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RIGHT OF PRIVACY:
STUDENT RECORDS POLICIES AND PROCEDURES
FOR
HOLLINS UNIVERSITY

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FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT OF 1974,
AS AMENDED

MAY 1999

TABLE OF CONTENTS

I. Annual Notification

II. Definitions

III. Procedures to Inspect Education Records

IV. Right of University to Refuse Access

V. Refusal to Provide Copies of Records

VI. Fees for Copies of Records

VII. Disclosure of Information to Requesters External to Hollins University

Directory Information

VIII. Disclosure of Information Within Hollins Community

IX. Records of Requests for Disclosure

X. Additions, Deletions, or Corrections to Educational Records

XI. Location of Guidelines

Family educational rights and privacy act Of 1974, as amended (FERPA)

RIGHT OF PRIVACY: STUDENT RECORDS POLICIES AND PROCEDURES FOR HOLLINS UNIVERSITY

I ANNUAL NOTIFICATION:

Students will be notified of their rights to inspect educational records annually by publication in the undergraduate student handbook, the graduate catalog and on the HollinsNet.

II DEFINITIONS:

For the purposes of this policy, Hollins University uses the following definition of terms:

Education records: Any record (in handwriting, print, tapes, computer media, film, or other medium) maintained by Hollins University or an agent of the university, which is directly related to a student, except:

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 another person;
Records created and maintained by the university law enforcement unit for law enforcement purposes;
An employment record of an individual 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 individual's employment;
Records made or maintained by a physician, psychiatrist, psychologist, or other recognized professional or paraprofessional 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.

III PROCEDURES TO INSPECT RECORDS:

Students may inspect and review their education records upon request to the appropriate record custodian:

RECORD TYPE	LOCATION	CUSTODIAN
Admission Records	Student Academic Affairs	Assoc. Dean for Student Academic Affairs
Cumulative academic record	Registrar's Office or Archives (records older than 80 years)	Registrar or staff Archivist
Health Records	Health Services	Director of Health Services
Financial Records	Business Office	VP for Finance & Administration
Placement Records	Career Development Center	Director of Career Development
Progress Records	Registrar/Assoc. Dean/Advisor's Office	Registrar/Assoc. Dean Advisor
Disciplinary Records	Student Services Office	Vice President of Student Services
Occasional Records	Appropriate Office	University official
(records not included above such as minutes or correspondence in areas listed)	Appropriate Office housing such records	University official responsible for collecting and maintaining such records

Students should submit to the records custodian or an appropriate university official a written request to inspect a record or records. This request must identify as precisely as possible the record or records he or she wishes to inspect.

The records custodian or an appropriate university official will make the needed arrangements for access as promptly as possible and notify the student of the time and place for inspection. Access will be given in 45 days or less from the date of receipt of the request in inspect.

When a record contains information about more than one student, the student requesting inspection may inspect and review only the records which relate to him or her.

IV RIGHT OF UNIVERSITY TO REFUSE ACCESS:

Hollins 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 his or her rights of access, or which were placed in the file before January 1, 1975.
Records connected with an application to attend Hollins University if that application was denied;
Those records which are excluded from the FERPA definition of education records.

V REFUSAL TO PROVIDE COPIES OF RECORDS:

Hollins University reserves the right to refuse to provide copies of education records under the following conditions:

If records have been received from other agencies with a clear direction that the record is not to be released to the student;
The student lives within commuting distance of the university and could, therefore, come to the campus to inspect the records;
The student has an unpaid financial obligation to the university. Any education record shall be retained by the university as a security interest until all such obligations are satisfied. Release of any such security interest prior or subsequent to any default by the debtors shall not be considered a binding precedent or modification on this policy.
There is an unresolved disciplinary action against the student.

VI FEES FOR COPIES OF RECORDS:

Hollins University reserves the right to change a fee for copying and mailing education records. A fee of $1.00 per page will be charged as a minimum. Additional fees may be charged depending upon the document copy requested.

VII DISCLOSURE OF INFORMATION TO REQUESTERS EXTERNAL TO HOLLINS UNIVERSITY:

Hollins University requires signed and dated written consent of the student to disclose information to agents/agencies external to the university except:

To certain officials of the U.S. Department of Education, the Comptroller General, and state or local educational authorities in connection with certain state or federally-supported educational programs;
In connection with a student's request for a 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 records disclosure is required by state or federal laws adopted prior to November 19, 1974;
To accrediting organizations to carry out their functions;
To parents who claim the student as a dependent for income tax purposes;
To comply with judicial order or lawfully-issued subpoena after the university has made a reasonable effort to notify the student in advance of compliance;
To organizations contracted by the university to conduct studies on behalf of the university;
To appropriate parties in health or safety emergencies;
To persons engaging in investigations of alleged crimes of violence;
Directory information so designated by the university.

DIRECTORY INFORMATION:

Hollins University designates the following items as directory information:

Category I: Campus Directories and Publications: Student name, class year or program, nickname, local mailing address, local residence address, local telephone number, parent name, student's permanent mailing address (usually the parent address). weight and height of athletes, photographs, date and place of birth, participation in officially recognized activities and sports, most recent previous school attended, field of study, e-mail address, awards and honors, full or part-time status.

A campus directory is published annually for internal use only. Distribution of the campus directory is managed by the Public Relations Office where all requests for external distribution must be sent.

Category II: External Requests: The university reserves the right to provide the following directory information to callers external to the university who request information such as confirmation of a student's attendance at Hollins University; dates of attendance (if known); degree awarded and date (if known); and withdrawal date (if known). All other requests for information from directory information is denied. An attempt is made (if requested by the caller) to reach the person about whom information is requested to let him or her know an attempt has been made to get in touch.

All or individual directory items may be deleted from directory information released internally or externally, provided written expression (Confidential Record form) is received by the office of the Vice President for Student Services no later than within three days of the start of classes for any term . A student who has a confidential hold on information his or her last term in attendance, will have the confidentiality honored as an alumnus/a.

VIII DISCLOSURE OF EDUCATION RECORDS WITHIN THE UNIVERSITY COMMUNITY:

Hollins University reserves the right to disclose information from a student's education records to internal agents/agencies of the university as follows:

To school officials who have legitimate educational interest in such records.

A school official is defined as a person employed by the university in an administrative, supervisory, academic, research, or support staff position; a member of the Board of Trustees; or a person employed by the university to perform a specific task, such as an attorney or an auditor.
A legitimate education interest is defined as:

In the act of performing a specific task as described in the job description of the school official requesting the information or by contractual agreement; in the performance of a task related to the student's education; in the performance of a task related to the discipline of a student; or in the process of providing a service or benefit relating to the student, his or her family or guardian, such as health care, counseling, job placement, financial aid, or other university services.

IX RECORDS OF REQUESTS FOR DISCLOSURE OF INFORMATION:

Hollins University will maintain a record of all requests for and/or disclosure of information from a student's education records to external inquirers.

The record will included the following information:

The name of the student's record from which information is requested;
The name of the party making the request;
The name(s) of any additional parties to whom the information is to be sent;
The legitimate interest for requesting the information

2. The records may be inspected and reviewed by the student and/or his or her parents.

X ADDITIONS, DELETIONS, OR CORRECTIONS TO EDUCATIONAL RECORDS:

Students have the right to ask to have records adjusted if they believe they are inaccurate, misleading, or in violation of privacy rights. Challenging a grade does not fall under the purview of FERPA regulations and has no bearing on these listed regulations and conditions.

The following conditions apply:

The student must make a formal request to amend a record. In doing so, the student must identify precisely the part of the record he or she is contesting. He or she must specify why the information is inaccurate, misleading, or in violation of privacy rights.
The university will review the request and either comply with the request to amend the record or notify the student of the decision not to comply, providing an opportunity for a hearing at which the student can challenge the decision.
Upon request, the university will arrange for a hearing, if necessary, and notify the student of the time, place, and date of the hearing.
The hearing will be conducted by a hearing officer, who is a third party with no interest in the case. The student will be afforded full and fair opportunity to present evidence relevant to the issue or issues raised in the request to amend the record. The student may seek outside assistance in his or her presentation, including the advice of counsel.
If the hearing officer decides the challenged information is not inaccurate, misleading, or in violation of the student's privacy rights, the student will be so notified. The student may place a statement setting forth his or her reasons for the challenge and the reason(s) for disagreeing with the decision.
Statements placed in the education records relating to challenged information will be maintained as a part of the student's file for as long as the contested portion of the file is maintained. If the university discloses the challenged information, it is required to also disclose the student's remarks relative to the decision.
If the hearing officer determines that the challenged information is inaccurate, misleading, or in violation of the student's privacy rights, the record will be amended. The student will be notified of the decision in writing, and the student will be provided an opportunity to inspect the amended record. The student may ask that all prior requesters of information be provided copies of the amended record(s).

XI LOCATION OF FERPA GUIDELINES

Copies of Hollins University FERPA guidelines will be available in all records custodial offices, in the office of the Vice President for Academic Affairs, in the office of Public Relations, in the office of the Vice President for Finance and Administration, in the office of the Vice President for Development and External Relations, and in the university library.

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