Family Educational Rights and Privacy Act

FERPA Annual Notice to Students: Access to Student Records

Hebrew Union College-Jewish Institute of Religion annually informs students of the Family Educational Rights and Privacy Act of 1974, (FERPA) as amended. The Office of the Registrar will disclose FERPA information by publishing a notice on HUC-JIR’s Registrar website and in other appropriate locations. This annual notice shall prescribe the procedures whereby a student may make a formal request for non-disclosure of directory information, exercise the right to inspect and review education records, request an amendment of education records, and obtain a copy of HUC-JIR’s education records policy. The Family Educational Rights and Privacy Act (FERPA) affords students certain rights with respect to their education records. See Section “6” below on your right to prevent the disclosure of directory information. The FERPA rights of students are:

The right to inspect and review your education records.

Students should submit to the registrar, dean, head of the academic department, or other appropriate official, written requests that identify the record(s) they wish to inspect. If the records are not maintained by the HUC-JIR official to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed. All such requests must be forwarded to the Office of the Registrar immediately for review. The Office of the Registrar, in coordination with the appropriate HUC-JIR officials and/or offices, shall ensure that requests to inspect and review education records are responded to in a timely manner. All requests shall be granted or denied in writing within 45 days of receipt. If the request is granted, you will be notified of the time and place where the records may be inspected. If the request is denied or not responded to within 45 days, you may appeal to the HUC-JIR’s FERPA appeals officer. Additional information regarding the appeal procedures will be provided to you if a request is denied. Schools are not required to provide copies of records unless, for reasons such as great distance, it is impossible for students to review the records. Schools may charge a fee for copies.

The right to request the amendment of the student’s education records that the student believes are inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.

You may ask HUC-JIR to amend a record that you believe is inaccurate, misleading, or otherwise in violation of your privacy rights under FERPA. You should write to the HUC-JIR official responsible for the records, clearly identify the part of the record you want changed and specify why it should be changed. If the college decides not to amend the record as requested by you, HUC-JIR will notify you of the decision in writing and will advise you of your right to a hearing before HUC-JIR’s FERPA appeals officer regarding the request for amendment. Additional information regarding the hearing procedures will be provided to you when notified of your right to a hearing.

The right to provide consent prior to the disclosure of personally identifiable information (“PII”) contained in your education records, except to the extent that FERPA authorizes disclosure without consent.

One exception which permits disclosure without consent is disclosure to college officials with legitimate educational interests. An HUC-JIR official typically includes the following:

a person employed by HUC-JIR in an administrative, supervisory, academic or research, or support staff position (including law enforcement unit personnel and health staff);
a volunteer or contractor who performs an institutional service or function for which the school would otherwise use its employees and who is under the direct control of the school with respect to the use and maintenance of PII from education records, such as an attorney, auditor, or collection agent or a student volunteering to assist another school official in performing his or her tasks;
a person serving on the Board of Governors; or
a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another college official in performing his or her tasks. A HUC-JIR official has a legitimate educational interest if access is reasonably necessary in order to perform their instructional, research, administrative, or other duties and responsibilities.

Upon request, HUC-JIR discloses education records without consent to officials of another college or school in which a student seeks or intends to enroll.

The right to appeal an alleged denial of FERPA rights to the:

Office of the Registrar
Hebrew Union College-Jewish Institute of Religion
3101 Clifton Avenue
Cincinnati, Ohio 45220

The right to file a complaint with the U.S. Department of Education concerning alleged failures by HUC-JIR to comply with the requirements of FERPA. The name and address of the Office that administers FERPA are:

Family Policy Compliance Office
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202-5920

For additional information: www.ed.gov/policy/gen/guid/fpco/ferpa/index.htmlHUC-JIR will make the following “directory information” concerning current and former students available to those parties having a legitimate interest in the information:

name (preferred/legal)
attendance dates (periods of enrollment)
address
telephone number
place of birth
photograph
email address
enrollment status (e.g., full- or part-time, etc.)
class level (e.g., undergraduate, graduate, etc.)
credit hours completed
major field of study
enrolled program
the previous school attended
degrees, honors, and awards received

By filing a “Request to Prevent Disclosure of Directory Information” form with the Registrar’s Office, current and former students may request that any or all of this directory information not be released without their prior written consent. This form is available in the Registrar’s Office and on the Registrar’s Office website and may be filed, withdrawn, or modified at any time.

Possible Federal and State Data Collection and Use

As of January 3, 2012, the U.S. Department of Education's FERPA regulations expand the circumstances under which your education records and PII contained in such records — including your Social Security Number, grades, or other private information — may be accessed without your consent.

First, the U.S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or state and local education authorities ("Federal and State Authorities") may allow access to your records and PII without your consent to any third party designated by a Federal or State Authority to evaluate a federal- or state-supported education program. The evaluation may relate to any program that is "principally engaged in the provision of education," such as early childhood education and job training, as well as any program that is administered by an education agency or institution.

Second, Federal and State Authorities may allow access to your education records and PII without your consent to researchers performing certain types of studies, in certain cases even when we object to or do not request such research. Federal and State Authorities must obtain certain use-restriction and data security promises from the entities that they authorize to receive your PII, but the Authorities need not maintain direct control over such entities.

In addition, in connection with Statewide Longitudinal Data Systems, State Authorities may collect, compile, permanently retain, and share without your consent PII from your education records, and they may track your participation in education and other programs by linking such PII to other personal information about you that they obtain from other Federal or State data sources, including workforce development, unemployment insurance, child welfare, juvenile justice, military service, and migrant student records systems.

Other Disclosures Permitted without Consent

FERPA permits the disclosure of PII from students’ education records, without consent of the student, if the disclosure meets certain conditions found in § 99.31 of the FERPA regulations. Except for disclosures to school officials, disclosures related to some judicial orders or lawfully issued subpoenas, disclosures of directory information, and disclosures to the student, § 99.32 of FERPA regulations requires the institution to record the disclosure. Eligible students have a right to inspect and review the record of disclosures. A postsecondary institution may disclose PII from the education records without obtaining prior written consent of the student:

To other school officials, including teachers, within HUC-JIR whom the school has determined to have legitimate educational interests. This includes contractors, consultants, volunteers, or other parties to whom the school has outsourced institutional services or functions, provided that the conditions listed in § 99.31(a)(1)(i)(B)(1) - (a)(1)(i)(B)(3) are met. (§ 99.31(a)(1)
To officials of another school where the student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer, subject to the requirements of § 99.34. (§ 99.31(a)(2))
To authorized representatives of the U. S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or State and local educational authorities, such as a State postsecondary authority that is responsible for supervising the university’s State-supported education programs. Disclosures under this provision may be made, subject to the requirements of §99.35, in connection with an audit or evaluation of Federal- or State-supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs. These entities may make further disclosures of PII to outside entities that are designated by them as their authorized representatives to conduct any audit, evaluation, or enforcement or compliance activity on their behalf. (§§ 99.31(a)(3) and 99.35)
In connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid. (§ 99.31(a)(4))
To organizations conducting studies for, or on behalf of, the school, in order to: (a) develop, validate, or administer predictive tests; (b) administer student aid programs; or (c) improve instruction. (§ 99.31(a)(6))
To accrediting organizations to carry out their accrediting functions. (§ 99.31(a)(7))
To parents of an eligible student if the student is dependent for IRS tax purposes. (§ 99.31(a)(8))
To comply with a judicial order or lawfully issued subpoena. (§ 99.31(a)(9))
To appropriate officials in connection with a health or safety emergency, subject to § 99.36. (§ 99.31(a)(10))
Information the school has designated as “directory information” under § 99.37. (§ 99.31(a)(11))
To a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense, subject to the requirements of § 99.39. The disclosure may only include the final results of the disciplinary proceeding with respect to that alleged crime or offense, regardless of the finding. (§ 99.31(a)(13))
To the general public, the final results of a disciplinary proceeding, subject to the requirements of § 99.39, if the school 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 school’s rules or policies with respect to the allegation made against him or her. (§ 99.31(a)(14))
To parents of a student regarding the student’s violation of any Federal, State, or local law, or of any rule or policy of the school, governing the use or possession of alcohol or a controlled substance if the school determines the student committed a disciplinary violation and the student is under the age of 21. (§99.31(a)(15))