STUDENT RECORD POLICY, PROCEDURES AND DEFINITIONS

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1 STUDENT RECORD POLICY, PROCEDURES AND DEFINITIONS PURPOSE The purpose of establishing this policy is to ensure Virginia Union University s compliance with the Family Educational Rights and Privacy Act (Buckley Amendment of 1974) which governs student educational records. FERPA OVERVIEW The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all institutions that are federally funded. When students enroll in an institution beyond the high school level, all rights granted to parents transfer to the student. Inherent in the FERPA regulations is an institution s responsibility to establish written guidelines to: 1) protect these records and 2) appropriately notify the student body of their rights under this legislation. Virginia Union University aligns itself with these federal regulations and therefore developed the definitions, policies and procedures below. DEFINITIONS (In accordance with 34 CFR part 99) 1. Education Official An individual employed by Virginia Union University (VUU) in an administrative, supervisory, academic, research or other support staff position; An individual that serves on VUU s governing body; An individual that is employed by or under contract with VUU, to perform a special task. 2. Educational Record Records that are directly related to a Virginia Union University (VUU) student and maintained by VUU or by a party acting for VUU. The following are not classified as educational records: a. Sole proprietor records, b. law enforcement records, c. employment records, d. medical records, and e. alumni records created post attendance. 3. Eligible Student A Virginia Union University student to which privacy rights have transferred. 4. Directory Information Virginia Union University classifies the following information as directory information. This information can be released without the written consent of the student: a. name, address, telephone number, b. major field of study, school or department, c. dates of attendance,

2 d. enrollment status, e. degrees and awards received, f. expected date of completion of degree requirements and graduation, g. most recent/ previous school attended, h. class rosters (to only those enrolled in that class), i. participation in officially recognized activities and sports and j. weight and height of athletic team members and other similar information *Students wishing to maintain the confidentiality of the information above are required to submit a written request to the Office of the Registrar that specifically notes the information that should be kept private. This request must be kept in the student s educational record. 5. Disclosure To permit access to or the release, transfer or the communication of personally identifiable information contained in Virginia Union University student education records to any party by any means which includes access to education records by school officials. 6. Legitimate Educational Interests A Virginia Union University official has legitimate educational interest if the official needs to review an education record in order to fulfill his/ her professional responsibilities for the University. POLICY AND PROCEDURES (In accordance with 34 CFR part 99) Student Rights In accordance with FERPA, students at Virginia Union University have the following rights: 1. The right to inspect and review his/ her educational record(s) within 45 days of the day the University receives a request for access. Any VUU student wishing to request to inspect and review his/ her file is required to adhere to the following procedures: a. Required to submit a written request to the appropriate office(s) that identifies the record(s) that the student wishes to inspect. b. An appropriate University official representing the office of interest will make arrangements for access (within the given timeframe) by notifying the student in writing of the time and place where the records may be inspected. c. All information pertaining to the student s request to inspect and review his/ her educational record will be immediately filed in the student s educational record. d. If the records are not maintained by the University official in which the request was submitted, that official is required to advise the student of the correct official with whom the request should be addressed. *Copies of a student record can be made available upon request, if and only if it is impossible for the student to review his/ her record within 45 days of the request. A fee of $1.00 per page will be assessed and must be paid prior to the dissemination of the information. 2. The right to request the amendment of his/ her educational record that he/ she believes to be inaccurate, misleading, or otherwise in violation of his/ her privacy rights under FERPA. A student who wishes to ask the University to amend a record is required to do the following:

3 a. Must submit a written request to the appropriate office(s) that identifies the record in which he/she wants to amend. All written requests must include the following: i. Clearly identify the part of the record that should be amended and ii. Clearly identify why the record should be changed. b. If the appropriate University official decides not to amend the record as requested, the University official will notify the student in writing of the decision and the student s right to an appeal hearing regarding the request for amendment. c. Information regarding the appeal process will be provided to the student when notified of his/ her right to a hearing. d. All written information pertaining to the student s request to amend any part of his/ her record will be filed in the student s record. 3. The right to provide written consent before the University discloses personally identifiable information from his/ her educational record, except when FERPA authorizes disclosure without consent. a. Each University official is required to have readily available, disclosure forms for those students that are willing to consent to the release of his/ her information. b. Each student is required to sign and date the form. c. All signed and dated consent forms will be immediately filed in the student s educational record. *Virginia Union University intends to forward information in educational records as requested by the student and/ or by the forwarding institution. 4. The right to file a complaint with the US Department of Education concerning alleged failures of Virginia Union University to comply with the requirements of FERPA. The name and address of the Office that governs FERPA is: Disclosure Exceptions Without written consent: Family Policy Compliance Office U.S. Department of Education 400 Maryland Avenue, SW Washington, DC In accordance with FERPA, Virginia Union University officials can disclose information in an educational record, without consent, to the following parties or under the following conditions (34 CFR part 99.31; 99.37):

4 a. School officials with legitimate educational interest. b. Other schools to which the student is transferring. c. Specified officials for audit or evaluation purposes. d. Appropriate parties in connection with financial aid to a student. e. Accrediting organizations. f. In compliance with a lawfully issued subpoena. g. Appropriate officials in cases of health and safety emergencies. h. Appropriate family members in cases of health and safety emergencies as documented on student emergency forms. Denial of student access: In accordance with FERPA, Virginia Union University is not required to permit access to the following types of information (34 CFR part 99.8; 99.10; and 99.12): a. Financial information submitted by parents. b. Confidential letters and recommendations in which a student waived his/her rights of inspection. c. Information specifically excluded under FERPA s definition of educational records. d. Student health, psychiatric and counseling records maintained in connection with the treatment of the student. e. Written medical, psychiatric, psychological and/ or counseling case notes for which the basis of any diagnoses or recommendation of treatment plans remain privileged information not accessible to the student.

5 PROCEDURES FOR APPEALING THE INNACURACY OF CONTENTS IN AN EDUCATIONAL RECORD A student may challenge or appeal the contents of his/her education record which they consider to be inaccurate, misleading or otherwise in violation of their privacy rights. Students may initiate the appeal process by following the procedures below: Must submit a written request to challenge the inaccurate information in a specific student record to the department that maintains the record of concern. An attempt must then be made to informally discuss the information at hand. If the informal discussion does not resolve the matter, then the student can request a formal hearing process. a. Students requesting a formal process will be notified in writing of the date, time and place of the hearing. b. All formal procedures will be held by at least one disinterested Virginia Union University employee. The outcome of the formal hearing process will be communicated to the student in writing within two days of rendering a decision. This decision is final. APPLICABILITY This policy and procedures apply to all VUU employees that maintain student records, students and constituents of the University without exception. UNIVERSITY ADHERANCE TO STUDENT RECORD POLICY Faculty, Staff and students are informed of the policy and trained to adhere in the following way: Information Format Faculty/ Staff Students Academic Catalog [link to page 50] X X Electronic Notifications X X Post/ Pre-School Conference X Student Handbook [link to page 28] X X University Website X X

6 STORAGE, RELEASE, DISSEMINATION AND DISPOSITION OF STUDENT RECORDS Storage and Retention All educational records at Virginia Union University are retained in accordance with Family Educational Rights and Privacy Act (FERPA), American Association of Collegiate Registrars and Admission Officers (AACRAO), the Jean Cleary Act and EDGAR. VUU s educational records are retained in the following manner: Record Type Storage Locations Minimal Retention Period Academic Records Academic Action (ie. Suspensions, warning, probation, etc.) Regisrar s Office Permanent Add/ Drop Forms Registrar s Office 1 Year after date submitted Admissions Records Admissions Office 2 years from date submitted Application for Graduation Registrar s Office 1 year after date of last attendance Advising Change of Grade Forms Appropriate Academic Area Registrar s Office Appropriate Academic Area 1 year after last advising date Permanent Change of Major Forms Registrar s Office 5 years after graduation Commencement Forms Registrar s Office Permanent Correspondence Registrar s Office Appropriate Academic Area 5 years after graduation Degree Audit Records Registrar s Office 5 years after graduation Enrollment Verifications Registrar s Office 1 year after verifications Graduation Authorizations Registrar s Office 5 years after graduation International Student Forms Registrar s Office Admissions Office Registrar s Office 5 years after graduation Name Change 5 years after graduation Authorizations Personal Data Information Registrar s Office 1 year from date Forms submitted Registration Forms Transcript Requests Transcript Credit Registrar s Office 5 years after date of Evaluations graduation Transcripts Registrar s Office Permanent Withdrawal Authorizations Registrar s Office 2 years after graduation

7 Non- Academic Records Campus Police Campus Police Judicial Affairs Residence Life 7 years after graduation Career Services Career Services 5 years after graduation Counseling Counseling and Student Development 10 years after last appointment Financial records Financial Affairs 10 years Judicial Affairs Judicial Affairs (excluding 7 years suspensions) Residence Life Residence Life Judicial Affairs Campus Police 7 years Student Activities Student Activities Judicial Affairs Campus Police 7 years Student Leadership Student Leadership 5 years Development Development Upward Bound Upward Bound 10 years Dissemination Hardcopy Records All official hardcopy educational records are secured in fireproof filing cabinets behind locked doors in a location appropriate for the record type. Unofficial documents are stored in locked filing cabinets behind locked doors. Only authorized staff and student workers have access to these records and are required to sign confidentiality forms prior to accessing the educational records. Each department is responsible for creating a confidentiality form that meets the needs for that particular area. Please note that the University is converting to an imaging system for all official files stored in the Registrar s Office. The imaging company that the Registrar s office selected is Virtual Image Technology. They are based out of Charlotte, North Carolina. This company will image all hardcopy files dating from 1981 to prior years of the university. These documents will be entered into an imaging system so that office staff can access records electronically. Electronic Records Virginia Union University subscribes to Jenzabar, an electronic record maintenance system. Educational records maintained electronically can only be accessed by appropriate education officials via password protected measures. These files are backed up on a daily basis and can be accessed remotely [LINK to Jenzabar back up process]

8 Microfische All official hardcopy educational records are secured in fireproof filing cabinets behind locked doors in a location appropriate for the record type. Only authorized staff and student workers have access to these records and are required to sign confidentiality forms prior to accessing the educational records. Old, damaged microfilm are currently being copied onto new microfilm for ease in reading and accessibility. These records are in the process of being imaged as well. LOCATION OF STUDENT EDUCATIONAL RECORD NOTIFICATIONS AND EDUCATIONAL RECORD FORMAT Location of Notification Academic Catalog Pg. 50 Student Handbook Pg. 28 On line Sites Record Format Hardcopy Electronic Hardcopy Electronic Electronic Students and other members of the University community are informed of the policies and procedures governing student records in the following manner: a. The University catalog on page 50. a. Made available in hardcopy in the Office of the Registrar and b. On the University webpage at b. Student Handbook on page 28. a. Made available in hardcopy on reserve in the University library, b. The Judicial Affairs webpage at and c. Sent electronically via VUU twice each semester i. Once upon arrival of new students ii. Once on the official census date

9 VIRGINIA UNION UNIVERSITY CONSENT TO DISCLOSE STUDENT INFORMATION I,, give the following offices permission to disclose information in my educational record to those listed below. I also acknowledge that this form remains in effect until I provide written notification to revoke the consent privilege of the offices/ departments listed. All revocation requests must be submitted in writing and must be area specific. Student Name: Student ID: Student Telephone Number: (local) (cellular) (permanent) Information to be released by: I would like to grant the following offices permission to disclose information in my educational record that is area specific: Academic Department/ Advisor (Please specify: ) Campus Safety Financial Aid Registrar s Office Student Affairs Department (Please specify: ) Information to be released to: Please release information in my educational record(s) from the area(s) noted above to: 1. Name: Relationship: Address : Phone Number(s): 1. Name: Relationship: Address : Phone Number(s): Student Signature Date University Official Signature Date

10 ELECTRONIC BACK UP PROCEDURES FOR AS400 Our strategy for backing up the as400 Student information SQL Server databases includes: All AS400 data is secured daily. All data is backed up on an 8mm data cartridge. The 8mm data cartridge is recorded to the Tape Back Up Log. The Tape Backup Log keeps an accurate record of which tape was used, on what date the tape was executed and who removed, stored (previous backup tape) and loaded (new backup tape). These 8mm data cartridges are changed Monday through Thursday of every week and are stored in a fire proof file cabinet. Every Friday the weekly backup is ran (which backups the entire system) and is also stored in a fireproof file cabinet. The importance of having the entire system backed up is in case of a major system failure, all PTFs and current data are only a week behind and the last daily brings the system as current as it can be. REQUESTING A LOGON TO THE AS400CAMPUS INFORMATION SYSTEM All AS400 Users are requested to complete a Logon ID Request Form [LINK TO LOGON ID REQUEST FORM]. The Logon ID Request Form needs to be completed by the Requester by printing his name, department, phone number and reading /signing the Requester Non-Disclosure Statement. The Requester Supervisor must sign off on the form confirming that the Requester understands the Requester Non-Disclosure Statement that the system is to be used for Virginia Union University Business only. Once the form is completed the IT Department assigns a logon ID to the Requester. The Requester has to date/sign off that he was issued a Logon ID. Once assigned a Logon ID the system will require the Requester to change password every ninety days. Copies of all Logon ID Request Forms are stored in the fire proof file cabinet in a private folder.

11 Virginia Union University Logon ID Request Form for AS400 Requester Information: (To be completed by requester and signed by both Requester and Supervisor) Last Name First Name Initial Department Phone # Requester Non-Disclosure Statement: Virginia Union University is granting me access to the Jenzabar EX Campus Information System. I will use this access in a responsible way and only to accomplish legitimate Virginia Union University business. I will not disclose my password to other people or knowingly or carelessly make it possible for other people to access the University s computer system using my logon ID and password. I understand that I am responsible for all actions that are taken under my logon ID. I further understand that my assigned identification logon and password serve as my electronic signature for all activity while active in the computer system. I am aware of my responsibility for complying with the University s standards contained in the Policies and Procedures Manual, including the handling of sensitive information. I understand that computer programs, software, listings and the information in the computer system to which I will access are valuable assets of Virginia Union and are considered proprietary. I am aware that this information may be protected by laws and other Copyright, and is the property of Virginia Union University. If I no longer require this access or a change in access requirements occur, I will promptly notify my Supervisor. I understand that unauthorized access or disclosure of Virginia Union information will be subject to management review and action, which could include termination of computer privileges. Requestor s Signature Approval: Date The individual identified above reports to me and has an appropriate business need for access to Virginia Union computer system. Supervisor s Signature For Information Technology Center Use Only: Date Date Received: Date Processed: Processed By: Logon ID Issued: Person Notified: Date Notified:

12 ELECTRONIC BACK UP PROCEDURES FOR JENZABAR EX Our strategy for backing up the Jenzabar Student information SQL Server databases includes: A combination of full database backups and transaction log backups. Full backups copy the entire database backup device. Transaction log backups copy the transaction logs to a backup device. Transaction log backups can be thought of as incremental backups. We backup transaction logs every 7 hours and a full database backup every night to local dedicated hard drives with a RAID 1 (Redundant Array of Inexpensive Disks 1) configuration. We then include the SQL backup files to our nightly system tape backup routine as a part of our disaster recovery procedure that is on a 30 day tape rotation cycle and are stored in a fireproof cabinet. We also backup the SQL backup files to a network storage devise off site in the CD King Building. REQUESTING A LOGON TO THE JENZABAR CAMPUS INFORMATION SYSTEM All Jenzabar Users are requested to complete a Logon ID Request Form [LINK TO LOGON ID REQUEST FORM]. The Logon ID Request Form needs to be completed by the Requester by printing his name, department, phone number and reading /signing the Requester Non-Disclosure Statement. The Requester Supervisor must sign off on the form confirming that the Requester understands the Requester Non-Disclosure Statement that the system is to be used for Virginia Union University Business only. Once the form is completed the IT Department assigns a logon ID to the Requester. The Requester has to date/sign off that he was issued a Logon ID. Once assigned a Logon ID the system will require the Requester to change password every ninety days. Copies of all Logon ID Request Forms are stored in the fire proof file cabinet in a private folder and in the employees employment file located in the Human resource office.

13 Virginia Union University Logon ID Request Form for Jenzabar EX Requester Information: (To be completed by requester and signed by both Requester and Supervisor) Last Name First Name Initial Department Phone # Requester Non-Disclosure Statement: Virginia Union University is granting me access to the Jenzabar EX Campus Information System. I will use this access in a responsible way and only to accomplish legitimate Virginia Union University business. I will not disclose my password to other people or knowingly or carelessly make it possible for other people to access the University s computer system using my logon ID and password. I understand that I am responsible for all actions that are taken under my logon ID. I further understand that my assigned identification logon and password serve as my electronic signature for all activity while active in the computer system. I am aware of my responsibility for complying with the University s standards contained in the Policies and Procedures Manual, including the handling of sensitive information. I understand that computer programs, software, listings and the information in the computer system to which I will access are valuable assets of Virginia Union and are considered proprietary. I am aware that this information may be protected by laws and other Copyright, and is the property of Virginia Union University. If I no longer require this access or a change in access requirements occur, I will promptly notify my Supervisor and the department of Information Technology I understand that unauthorized access or disclosure of Virginia Union information will be subject to management review and action, which could include but is not limited to termination of computer privileges, termination of employment and prosecution to the fullest extent of the law Requestor s Signature Approval: Date The individual identified above reports to me and has an appropriate business need for access to Virginia Union computer system. Supervisor s Signature For Information Technology Center Use Only: Date Date Received: Date Processed: Processed By: Logon ID Issued: Person Notified: Date Notified:

14 OFFICE OF JUDICIAL AFFAIRS Statement of Confidentiality All information disclosed, verbally and in writing, from the Office of Judicial Affairs; the parties involved; or by witnesses in the judicial cases shall not be divulged by Board members to anyone, including fellow Board members. (An exception to this is in cases of abuse or imminent threat of danger to self or others, at which time the information shall be shared with the Office of Judicial Affairs, the Vice President of Student Affairs, Campus Police and/or the University President). All records, reports and other documents received by a Board member while serving in that capacity shall be strictly confidential. The Board member shall not divulge such records or testify in regard to the case in any adversary proceeding or judicial forum. The Office of Judicial Affairs will solely maintain all judicial files. All paperwork and notes obtained within the hearing must be turned in prior to departing the hearing room. Failure to comply with the above statement of confidentiality will result in immediate termination from the Judicial Board and a recommendation by the Office of Judicial Affairs to the appointing body for further review and penalties. I promise to uphold the strictest confidentiality regarding all judicial cases. I understand that violation of this statement of confidentiality will result in immediate termination of service and a referral to the appointing body for further action. Judicial Board Member Date Director of Judicial Affairs Date