FERPA Policy - 2020
The Family Educational Rights and Privacy Act (FERPA) of 1974, as amended, sets out requirements designed to afford students certain rights with respect to their education records. In addition, it puts limits on what information the institution may disclose to third parties without receiving prior written consent from the student via a FERPA release form, an authorized signature on another document or a lawfully-issued subpoena or judicial order.
The Registrar’s office maintains student educational records, provides students access to their records, and keeps information contained in those records confidential as required by FERPA. The Act covers anyone who is or has been enrolled at the institution.
Education records are defined as official records that are directly related to a student and maintained by the Registrar. When a record contains personally identifiable information about more than one student, the student may inspect and review only the information that relates to them personally.
Cummings Graduate Institute is committed to protecting the privacy of our students, full-time faculty, adjunct faculty, board members, team members, alumni, and any other stakeholders in all communications and documents in the institution’s possession. This information includes, but is not limited to, social security numbers, credit card numbers and check information, personal and financial information, academic transcripts from schools, academic records at this institution, and/or emails. Such information belongs exclusively to the individual and cannot be released outside of the institution without the prior written approval of the individual who owns these records, except as provided under the Family Educational Rights and Privacy Act (FERPA).
Cummings Graduate Institute maintains student educational records, provides students access to their records, and keeps information contained in those records confidential as required by FERPA. FERPA covers anyone who is or has been enrolled at the institution, including the following:
- Active students currently enrolled in a program
- Former students and alumni
- Administrative staff members, full-time faculty members, and adjunct faculty members
When operating websites, Cummings Graduate Institute takes special measures to ensure the confidentiality of the information is protected. A privacy statement appears on the websites that explains what information Cummings Graduate Institute may collect through our websites, why the institution collects such information, how the information is protected, and the choices stakeholders have about how Cummings Graduate Institute uses the information.
Cummings Graduate Institute has the obligation to safeguard this information and to ensure the stakeholders are protected.
Disclosure of Educational Records
Generally, schools must have written permission from the eligible student in order to release any information from a student's education record. However, FERPA allows schools to disclose those records, without consent, to the following parties or under the following conditions (34 CFR § 99.31):
- School officials with legitimate educational interest
- State and Federal Regulatory Agencies
- Other schools to which a student is transferring
- Specified officials for audit or evaluation purposes
- Appropriate parties in connection with financial assistance to a student
- Organizations conducting certain studies for or on behalf of the school
- Accrediting organizations
- Compliance with a judicial order or lawfully-issued subpoena
- Appropriate officials in cases of health and safety emergencies or crises
- State and local authorities, within a juvenile justice system, pursuant to specific State law
The Cummings Graduate Institute has designated certain types of information as "Directory Information," which may be disclosed without a student’s consent.
The term “Directory Information” means information contained in a student record that would not generally be considered harmful or an invasion of privacy if disclosed to the public. The following information has been designated by Cummings Graduate Institute as Directory Information:
- Student's name
- Email address
- Major field of study
- Dates of attendance
- Enrollment status
- Graduation status
This information may be released to interested parties who request for purposes of, but not limited to, the following:
- Volunteer opportunities
- Rental/credit checks
- Verification of degree conferral
- Gathering for research.
Per the Personally Identifiable Information Policy, new and continuing students at Cummings Graduate Institute can contact the Registrar at firstname.lastname@example.org to adjust what they want as Directory Information.
Cummings Graduate Institute will annually notify students of their rights under FERPA. Students may request nondisclosure of student directory information by completing a FERPA - Nondisclosure Form. Failure to request nondisclosure of directory information may result in disclosure of one or more of the above-designated categories of directory information.
Non-directory information is considered any information that is not listed as directory information. This information may not be released without the prior written consent of the current or former students. Students can request consent by completing a FERPA - Authorization of Information Release Form. Once the completed form is submitted, The Registrar follows up via phone to legitimize all information and consent.
It is the responsibility of the student to review the policy and submit any FERPA forms as needed.
It is the responsibility of the Registrar to respond to all student inquiries within the time limits set out by the policy.
Policy and Compliance Office
It is the responsibility of the Policy and Compliance Office to audit the compliance of the FERPA policy.
Staff, Faculty, Board of Directors, and Students
It is the responsibility of the staff, faculty, Board of Directors, and students to ensure the privacy of all students, according to the FERPA Policy.
Procedure to Inspect and Retrieve Education Records
Under FERPA, students have the right to inspect and review their education records. A student who wishes to inspect and review their records should submit an email request to the Registrar at email@example.com.
All records requests will be responded to within 14 calendar days from the date of receipt of the request. If the requested records are subject to inspection and review by the student, arrangements for access will be made within a reasonable period of time, but in no case more than 45 calendar days after the request was made.
Request to Correct Education Records
Students have the right to request an amendment of education records if they believe the records are inaccurate or misleading. The request for amendment must be made in writing and include a notarized signature. The request must be sent to the attention of the Registrar, via email at firstname.lastname@example.org or mail to the administrative offices, and must identify the part(s) of the education records to be amended and specifying the reasons why the student believes the information is inaccurate or misleading.
The Registrar shall notify the student of the decision within 15 calendar days of the receipt of the request. If the Registrar denies the student’s request to correct education records, the student has the right to file a grievance. If a student wishes to file a grievance, they should review the Complaint and Grievance Policy.
Policy was revised on: June 15th, 2020
Policy was approved by: Amanda Harrison, Chief Operating Officer