Policies Governing Student Records

Policies are designed to ensure that the College has a student record-keeping system that achieves an effective balance between the student’s right to privacy and the College’s need to use the same information in carrying out its educational mission. The College’s policies governing student educational records are in full compliance with the Family Educational Rights and Privacy Act of 1974 (FERPA), also known as the Buckley Amendment. These policies assure students’ rights of privacy, while providing them with access to their own records.

The Family Educational Rights and Privacy Act of 1974 (Buckley Amendment)
These policies conform to the Family Educational Rights and Privacy Act of 1974 (Buckley Amendment), referred to hereafter as FERPA, and are a declaration of existing practice.

I. Definitions

1. In these defined policies, the term “student” refers to any person who has completed the registration process for any semester at Purchase and for whom the College has developed an educational record. Applications for admission are not included in the term.
   
   
2. “Educational records” are all collections of personally identifiable information pertaining to students; these records are maintained by the College or by personnel acting for the College. This includes computer files and written materials contained in a file folder in a traditional manner. As stipulated by FERPA, the following files are not considered “educational records” and, as such, are not available to students:
   1. Records maintained by the University Police Department, the Counseling Center, and Student Health Services;
   2. Financial records of parents;
   3. Employment files (i.e., applications for resident assistant and student manager positions and job-related materials);
   4. Records developed and maintained by faculty and staff that serve their individual record-keeping purposes and remain exclusively in their individual possession.

II. Access
The essence of these guidelines and FERPA is that all students have the right to inspect their own educational records, irrespective of age or economic dependence on parents, with the exceptions listed above. Although the College is not required to release records maintained by the Counseling Center and Student Health Services, on written request by the student, information maintained in these files must be released to the appropriate professional of the student’s choice.

There is a general limitation that a student may not review letters or statements of a confidential nature included in any of their files before January 1, 1975. These materials are removed before a student reviews the folder and are returned to the folder after the review, if relevant to the file. (Refer to Expunging.) All materials included after January 1, 1975, are available for student inspection unless there is written evidence in the folder that the student has waived the right to review a particular item.

A request to inspect a file should be made directly to the office holding the file. For those unable to come to the campus because of geographical location, requests by mail are honored. Copies are available to all students at the cost of reproduction. (Contact the Office of the Registrar for further information.)

Parents and legal guardians have access to their dependent’s records if the student is a dependent in the Internal Revenue Service definition of the term or if the student has given written consent. Thus, it is the parents’ or guardians’ responsibility to present evidence of dependency before a student record may be released. If such evidence is presented, the student is notified.

Student records are accessible to employees of the College whose primary job responsibilities require access to some or all of the information included in a particular file and to employees with a legitimate educational need to review a student’s file. Each student’s file must contain a list of individuals who have requested or gained access to the records, excluding the student, school officials, those with written consent from the student, and those who have requested directory information.

III. Right of Challenge
A student who discovers what he or she may feel to be an inaccurate, misleading, or incomplete recording of information in the personal record may request that a change be made by the appropriate submitting office. If the request for change is denied, the student may request that the hearing be conducted within a reasonable period of time by a person who is not directly involved in the issue, appointed by the vice president for student affairs and preferably approved by the student. In controversies related to a grade, the debate is limited to accuracy and completeness, and may not entail the justification for a particular grade. Complaints concerning the conduct of the hearing or the aspects of these guidelines may be directed to:

The Family Educational Rights and Privacy Act (FERPA) Office
Department of Education
330 Independence Avenue, SW
Washington, D.C. 20201

Students who differ with the decision rendered in the hearing are entitled to include a statement explaining their dissent in their file.

IV. Waiver of Access
Students may waive their right to inspect a particular file or portion of a particular file. Individual referees may require that students waive their right to review a particular letter of reference they have been asked to write. Faculty or staff involved in advising may recommend that students waive their right to review recommendation letters, in the belief that a waiver effectively increases the credibility and usefulness of the reference when reviewed by the admissions committee or prospective employer. The College may not, however, require that any student waive the right of access to a file or any part of the file.

Student waiver of access to letters of recommendation is generally exercised on a letter-by-letter basis. This may be done by affixing a signed, dated statement to the letter before its inclusion in a folder; or, in the case of letters included in the credential file maintained by the Career Development Center, by signing the candidate’s waiver of right of access to confidential reference letters, printed on the confidential reference form.

V. Release of Records

1. There is to be no oral or written release of personally identifiable information from any student educational record without the signed and dated consent of the student, except to:
   1. authorized College personnel, defined by the person responsible for the file as having a reasonable need to know;
   2. state and federal education authorities to whom information must be made available by statute and/or for the audit of federal programs;
   3. organizations and educational agencies involved in testing, administering financial aid, or improving instruction, provided the information is presented anonymously;
   4. accrediting agencies;
   5. parents and legal guardians of students regarded as “dependent” by the IRS definition of the term, if dependency is demonstrated (access is “view only”);
   6. situations of compliance with court-order subpoena, in which case an attempt is made to notify the student in advance;
   7. appropriate persons in the case of emergency;
   8. College counsel.
   
   
2. Information routinely released to the public (i.e., commencement listings, election results, and rosters of athletic teams) is regarded as “public” or “directory information” and, as such, may be released without a student’s consent. Specific items regarded by the College as directory information are listed in the Registration Schedule published each semester by the Office of the Registrar as part of an announcement informing students of their rights to exclude themselves from any or all such releases. Items currently regarded by Purchase as directory information are noted later in this section. Students must notify the registrar in writing if certain information is not to be released.
   
   Information may be released for research and for purposes related to the welfare of certain groups in an anonymous manner or in a way that does not infringe on any individual’s right to privacy. One acceptable way is to remove all identifiable signs and to provide the information by class only. Another is to inform individuals of the chance to participate in a particular research project by informing them who to contact if they wish to participate. When any personally identifiable information is released from a student record in an authorized fashion, the party to whom the information is given must be notified that there is to be no release of that information to a third party.
   
   
3. Regulations concerning the release of information regarding alcohol or drug use or possession to parents or guardians of students under the age of 21 are published in the annual Student Handbook under “Alcohol or Drug Use/Possession Disclosure Policy.”

VI. Expunging
Student records should be free of extraneous data that no longer serve the purpose(s) for which they were gathered. Therefore, systematic attempts should be made to expunge extraneous materials in student records. Another recommended means is to purge files on an ad hoc basis in the review given each file before the student inspects it. Judgments concerning the relevance of materials should be made by the person who is responsible for the particular file.

VII. Annual Notices

1. Students are informed annually of the rights provided to them by FERPA and by the guidelines that are published in the Registration Schedule to inform students of their rights and responsibilities. Copies of these publications are provided to each student entering the College.
   
   
2. The registrar is responsible for establishing these guidelines and monitoring their implementation. Questions, concerns, and suggestions should directed to the Office of the Registrar, Student Services Building, First Floor, (914) 251-6360.
   1. Directory information includes:
      Name
      Local campus mailbox number
      Campus telephone number
      Home address
      E-mail address
      Home telephone number
      Date of birth
      Matriculation status
      Class level
      Current full-time or part-time status
      Photographs
      Dates of attendance and graduation
      Major fields of study and degrees
      
   2. Other information regarded as public:
      Information released in a routine manner to the appropriate representatives of various media for publicity purposes:
      1. awards and academic degrees given at Purchase;
      2. participation in recognized College activities (e.g., election outcomes, membership in athletic teams, participation in plays);
      3. personal information on members of College athletic teams (e.g., height, weight, high school).
   3. Refer to the Alcohol or Drug Use/Possession Disclosure Policy in the annual Student Handbook.

VIII. Directory of Educational Records

1. A compendium of all the educational records maintained for students, including title, description, and location of files, and the name of the person to contact. The directory includes:
   1. Advisor File, located in the office of the student’s advisor or school/conservatory: Advisor copy of narrative evaluations, declaration of major, registration forms, transfer credit evaluations, copies of petitions for rule exceptions.
   2. Academic Record File, located in the Enrollment Services, Student Services Building, First Floor, (914) 251-6360: Application form(s); correspondence; high school and/or community college records; scores from national standardized tests; transcripts from previous post-secondary schools; relevant and external transcripts; grades and their supporting documents; leave forms; declaration of major forms; change of advisor forms, probation letters; change of student status forms.
   3. Admission File, located in the Office of Admissions, (914) 251-6300: High school and college transcripts; recommendation letters; test scores; correspondence with students’ parents and others; application information; AP results; student’s own statement. Portions of this file are transferred to the Office of the Registrar on or about October 1 for students entering in the fall semester and February 1 for students entering in the spring semester.
   4. Divisional Student File, located in the office of the student’s academic dean: Department information on majors and graduate students; faculty appraisals: letters of reference to law schools, proposals from students to B.A.L.A. Committee, committee reply correspondence relating to project. Contact program chairpersons and the Premedical Advisory Committee.
   5. Digital Student Record File, located in the Enrollment Services, Student Services Building, First Floor: A digital record exists for every semester a student has been in attendance. Selected identification, classification, biographical, and academic information taken from various documents in the “paper files” listed above is submitted to the digital student record file for storage.
   6. Counseling Center File, located in the Counseling Center, Durst Family Humanities Building, Room 0007, (914) 251-6390: Counseling Center records are not considered educational records and are governed under the standards of practice established by the American Psychological Association.
   7. Credential File, located in the Career Development Center, Student Services Building, Second Floor, (914) 251-6370: Résumés; letters of recommendation; relevant transcripts; course list.
   8. Student Personnel File, located in the Office of the Vice President of Student Affairs, Student Services Building, Third Floor, (914) 251-6030: Letters of disciplinary charges to student; relevant information for the disciplinary hearing (all available to student); letter to student on disposition of the case.
   9. Health Services File, located in Student Health Services, Campus Center South, (914) 251-6380: Health Services records are not considered educational records and are governed under the standards of practice for medical records in the State of New York.
   10. International Student File, located in the Office of International Programs and Services, Student Services Building, Second Floor, (914) 251-6032: Copy of admission letter; copies of all immigration documents; arrival form; information regarding specific activities of a particular student (e.g., newspaper stories); all correspondence concerning the student and basic information sheet; latest internal transcripts; any and all documents required under authority of the U.S. Department of Homeland Security.
   11. Liberal Studies Degree Program File, located in the Office of the Academic Advisor, School of Liberal Studies & Continuing Education, Music Building, Suite 0089, (914) 251-6500: Copy of application; correspondence; latest internal transcripts; copies of transfer credit evaluation; copies of transcripts from previous colleges.
   12. Student Financial File, located in the Student Financial Services, Student Services Building, First Floor, (914) 251-6350: Federal application for financial aid; parent’s confidential statement; Financial Aid Form; parents’ and student’s federal 1040 form; statement of financial independence and other verifying agencies; Guaranteed Student Loan Program Application and letters of clarification.
   13. Residence Life File, located in the Office of Residence Life, Student Services Building, Third Floor, (914) 251-6321: Copies of license agreements, formal notifications, damage billings, and all matters related to student housing assignment and occupancy.
   
   
2. Student consumer information requirement:
   In compliance with both federal and state law, the College makes available to students or prospective students information about instructional programs, costs of attending the institution, financial assistance available to students, the refund policy, qualifications of faculty members, graduation rates, and placement of grades. The vice president for academic affairs and the vice president for student affairs are available to assist students or prospective students in obtaining information specified in the Regulations of the Commissioner of Education, Chapter 2, Sections 53.1–43.4.