Policy: Ohio Northern University recognizes its responsibility to protect students and former students against improper disclosure of information. The University will comply with all applicable state and federal laws, including the Family Educational Rights and Privacy Act of 1974 (FERPA), that relate to retention and disclosure of information about students and former students.
Definitions: A student is an individual who is or who has been in attendance at Ohio Northern University. Attendance includes attendance in person or by correspondence and any period during which an individual is working for the University under a work-study program. Education records are all records, files, documents and or materials, maintained in any medium, that contain information directly related to a student and are maintained by University faculty, staff and/or its agents.
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Education records maintained by the University include:
- Academic records
- Financial records
- Computer and network use records
- Disciplinary records
- Employment records of students
- Security records
Education records do not include following:
- Personal notes made by professors, teachers, staff or agents, solely for his or her use that are not shared with anyone
- Records created and maintained by the University Security Office for purposes of compliance with Clery Act
- Employment records of a student whose employment is not contingent on fact that he or she is a student
- Alumni records containing information about a student after he or she is no longer in attendance at the University and which do not relate to person as a student
- Medical and counseling records
A school official is a person employed by the University in an administrative, supervisory, academic, research, or support staff position (including University Security personnel and health and counseling staff); a person or company with whom the University has contracted (such as an attorney, auditor, financial aid processing agent, or collection agent); a person serving on the Board of Trustees; or a student serving on an official committee, such as a disciplinary board or a grievance committee, or assisting a 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 responsibility for the University. Personally identifiable information is any information which can be used, by itself or in combination with other information, to identify an individual. Examples include name, address, telephone number, social security number, student identification number, photos, or fingerprints.
Ohio Northern University will not disclose personally identifiable information contained in a student’s education records without prior written consent, except as authorized by applicable state or federal law. Educational records, with exception of those social disciplinary records involving misconduct under ONU’s Student Code of Conduct, will not be disclosed to parent of a student without that student’s consent. Social disciplinary records may be disclosed to parents claiming a student as a dependent for tax purposes. Educational records will also be disclosed to persons who have legitimate power of attorney for a student.
In addition to the directory information, the University will disclose personally identifiable information contained in a student’s education records without prior written consent to:
- School officials with a legitimate educational interest
- Authorized agents of state or federal government in connection with an audit or evaluation of federally or state supported programs
- Authorized agents in connection with financial aid for which student has applied or which student has received
- Accrediting organizations in order to carry out their accrediting functions
- To comply with a lawfully issued court order or subpoena (the University will make reasonable efforts to notify student prior to compliance with subpoena)
- To appropriate persons in relation to a health and safety emergency, as specifically determined by the University, in accordance with FERPA
- To an alleged victim, final results of any disciplinary proceeding conducted by the University, where behavior alleged constituted a crime of violence, or a non-forcible sexual offense. disclosure will be made regardless of where alleged perpetrator was found to have violated any University policy with respect to alleged crime or offense
- To third parties, final results of any disciplinary proceeding conducted by University, where behavior alleged constituted a crime of violence, or a non forcible sexual offense, only when alleged perpetrator has been found to have violated any University policy with respect to alleged crime or offense. No victim or witness names will be disclosed without their prior written consent
- To comply with a court order obtained under the USA PATRIOT Act for education records considered relevant to a terrorism investigation or prosecution, without advance notice to student
- To disclose to a student’s parent information regarding any violation of law or of University rule or policy as to alcohol or drug use or possession, if the student is under age 21 at time of disclosure and the University determines that such alcohol/drug use or possession constitutes a disciplinary violation
- To disclose information provided to the University under Section 170101 of the Violent Crime Control and Law Enforcement Act of 1994 (42 U.S.C. 14071) concerning registered sex offenders who are required to register under that section
- To U.S. Citizenship and Immigration Services (USCIS) / Department of Homeland Security (DHS) concerning an F, J, or M nonimmigrant alien, only to extent necessary for the University to comply with Student and Exchange Visitor Program (SEVP) reporting requirements, as mandated by Illegal Immigration Reform and Immigrant Responsibility Act of 1996, USA
- PATRIOT Act, Enhanced Border Security and Visa Entry Reform Act of 2002, and regulation at 8 CFR 214.1(h). Consent is not necessary for University to disclose required information to USCIS or DHS in compliance with SEVP reporting obligations
- To National Student Clearinghouse to function as the University’s agent in matters including but not limited to:
- FELP loan deferment
- reporting enrollment to NSLDS and/or related enrollment and degree verification services.
Directory information will be disclosed by the University without prior written consent. Students may direct the University not to disclose their directory information by notifying The Office of Registrar in writing, within two weeks of first day of fall term. Requests to withhold directory information will remain in effect until rescinded in writing by the student. At Ohio Northern University, directory information includes following:
- Student name
- Home and local address and telephone numbers
- Major fields of study and college of enrollment
- Degrees, honors, awards, and dates received
- Class (year of study)
- Dates of attendance
- Most recent institution previously attended
- Previous degrees earned and granting institutions
- Participation in officially recognized activities and sports
- Height and weight of members of athletic teams
- Enrollment status (enrolled, withdrawn, full- or part-time)
- Name and address of parent(s)
- Student email address
- Student picture
Records of Disclosures
University shall maintain within student’s education records a record for each disclosure request and each disclosure, except for following:
- Disclosures to student
- Disclosures pursuant to student’s written consent
- Disclosures to school officials with a legitimate educational interest
- Disclosures to comply with a court order obtained under USA PATRIOT Act
- Directory information
Destruction of Records
Nothing in this policy requires continued maintenance of any student record for any particular length of time. If, under terms of this policy, an individual has requested access to a student’s education record, that record will not be destroyed before custodian has determined where and to what extent access is permitted.
Students’ Rights with Respect to Education Records
A student has right, upon written request, to review materials that are contained in student’s education records, except:
- Financial information submitted by student’s parents
- Confidential letters and recommendations associated with admission, to which the student has waived his/her right to inspection and review
- Employment or job placement records
- Honors information, to which the student has waived his/her right to inspection and review
- Education records containing information about more than one student, in which case the University will only permit access to that part of the record pertaining to the inquiring student.
Students wishing to review their records must make a written request to The Office of Registrar specifying which records they wish to review. The Registrar will make education records available within forty-five (45) days of receipt of request. Unless the student has an outstanding financial indebtedness to the University, copies of student education records can be made at student’s expense at prevailing institutional rates.
Students who believe their education records contain information that is inaccurate, misleading or otherwise in violation of their privacy or other rights may request an amendment of their records. Students wishing to amend their records should submit a request for the amendment in writing to The Office of Registrar. Requests should clearly identify what records the student wants to amend and the reasons supporting the amendment. Within a reasonable amount of time, the Registrar will notify students of the decision regarding their request. If the education record is not amended pursuant to student’s request, the Registrar will inform tthe student of their right to request a formal hearing.
A request for a formal hearing must be made in writing to the Vice President for Academic Affairs or the Vice President for Student Affairs, who, within a reasonable period will inform the student of the time, date and place of the hearing. A student may present relevant evidence to issues raised and may be assisted by any person of their choice. The panel for the hearing will consist of the Vice President for Academic Affairs, the Vice President for Student Affairs and the Academic Dean of student’s college. In the event that one of these individuals is the party alleged to be responsible for disputed contents of record, the President will appoint an alternate member to the panel. The panel shall base its decision only upon evidence presented at the hearing. Panel decisions are considered final and will consist of a written statement summarizing the evidence presented, findings of panel, and its decision. A written statement will be delivered to all parties concerned. If the decision is in favor of student, their education records will be amended according to the decision of panel. If the panel finds against the student, student has a right to place a statement commenting on information in their record and that the student disagrees with the panel. The statement will be maintained as part of student’s education records and be released whenever their record is disclosed.
Any student who believes that adjudication of their request for amendment was unfair or not in keeping with provisions of FERPA may make a written request for assistance of the President of the University. In addition, students who believe the university is not in compliance with FERPA may file a complaint with:
Family Policy Compliance Office
U.S. Department of Education
400 Maryland Avenue SW
Washington, DC 20202 5901
Possible Federal and State Data Collection and Use
As of January 3, 2012, the U.S. Department of Education's FERPA regulations expand the circumstances under which your education records and personally identifiable information (PII) contained in such records — including your Social Security Number, grades, or other private information — may be accessed without your consent. First, the U.S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or state and local education authorities ("Federal and State Authorities") may allow access to your records and PII without your consent to any third party designated by a Federal or State Authority to evaluate a federal- or state-supported education program. The evaluation may relate to any program that is "principally engaged in the provision of education," such as early childhood education and job training, as well as any program that is administered by an education agency or institution. Second, Federal and State Authorities may allow access to your education records and PII without your consent to researchers performing certain types of studies, in certain cases even when we object to or do not request such research. Federal and State Authorities must obtain certain use-restriction and data security promises from the entities that they authorize to receive your PII, but the Authorities need not maintain direct control over such entities. In addition, in connection with Statewide Longitudinal Data Systems, State Authorities may collect, compile, permanently retain, and share without your consent PII from your education records, and they may track your participation in education and other programs by linking such PII to other personal information about you that they obtain from other Federal or State data sources, including workforce development, unemployment insurance, child welfare, juvenile justice, military service, and migrant student records systems.