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RSCC Policy SA-01-01; Student Records: Control and Security

Roane State Community College
Policy Number: SA-01-01
Subject: Student Records: Control and Security
  1. Policy
    1. Regulations issued by the Department of Health, Education and Welfare pursuant to the Family Educational Rights and Privacy Act (FERPA) of 1974, provide the guidelines for control and security of student records. Student records reside in the office of Records and Registration, and the director of this office is responsible for the implementation of the regulations. Violations of these regulations should be reported to the Director of Records and Registration. Complaints of violation by the institution may be filed with the Office of the Secretary, United States Department of Education.
    2. Regulations provide for student access to records and privacy and protection of records. A further provision includes guidelines for correction of inaccurate entries. The intent of this regulation limits the challenge of grades to the accuracy of recording, not to the grade which the instructor awarded.
    3. There are definitive guidelines as to what kinds of information about a student may be released, to whom, and under what conditions and each individual is responsible for complying with the Buckley Amendment. Directory information may be released to anyone. Directory information includes a student's name, address, email address, telephone listing, date of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, enrollment status – part-time, full time, degrees and awards received, and the most recent previous educational institution attended by the student. Those who may have access to a student's actual record without the student's consent are those instructors and staff who have a "legitimate educational interest arising from the need to fulfill his/her assigned responsibilities." The designated college official will determine when such an interest exists.
    4. Appropriate references to this policy shall be included in each faculty and staff handbook and shall be included in orientation sessions for new employees who work with or have access to student records.
  2. Disclosure with Consent
    1. The institution may disclose personally identifiable information with the signed written consent of the student. The consent form must be dated and must specifically identify the particular records to be disclosed, the purpose of the disclosure and the persons to whom such disclosure is to be made.
    2. A copy of the consent must be maintained with the student's record to which it pertains. Unless the consent form specifies that the information may be disclosed further, the statement attached to the disclosed information shall also include a warning against further disclosure by the recipient.
  3. Disclosure Pursuant to a Subpoena
    1. The institution must disclose confidential student records pursuant to a lawfully issued subpoena or judicial order. Upon receipt of such a subpoena or judicial order, the institution shall examine the subpoena in order to verify that it has been executed by an officer of the court or other authorized official. (The TBR Office of General Counsel may be contacted for assistance in verification.)
    2. Prior to disclosure, the institution must use reasonable efforts to notify the student of the receipt of the subpoena or order and of the institution's intent to comply.
    3. A letter will be sent by certified mail to the last known address for the student. The letter should notify the student of the college’s intent to comply unless the student intervenes and should inform the student of the date the college will submit the requested documents. Under FERPA, the college has 20 days within which to comply with the request for student records. Requested documents must be sent with a notarized affidavit stating that proper notification to the student has occurred.
    4. Finally, a letter will be sent to notify the student that the college has complied with the request. All subpoenas for educational records received by the college should be forwarded to the Director of Records and Registration for compliance.
  4. Disclosure to Parents of Dependent Students
    The institution may disclose personally identifiable student records to parents of a student only if the student is a dependent of the parent as defined in Section 152 of the Internal Revenue Code.
  5. Disclosure to Officials of Other Schools and School Systems
    The institution may disclose confidential student records to officials of other schools and/or school systems in which the student is currently enrolled, or seeks, or intends to enroll, provided such disclosure is consistent with the following condition:

    The institution makes a reasonable attempt to notify the student, and/or parent if the student consents, of the disclosure at the student's last known address. The institution does not have to attempt notice to the student if the disclosure is initiated by the student at the sending institution.
  6. Student Records
    1. Student files at Roane State generally include only those documents submitted by the student in support of his/her application for admission to the college such as transcripts, the health history form, and the permanent record of courses for which the student has enrolled at this college. When a student wishes to review his/her records, a written request is to be submitted to the Director of Records and Registration.
    2. Upon receipt of this request, an appointment is arranged with the student within forty five (45) days. The records will be reviewed in the presence of a member of the Records Office staff. If, upon review, the student wishes to challenge the content of the file, this should be done in writing and addressed to the Director of Records and Registration. Most problems regarding records can be resolved between the student and the Director of Records and Registration.
    3. However, if a problem cannot be resolved, the student may request a hearing review. The hearing request must be submitted in writing to the Dean of Students who will schedule a review appointment with the student and the Review Panel. The panel designated to hold the hearing will be composed of the Vice President of Student Learning, the Dean of Students, the Director of Human Resources and/or the affirmative action officer. Decisions of this panel will be final. Decisions will be based solely on the evidence presented at the hearing, and written statements summarizing the evidence and stating the reasons for the decisions will be delivered to all parties concerned. The student may be assisted or represented by individuals of his/her choice and at his/her expense.
    4. The Dean of Students shall prepare a written recommendation to the Director of Records and Registration outlining any required revision of the records. The Dean of Students makes the final decision regarding record revision. The student may obtain a copy of each document in his/her school file at a cost of $1.00 per page.
    5. The written decisions resulting from the review procedure will become a part of the student's record. The student may submit a written clarification and explanation of his/her understanding, and this record also becomes a part of the student's record. The student is guaranteed due process protection and procedures.
  7. Disclosure in an Emergency
    Schools may disclose education records to parents if a health or safety emergency involves their son or daughter. In compliance with 99.21(b) of the regulations, the following points will be considered in determining whether or not the release of student information is necessary for the protection of the health or safety of the student or other individuals:
    1. The seriousness of the threat to the health or safety of the student or other individuals.
    2. The need for the information to meet the emergency.
    3. Whether the parties to whom the information is disclosed are in a position to deal with the emergency.
    4. The extent to which time is of the essence in dealing with the emergency. A full text of the official statement of the college relating to its interpretation and implementation of the Family Educational Rights and Privacy Act may be obtained from the Dean of Students.

Responsible Party: The Registrar shall be responsible for development and maintenance of this policy for issuance by the Vice President of Student Services and Enrollment Management.

Revision History: 07/01/1990, 07/01/1995, 02/21/2000, 11/29/2006, 06/04/2007, 06/15/2008, 08/20/2018
TBR Policy Reference: 3.02.03.00
TBR Guideline Reference: S-020
Revision Date Effective: 02/02/2021
Revision Approval By: Christopher L. Whaley, President
Original Date Effective: 01/11/1988
Original Approval By: Cuyler A. Dunbar, President
Office Responsible: Vice President Student Services & Enrollment Management
Reviewed: 02/12/2021

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