name regardless of font that has not been verified through secure software or through the student portal; an email from an email address other than the NPC student email; any other unauthenticated communication
3. NPC may disclose information from a student's education record to the following parties without written consent:
  1. School officials with legitimate educational interest
  2. The National Student Clearinghouse, which collects and shares student data for reporting, data verification, and reverse transfer purposes.
  3. Parents when the student is a dependent for tax purposes and appropriate documentation of dependency status is on file, when a health or safety emergency requires disclosure to the parent, or when the student is under 21 at the time of disclosure and has violated federal, state or local laws or an NPC policy governing the use or possession of alcohol or a controlled substance and NPC has found the student in violation of the Student Code of Conduct
  4. Schools to which the student intends to transfer if the disclosure is related to enrollment or transfer
  5. Specified officials of the US Department of Education, the Comptroller General, the Attorney General of the United States, US Department of Veteran Affairs, and state and local educational authorities for audit or evaluation of Federal or state supported education programs or for the enforcement of or compliance with Federal legal requirements related to those programs
  6. Appropriate parties in connection with financial aid to a student
  7. Organizations conducting certain studies for or on behalf of the school as outlined in an established agreement between the organization and the college
  8. Accrediting organizations to carry out their accrediting functions
  9. Individuals delivering a judicial order or lawfully issued subpoena - NPC will make a reasonable effort to contact the student unless the judicial order or subpoena specifically and lawfully prohibits it
  10. Appropriate officials in cases of health and safety emergencies if knowledge of the information is necessary to protect the health or safety of the student or other individuals
  11. Victims of an alleged perpetrator of a crime of violence or a non-forcible sex offense, limited only to the final results of an NPC disciplinary hearing regardless of the college's findings
  12. General public - the final results of a disciplinary proceeding if NPC determines the student is an alleged perpetrator of a crime of violence or non-forcible sex offense and the student has committed a violation of the NPC's policies or Student Code of Conduct with respect to the allegation made against him or her
  13. State and local authorities, within a juvenile justice system, pursuant to specific State law
  14. To relatives of a deceased student when sufficient documentation of a student's death and their relationship to the student is provided
4. The Registrar's office will maintain a record of any requests for and releases of personally identifiable information made by a third party without written student consent or a lawfully issued court order or subpoena. The record will include the date the information was released, to whom the information was released, the records that were released, and the purpose of the request. In most cases, NPC will still require a student's written consent to release the information.

Disclosure of Directory Information - Information designated as directory information may be released by NPC without a student's consent.
1. Directory information includes the following:
  1. Name
  2. Address
  3. E-mail address
  4. Phone number
  5. Photograph
  6. Date of Birth
  7. Academic major
  8. Full-time or part-time status
  9. Academic and nonacademic honors
  10. Degree obtained and date conferred
  11. Participation in officially recognized activities and sports
  12. Height and weight of members of athletic teams
  13. Leadership positions
  14. Dates of attendance
2. Students may request to restrict release of directory information by submitting the NPC Non-Disclosure of Directory Information form to the Registrar's Office. The request will remain in effect until a new request is submitted to rescind the original request. The non-disclosure will restrict disclosure of all directory information unless requested differently in writing
3. Restricting directory information does not prevent NPC from disclosing or requiring a student to disclose a student's name, student ID, or electronic identifiers in a class in which the student is enrolled.

Security - Computer Services/IT is responsible for maintaining the security of the NPC networks, servers, and all electronic communications and services. IT works with the campus to maintain appropriate security controls based on roles and proven legitimate educational interest.
FERPA Training for Faculty/Staff - NPC conducts annual FERPA training through the Learning Management System (LMS). In addition, annual email notifications to all employees are sent as a reminder of FERPA guidelines.
1. Expectations of School Officials - it is expected that school officials with access to student records maintain high ethical and behavioral standards regarding the access, maintenance, and dissemination of student information. Passwords should be kept in a secure location, personally identifiable information should not be displayed in open locations, and security violations or data breaches must be reported immediately.
Complaints alleging NPC's failure to comply with FERPA regulations may be submitted to the Family Policy Compliance Office, US Department of Education, 400 Maryland Ave SW, Washington, DC 20202-8520.

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