Fort Lewis College Official Seal

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Preventing Oral Disclosure of Student Records

Policy Summary

This policy establishes how the College will comply with Family Educational Rights and Privacy Act regulations regarding oral disclosure of student records.

Policy Owner

President

Approval Date

November 18, 2015

Effective Date

November 18, 2015

Search Terms

president, p, f, a, r, ferpa, student, academic, records

Scheduled for Review

Fall 2020

Policy Statement

  1. The Family Educational Rights and Privacy Act (FERPA) became a law in 1974.  Per 34 CFR 99.3, “Disclosure means to permit access to or the release, transfer, or other communication of personally identifiable information contained in education records by any means, including oral, written, or electronic means, to any party except the party identified as the party that provided or created the record.” 
  2. When a College employee provides services from a space that does not prevent oral disclosure of student records to persons without an educational interest, an alternative will be offered to students.  The designated space:
    1. Will have floor to ceiling walls and closed door where conversations in a reasonable voice cannot be discernible;

    2. Will be compliant with the Americans with Disabilities Act; 
    3. May be in a different building than the office providing the service;
    4. Will be equipped or equippable with the telecommunications and information technology required to provide the service.

  3. Signage will be posted at individual service providers’ spaces, as well as at office reception desks, notifying students that they can request to meet in a private office setting with minimal risk of disclosure to person(s) without a legitimate educational interest.

Reason for Policy 

The internal audit of the Office of Financial Aid, which was approved by the Board of Trustees on May 29, 2015, required action be taken to comply with FERPA disclosure requirements.

Responsibilities 

For following the policy: Director of Office of Financial Aid, Registrar, Director of Student Success and like offices

For enforcement of policy: Associate Vice President for Enrollment Management and supervisors of like offices

For oversight of policy: President

For notification of policy: Policy Librarian

For procedures implementing policy: As outlined in 5-5 Facilities Use Policy