College of St. Catherine Student Handbook

Policies and Procedures Regarding Education Records
A. Definitions
For the purposes of this policy, St. Catherine University ("the University") has used the following definitions of terms:

Student is any person who attends or has attended St. Catherine University.

Education Records are any record (handwritten, print, tape, film or other medium) maintained by the College or an agent of the University that is directly related to a student, except:

1. A personal record kept by a staff member if it is kept in the sole possession of the maker of the record and is not accessible or revealed to any other person except a temporary substitute for, or a permanent replacement for, the maker of the record.

2. An employment record of an individual whose employment is not contingent on the fact that she or he is a student, provided the record is used only in relation to the individual's employment.

3. Records created and maintained by the University's Department of Public Safety that were created for the purpose of law enforcement.

4. Records maintained by the University's health service, by University psychologists or counselors, or by University medical or counseling paraprofessionals, if the records are used only for treatment of a student and made available only to those people providing the treatment. (The term "treatment" does not include remedial education that is part of the program of instruction at the University.)

5. Alumnae/i records that contain information about a student after she or he is no longer in attendance at the University and that do not relate to the person as a student.

Directory Information is information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. It includes a student's name, address, telephone number, email address, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, full- or part-time status, degrees and awards received, Latin Honors received, most recent previous school attended and photograph.

Personally Identifiable Information includes, but is not limited to: a) the student's name; b) the name of the student's parent(s) or other family members; c) the address of the student or student's family; d) a personal identifier, such as the student's social security number or student number; or e) other information that would make the student's identity easily traceable.

Party is an individual, agency, institution or organization.

B. Right of Access and Limitations
1. Students of St. Catherine University have the right to review their own education records upon submitting a written request to do so.

2. The University reserves the right to refuse to permit a student to inspect the following records:

The financial statement of the student's parents.

Letters and statements of recommendation for which the student has waived her or his right of access, or that were placed in file before Jan. 1, 1975 (unless the letters were used for any purpose other than as recommendations).

Letters and statements of recommendation placed in the education record after Jan. 1, 1975, if: 1) the student has waived the right to inspect and review these documents; and 2) the documents were related to the student's admission to an educational institution, application for employment or receipt of an honorary recognition.

C. Right to Copies and Limitations
1. The University will provide copies of education records to students after receiving a written request to the appropriate records custodian.

2. The fee for official transcripts: $5 per copy. The fee for copies of academic records (other than transcripts): $3 per page; and the fee for career development credentials: $2 per set.

3. The University reserves the right to deny transcripts or copies of records in any of the following situations:

The student has an unpaid financial obligation to the University.

There is an unresolved disciplinary action against the student.

D. Types, Locations and Custodians of Education Records
The following is a list of the types of records that the College maintains, their locations and their custodians.

Types	Location	Custodian
Admission Records: (attendance at either Campus)	Registrar’s Office 240 Old Main Building 229 Derham Hall	Registrar
Cumulative Academic Records: (for current students, Graduates and withdrawals)	Registrar’s Office 240 Old Main Building 229 Derham Hall	Registrar
Financial Records	Office of Student Accounts 240 Old Main Building 203 Derham Hall	Manager of Student Accounts
Disciplinary Records	Office of Student Affairs 306 Derham Hall Student Life office 359 Education Building	Dean of Students Associate Director of Student Life
Immunization Records Related to Clinical Education Department	Health Information 206 Old Main Building	Coordinator of Health Information
Health Records: (Health records that are not specifically excluded from the definition of education records of that the student has a right to inspect under applicable State law.)	Health and Wellness Center	Director/Nurse Practitioner
Occasional Records: (Student education records not included in the types listed above, minutes of faculty committee meetings, copies of corresponding in offices not listed, etc.)	The appropriate official will collect such records, direct the students to their locations or otherwise make the records available for inspection and review.	The university staff person who maintains such records.

E. Procedure to Inspect Education Records
Students may inspect and review their education records upon submitting a written request to the appropriate records custodian. Students should submit to the appropriate records custodian (or to an appropriate University staff person in the same office as the record custodian) a written request that identifies as precisely as possible the record or records the student wishes to inspect.

The records custodian or an appropriate University staff person will make arrangements for access as promptly as possible and notify the student of the time and place where the records may be inspected. (The University will provide access in 45 days or fewer from the date the request was received.)

When a record contains information about more than one student, the student may inspect and review only that portion of the record that relates to herself or himself.

F. Disclosure of Education Records to Third Parties
The University will disclose information from a student's education records only with the written consent of the student, except education records may be disclosed:

1. To school officials who have a legitimate educational interest in the records.

A school official is:

A person employed by the University in an administrative, supervisory, academic or research, or support staff position.

A person elected to the Board of Trustees.

A person or company employed by or under contract with the University to perform a special task (such as an attorney, auditor, judicial hearing board member or student member of the Board of Trustees).

A student serving on an official University committee or assisting another school official in performing his or her tasks.

A school official has a legitimate educational interest if the official is:

Performing a task that is specified in her or his position description or by a contractual agreement or is within the scope of the usual duties performed by a person in that position.

Performing a task related to a student's education.

Performing a task related to the discipline of a student.

Providing a service or benefit relating to the student or student's family, such as healthcare, counseling, job placement or financial aid.

2. Directory information, as defined above. Any student who wishes to designate directory information as confidential information not subject to disclosure should complete the online Request for Non-disclosure of Directory Information form (available on the Office of the Registrar Web page) by September 25, 2009. This status is valid for a period of one year.

3. To officials of another school, upon request by the student, in which a student intends to enroll.

4. To certain officials of the U.S. Department of Education, the Comptroller General and state and local educational authorities, in connection with certain state or federally supported education programs.

5. In connection with a student's request for or receipt of financial aid, as necessary to determine the eligibility, amount or conditions of the financial aid, or to enforce the terms and conditions of the aid.

6. If required by a state law requiring disclosure that was adopted before
Nov. 19, 1974.

7. To organizations conducting certain studies for or on behalf of the University.

8. To accrediting organizations to carry out their functions.

9. To comply with a judicial order or a lawfully issued subpoena.

10. To appropriate parties in a health or safety emergency.

11. To an alleged victim of any crime of violence of the results of any disciplinary proceeding conducted by the University against the alleged perpetrator of that crime.

12. To any party if the student provides written consent.

G. Record of Requests for Disclosure
The University will maintain a record of 1) requests for disclosure of and 2) actual disclosures of, information from a student's education records as required by law. Records of such requests will be maintained for as long as the student record is maintained. The record will indicate the name of the party making the request, any additional party to whom it may be redisclosed and the requestor’s indicated interest in the records.

H. Correction of Education Records
Students have the right to ask to have records corrected if they believe that the records are inaccurate, misleading or in violation of their privacy rights. The procedure for correcting education records is as follows:

1. A student must request in writing of the appropriate custodian to amend a record. In so doing, the student should identify the part of the record she or he wants changed and specify why it is believed to be inaccurate, misleading or in violation of her or his privacy or other rights.

2. The University may comply with the request or it may decide not to comply. If it decides not to comply, the University will notify the student of the decision at her or his last known address of record and advise the student of the right to a hearing to challenge the information believed to be inaccurate, misleading or in violation of the student's rights.

3. A written request for a hearing must be submitted to the appropriate records custodian. The University will arrange for a hearing on the matter and will notify the student, reasonably in advance of the hearing, of the date, place and time that hearing will be held.

4. The hearing will be conducted by a hearing officer who has no direct interest in the outcome of the matter to be decided; however, the hearing officer may be an official of the institution. The student shall be afforded a full and fair opportunity to present evidence relevant to the issues raised in the original request to amend the student's education records. The student may be assisted by one or more individuals, including an attorney.

5. The hearing officer will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence presented and the reasons for the decision. A copy of the written decision will be provided to the student at her or his last known address of record within a reasonable time after the hearing, usually 10 business days unless circumstances require a longer period for a decision to be prepared.

6. If the hearing officer decides that the challenged information is not inaccurate, misleading or in violation of the student's right of privacy, she or he will notify the student of the right to place in the education record a statement commenting on the challenged information and/or a statement setting forth reasons for disagreeing with the decision.

7. The statement will be maintained as part of the student's education records as long as the contested portion is maintained. If the University discloses the contested portion of the record, it also must disclose the student's statement.

8. If the University decides that the information is inaccurate, misleading or in violation of the student's right of privacy, it will amend the record and notify the student, in writing at her or his last known address of record, that the education record has been amended.

I. Annual Notification
Students will be notified of their Family Educational Rights and Privacy Act (FERPA) rights annually by publication in the student handbook.

J. Application of This Policy
This policy shall be applied in accordance with the written Guidelines for Records Custodians. Questions or concerns about this policy and its interpretation should be directed to the appropriate dean.

Revised 9/09