Student Records

FERPA Annual Notice

The Family Educational Rights and Privacy Act ("FERPA"), a federal law, provides students with certain rights with respect to their education records. These rights are:

1. The right to inspect and review your education records within forty-five (45) days of the day the College receives a request for access. You should submit to Student Affairs a written request that identifies the record(s) you wish to inspect. Student Affairs will make arrangements for access and notify you of the time and place where the records may be inspected. If the records are not maintained by Student Affairs, Student Affairs will advise you of the correct official to whom your request should be made.
2. You have the right to challenge an item in your education records believed to be inaccurate, misleading or otherwise in violation of your privacy rights.  You may file a grievance pursuant to Policy 05.03.060 – Student Grievance beginning at Step Three. If the final decision is that the information in the record is, in the College’s determination, not inaccurate, misleading or otherwise in violation of the privacy rights of the student, the Dean of Student Services shall inform you of the right to place a statement in the record commenting on the contested information in the record or stating why you disagree with the College’s decision.
3. The right to consent to disclosures of personally identifiable information contained in your education records. FERPA requires that the College obtain your written consent prior to the disclosure of any such information with certain exceptions. College officials with a legitimate educational interest are an exception and do not need your consent. For a complete list of the disclosures that may be made without your consent, see 34 CFR Part 99.31 – 99.39.  Exceptions to disclosures include, but are not limited to:

• Organizations conducting studies;
• Health/safety emergencies;
• Under the U.S. Patriot Act;
• Federal, state and local authorities;
• Accrediting organizations;
• State, local or tribal welfare agencies;
• College officials with legitimate educational interest;
• In response to subpoenas and court orders; and
• In response to a lawsuit where a student names the College as a party.

      4. A College official includes any of the following when that person has a legitimate educational interest in having access to the information:

A College official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibility. The Vice President of Academic Affairs and Workforce Development has final authority on determining legitimate educational interest. Legitimate educational interest does not constitute authority to disclose information to a third party without the students written consent and does not convey inherent rights to any and all student information.

a. Any administrator, instructor, certified staff member, or support staff member (including health, medical, safety, and security staff) employed by the College;

b. A member of the College’s Board of Trustees;

c. A contractor, consultant, volunteer, or other party to whom the College has outsourced services or functions, such as, but not limited to: an attorney, auditor, cloud storage provider, consultant, expert witness, hearing officer, law enforcement unit, investigator, insurer/insurance company adjuster, investigator, or any other claims representative, medical providers or consultants, or counselors/therapists, provided that the person is performing a service or function for which the College would otherwise use employees, is under the direct control of the school district with respect to the use and maintenance of education records, and is subject to FERPA requirements governing the use and re-disclosure of personally identifiable information from education records; and

d. A person serving on a committee appointed by the College, such as a disciplinary or grievance committee or other review committee.

5. The College may release Directory Information about you unless you have advised the College to the contrary. The College has designated the following information as Directory Information: Student’s name, address, telephone listing, email address, birth date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, grade level, enrollment status (e.g., undergraduate or graduate, full or part-time), degrees and awards received, and the most recent previous educational agency or institution attended.

6. The College shall only release Directory Information to individuals and organizations that demonstrate, in the College’s opinion, a legitimate, educational interest in the information or provide a direct service to the College; provided, however, the College shall release Directory Information to military recruiters in compliance with the Solomon Amendment unless you specifically restrict the release of your Directory Information.

  7. If you do not want the College to disclose your Directory Information described above from your education records to the recipients identified above without your prior written consent, you must submit the request to the Director of Records and Registration by the third week of the semester.

  8. In compliance with Title IX, the College may disclose the final results of campus disciplinary proceedings in which a student respondent is charged with a violent crime or non-forcible sex offense. Upon the request of the complainant, disclosure may be made regardless of whether the respondent was found responsible. Disclosures to third parties may be made only if the student respondent is found responsible. Disclosure in this situation is limited to the name of the violator, the type of student code violation found to have occurred, and the sanction imposed by the College.

9.You have the right to file a complaint with the U.S. Department of Education concerning alleged failures of the College to comply with the requirements of FERPA.  The name and address of the office that administers FERPA is the:

Family Policy Compliance Office

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC  20202-5901

Questions regarding student records should be directed to Student Services.

Confidentiality

Each area of the campus that handles student records shall establish internal procedures to protect the security and confidentiality of student information, including hard copy and digital formats.  The following guidelines must be followed when accessing confidential information and student records.

Hard Copy Data

• Student information with social security numbers and birth dates shall not to be placed on hard copy file folder labels (use student ID instead).
• Student information with social security numbers and birth dates should not be left unsecured at any time.
• File folders (hard copies) containing student information with social security numbers and birth dates must be kept in a locked drawer or a locked room with access only by appropriate personnel.
• Any documents containing student information that is confidential should be shredded before discarding.
• Interoffice mail containing sensitive student information shall be sent using a sealed, opaque envelope.
• Sensitive information shall be mailed First Class or using other traceable delivery service and using an opaque envelope with no markings that will distinguish it as sensitive information.

Electronic Data

• Electronic data shall be maintained by ITS and shall be backed up to a separate location daily. The only exception to this is that Distance Learning student course records are housed off-campus through Remote-Learner. These records do not contain student SSN and are also backed up daily by Remote-Learner.
• Electronic student and confidential information is only accessible to appropriate personnel in accordance with procedures approved by ITS.
• Access to information systems is only given to appropriate personnel upon permission by a staff member’s supervisor. Permission records will be maintained by ITS.
• Personnel who have been granted authority to access student information will be issued an ID and password by ITS to access information systems.
• Personnel are only to use their designated ID and password to access student and confidential information. Under no circumstances should an ID and password be shared or should a staff member access College information systems under an ID and password that has not been issued to him or her.
• Student information with social security numbers and birth dates is not to be distributed or transmitted through email or otherwise made accessible to users without clearance to see this information.
• The student ID generated by the College’s operating system will be used in place of the social security number for identification purposes and in all communications.
• ITS reserves the right to revoke all privileges to information systems if College Information Technology policies and procedures are not followed.
• Faxing of sensitive student information shall be done by first verifying the fax number. Once the number has been verified the intended recipient must be readily available to retrieve the information.

Student Communications

• Students are required to create a unique password upon setting up their accounts in the College’s information systems.
• Electronic communication with an active student should only be sent to that student's College email address. Communication with prospective students or past students may be sent to the student's personal email, but should not include any sensitive information (e.g., student grades).
• When communicating with students regarding technical support, registration, transcripts, financial aid and financial information, students should not be asked for a social security number or birth date in public/within hearing distance of other people.
• Two forms of authentication must be requested when verbally verifying student identification. Appropriate forms of authentication are the student Colleague ID number, the last four digits of the social security number, and birth date. Under no circumstances should a student be requested to verify their social security number through email.

Security Breach

• Any security breach or loss of records should be reported to one's immediate supervisor immediately upon discovery of the breach/records loss.
• Any student that has had their sensitive information compromised shall be contacted within 24 hours via telephone. In the event that the student cannot be reached, the College will use the emergency contacts to try to establish communications with the student. After the College has exhausted these resources the next form of contact will be First Class mail or other traceable delivery service in accordance with N.C.G.S. § 75-65.
• While sensitive student information is in transport to the College, the information shall remain locked in the trunk or other secure area of the vehicle. If the vehicle does not have a secure location, the sensitive student information must not be transported until the information can be transported securely unless it will be transported with no stops that will require the vehicle to be left unattended.
• Any student information that is collected off-campus or after campus hours shall remain in the custody of the student, agency or business until the sensitive student information can be delivered to the College.
• With the exception of coursework to be graded, no College employee will have hard copies of sensitive student information in their possession overnight without prior approval from that employee's supervisor or the college president. Any digital records removed from campus should be encrypted and password protected.

Release of Student Educational Records

The following “Directory Information” may be made available to the public by the College without students’ written permission unless students notify Records and Registration in writing by the third week of the semester that such information concerning themselves is not to be made available.

• Student’s name, address, telephone listing, email address, birth date and place of birth.
• Major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams.
• Dates of attendance, grade level, enrollment status (e.g., undergraduate or graduate, full or part-time), degrees and awards received, and the most recent previous educational agency or institution attended.

Faculty and administrative officers of the College who demonstrate a legitimate educational need will be permitted to look at the official student file for a particular student. Requests for confidential information shall not be honored without proper written consent for the release of such records by students. The written consent must specify the records or the specific data to be released and to whom it is to be released, and each request must be handled separately. Exceptions to this policy are the following:

• Requests for confidential information will be honored without prior consent of the student in connection with an emergency.
• Official requests in connection with the audit and evaluation of federal or state supported programs or in connection with enforcement of federal or legal requirements which relate to such programs.
• A lawfully issued subpoena or court order instructing the College not to disclose the existence or contents of the subpoena or the College’s response.
• All other subpoenas. (Students will be notified immediately by registered mail that their records have been subpoenaed.)
• An Ex Parte Order from the Attorney General of the United States in connection with the investigation or prosecution of terrorism crimes as specified in the U.S. Code.
• Non-directory information required by the Immigration and Naturalization Service about International Students.
• Persons or organizations providing financial aid to the student or determining financial aid decisions.

Control of Student Records

Transcripts and other information are released only with the written permission of the student. Students have the right to inspect their own records. Upon inspection students are entitled to an explanation of any information contained in their records. Students have the right to copies of academic records of credits earned at Western Piedmont Community College. Copies of transcripts and/or other information from institutions other than WPCC must be requested from the originating institution.

An official student file shall not be sent outside the Counseling Office, Records Office, Financial Aid Office, Veterans Affairs Office, Advising Office or other custodial offices except in circumstances specifically authorized by the Dean of Student Services. The authorization for such special circumstances must be in writing. College officials responsible for the maintenance of education records include the Director of Records and Registration and Dean of Student Services.

A student who believes that information contained in records is inaccurate or misleading may request that the record(s) be amended. The procedure for challenging any contested information is described in the College Policy Manual (Policy 05.03.060 – Student Grievance)

Records Retention

Decisions about retention and disposition of all public records at Western Piedmont Community College will follow the Records Retention & Disposition Schedule as published by the Division of Archives and Records of the North Carolina Department of Natural and Cultural Resources and the North Carolina Community College System.