5.2.1 Students’ Rights of Privacy and Access to Records
5.2.1.a Annual Notification of Rights under FERPA
Annually, the Seminary informs students of their rights under the Family Educational Rights and Privacy Act of 1974 (FERPA), as amended, in the following ways: publishing the annual notification in the Seminary’s catalog and on the Registrar’s Office webpage, and announcement from Registrar’s Office via email during the Fall registration period. The annual notification is:
The Family Educational Rights and Privacy Act (FERPA) affords students certain rights with respect to their education records. These rights include:
- The right to inspect and review the student's education records within 45 days of the day the Seminary receives a request for access.
A student should submit to the Registrar’s Office a written request that identifies the record(s) the student wishes to inspect. The Registrar’s Office will make arrangements for access and notify the student of the time and place where the records may be inspected.
- The right to request the amendment of the student’s education records that the student believes are inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.
A student who wishes to ask the Seminary to amend a record should write the Registrar’s Office, clearly identify the part of the record the student wants changed, and specify why it should be changed.
If the Seminary decides not to amend the record as requested, the Seminary will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
- The right to provide written consent before the Seminary discloses personally identifiable information from the student's education records, except to the extent that FERPA authorizes disclosure without consent (Ref: 34 CFR §99.31).
The Seminary discloses education records without a student’s prior written consent under the FERPA exception for disclosure to school officials with legitimate educational interests. A school official is a person employed by the Seminary in an administrative, supervisory, academic or research, or support staff position; a person or company with whom the Seminary has contracted as its agent to provide a service instead of using Seminary employees or officials (such as an attorney, auditor, or collection agent); a person serving on the Board of Trustees; or a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another school official in performing his or her tasks.
A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibilities for the Seminary.
Upon request, the Seminary also discloses education records without consent to officials of another school in which a student seeks or intends to enroll.
- The right to file a complaint with the U.S. Department of Education concerning alleged failures by the Seminary to comply with the requirements of FERPA. The name and address of the Office that administers FERPA is:
Family Policy Compliance Office
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202-5901
5.2.1.b Directory Information
FERPA defines Directory Information as “[i]nformation contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed”. The Seminary designates the following as Directory Information, which it may disclose at its discretion: student’s name, spouse’s name, address(es), telephone listing(s), Westminster-assigned student email address, personal email address(es), photograph, program and year of study, enrollment status (e.g. full-time, part-time), dates of attendance, degree(s) awarded, most recent school attended, citizenship, and home town. It is Seminary practice to include the following Directory Information in the Student Directory and Handbook (SDH): Student’s name, program of study, spouse’s name, Westminster-assigned student email address, photograph, address, phone number, and home town.
5.2.1.c Withholding Directory Information
Students may withhold free disclosure of Directory Information (on an “all or nothing” basis) to non-institutional persons or organizations. To do this, the student must complete a Request to Withhold Directory Information form to the Registrar’s Office. A photo ID may also be required. Though a request may be submitted to the Registrar's Office at any time, it must be received by the first week of Fall semester classes in order for the student's Directory Information to be withheld from the SDH. The request will be honored until revoked by the student in writing.1
Effect of withholding Directory Information: If a student elects to withhold Directory Information, none of that student’s information, including name and photograph, will appear in the SDH. That student must make all address changes with a signed authorization or in person with an appropriate form of photo ID. In addition, no information for that student will be released such that a third party (e.g. loan company, prospective employer, church official, family member, etc.), will be informed that the Seminary has no record of the student’s attendance, unless the student submits to the Registrar’s Office a written authorization to release information to the designated third party.
5.2.1.d Release of Academic Records
In addition to the student’s rights under FERPA (see above), a student may authorize, by submitting a written request to the Registrar’s Office, release of academic information to a designated third party in the form of an Official Letter. Written authorization must include the specific information for release. The Registrar’s Office may require that the student submit instead an Official Transcript Request for release to the third party.
5.2.1.e Limits to Academic Records Access
The Seminary is not required to permit students to inspect confidential letters and recommendations received prior to January, 1, 1975, financial information submitted by parents, or records containing information about another student, unless all reference to the other student is redacted. If a student has signed a waiver, information from a recommendation is not available to him or her. Application materials, once submitted, become the property of the Seminary. Under no circumstances will a student be permitted to copy, photograph, or have returned any part of his or her academic records, including submitted application materials, recommendations and transcripts.
5.2.1.f Solomon Amendment
The Seminary, which receives federal funding via the Federal Direct Student Loan Program, is required under the Solomon Amendment to provide “student recruiting information” to military recruiters from the twelve eligible units within the four branches of the Military Service. “Student recruiting information” consists of: student’s name, address, telephone listing, age or year of birth, place of birth, level of education or degrees received, academic major, and the most recent previous educational institution attended. “Student recruiting information” will be withheld only for those students who have submitted a signed Request to Withhold Directory Information form that is still current (i.e. not revoked by the student).