Release of Information

Graceland University Policy and Procedure

SUBJECT: Privacy, Disclosure and Access to Student Records.

PURPOSE: To comply with the Federal Educational Rights and Privacy Act (FERPA), and to delineate Graceland University’s (Graceland) policy for disclosure of, and access to, educational records.

DEFINITIONS:

Directory Information: Graceland designates the following as directory information: name, local and home address, local and home telephone number, e-mail address, date and place of birth, major field of study, class level, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards earned, most recent previous school attended, and photograph. Graceland may disclose any of the above directory information without prior consent, unless notified in writing by the student to the contrary prior to the start of classes each period of enrollment. Such writing should be delivered to the Office of Residence Life.

Education records: any record (in handwriting, print, film, tapes, video, or other medium) maintained by Graceland or an agent of Graceland, which is directly related to a student, except the following:

A personal record in any form (including paper, electronic mail, and voice mail forms) kept by a non-faculty 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 or permanent replacement for the maker of the record;
An employment record of a student whose employment is not contingent on the fact that he or she is a student, provided the record is used only in relation to the student’s employment;
Records maintained by Health Services if the records are used only for treatment of a student and made available only to those persons providing the treatment;
Alumni records which contain information about a student after he or she is no longer in attendance at the University and which do not relate to the person as a student.

Graceland Official: A person employed by the University in an administrative, supervisory, academic or research, support staff or student worker position; person elected to the Board of Trustees; a person employed by or retained by Graceland to perform a special task, such as an attorney or auditor; employees or students appointed to official Graceland committees.

Designated Records Custodians: The following positions are the designated record custodians and only those custodians should release the types of data listed in the first column:

Types of Data	Record Custodian
Admissions Records for students prior to enrollment for all programs administered by the Lamoni campus	Vice President for Enrollment Management
Admissions Records before and following enrollment for all programs administered by the Independence campus	Vice President for Enrollment Management
Admissions Records following enrollment for all programs administered by the Lamoni Campus	Vice President for Enrollment Management
Placement Records	Director, Office of Institutional Research
Cumulative Academic Records	Registrar
Discipline Records	Vice President for Student Life, Dean of Students
Employment Records for Students	Director of Human Resources
Financial Records for Students	Director of Student Financial Services
Health Records for Student Athletes	Director of Athletic Training
Health Records for Students in programs administered by Independence	Dean, School of Nursing
Progress Records, courses in progress	Course Instructor
Progress Records, degree in progress	Registrar
Other Records	The appropriate official will collect such records, direct the student to their location, or otherwise make them available for inspection and review

POLICY:

Access of Education Records

In accordance with Section 99.7 of the Family Education Rights and Privacy Act (FERPA) regulations to provide annual notification of students’ FERPA rights, Graceland University includes such notification in the student handbook.

Student’s inspection of education records: Students may inspect and review their education records upon request to the appropriate record custodian. Students may be required to complete a written request identifying as precisely as possible the record or records he or she wishes to inspect. The record custodian will make the needed arrangements for access as promptly as possible and notify the student of the time and place where the records may be inspected. Graceland will provide the copy as expeditiously as possible, but no later than 45 days from the receipt of the request. When a record contains information about more than one student, the student may inspect and review only the records which relate to him/her. If multiple students are referenced within a record, the record custodian will redact names and any identifying phrases.

Right of refusal to inspect records: Graceland 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 his or her right of access, or which were placed in file before January 1, 1975.
Records connected with an application to attend Graceland if the application was denied.
Those records which are excluded from the FERPA definition of educational records.

Right to deny transcripts and copies of records: Graceland reserves the right to deny transcripts or copies of records not required to be made available by the FERPA in any of the following situations:

The student has an unpaid or delinquent financial obligation to Graceland.
There is an unresolved disciplinary action against the student.

Fee for copies: The standard fee for copies will apply for any records made available in accordance with this policy.

Disclosure of Education Records

Directory information may be disclosed without prior consent of the student unless Graceland is notified in writing to the contrary prior to the start of classes.

Graceland will disclose information from a student’s educational records only with written consent of the student, except the following:

To Graceland officials who have a legitimate educational interest in the records. A Graceland official has a legitimate educational interest if the official is:
1. Performing a task that is specified in his or her position description or by a contract agreement.
2. Performing a task related to the student’s education.
3. Performing a task related to the discipline of a student.

To officials of another school, upon request, in which the student seeks or intends to enroll.
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.
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.
If required by a state law requiring disclosure that was adopted before November 19, 1974.
To organizations conducting certain studies for or on behalf of Graceland.
To accrediting organizations to carry out their functions.
To parents of a student, if the student is claimed as a dependent for income tax purposes.
To comply with a judicial order or a lawfully issued subpoena.
To appropriate parties in a health or safety emergency.
To an alleged victim of any crime of violence: the results of any Graceland disciplinary proceeding against the alleged perpetrator of that crime with respect to that crime.

Record of requests for disclosure: Graceland will maintain a record of all requests for and/or disclosure of non-directory information from a student’s education records, other than a Graceland official with a legitimate educational interest. The record will indicate the name of the party making the request, any additional party to whom it may be redisclosed, and the legitimate interest the party had in requesting or obtaining the information. The record may be reviewed by the student, and/or parents of the student if the parents claim the student as a dependent for income tax purposes.

Correction Of Education Records

Student’s right to request correction of records: Students have the right to request corrections of records they believe are inaccurate, misleading, or in violation of their privacy rights. Following are the procedures for the correction of records:

A student’s request to amend a record must be directed to the designated record custodian (see the record custodian listing above). The student must identify the part of the record to be changed and specify why the information is inaccurate, misleading or in violation of the student’s privacy or other rights. If the record custodian agrees with the request, the record will be changed.

If the record custodian believes that the information presented does not merit a change, the student will be notified of that decision and advised of the hearing process. If a hearing is requested the following steps will be followed:

A written request for a hearing must be submitted by the student to the record custodian who will arrange for a hearing and notify the student in a timely manner of the date, place and time of the hearing.
The hearing will be conducted by an unbiased hearing officer who may be an official of Graceland. The student will 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.
The hearing officer will prepare a written decision based solely on the evidence presented at the hearing. The documentation will include a summary of the evidence presented and the reasons for the decision.
If the hearing officer decides that the information contested is inaccurate, misleading or in violation of the student’s right of privacy, the record will be changed.
If the hearing officer decides that the information contested is not inaccurate, misleading or in violation of the student’s right of privacy, the record will not be changed. The student will then be notified of his or her right to place a statement in the record commenting on the challenged information and/or a statement setting forth reasons for disagreeing with the decision. The statement will be maintained as part of the student’s education records as long as the contested portion is maintained. If Graceland discloses the contested portion of the record, it must also disclose the student’s statement.

PROCEDURE:
In accordance with FERPA, academic information about a student will not be released unless written authorization is given by the student. However, Graceland officials may use discretion to release directory information (defined above) unless the student specifically requests otherwise following the process set forth above.

Approved: January 23, 2019