Office of Procedures, Records, and Forms Business Policies and Procedures Manual

RECORDS
90.06
Revised 6-10

For more information contact:
   Registrar’s Office
   509-335-5346

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Release of Student Education Records

Overview

University personnel are responsible for disclosing and withholding disclosure of student education records in accordance with the following University guidelines. (These guidelines are based upon WAC 504-21 and WAC 504-45.)

Student Records Officer

The University Registrar located at WSU Pullman is the Student Records Officer designated by the President. Questions regarding the disclosure of student records should be directed to the Student Records Officer. At a regional campus disclosure questions should be directed first to the Registrar at that campus. The campus Registrar may refer such questions to the Student Records Officer.

The Student Records Officer is responsible for reviewing unusual requests for information and for assisting in the interpretation of these rules. The Student Records Officer is also responsible for receiving and/or hearing appeals as defined in WAC 504-21-040.

A departmental administrator should seek assistance from the Student Records Officer when the administrator is unsure whether or not a given record should be released.

Education Records

Student education records include any file, document, or other material which provides information directly related to a student. A student is any person who has ever been in attendance (officially enrolled as of the first day of classes) at the University and with respect to whom the University maintains education records or personally-identifiable information.

Not Educational Records

The following are not considered student education records:

  • Records of the WSU police department that are created and maintained by the WSU police department for the purposes of law enforcement.
  • Records which relate to the student’s capacity as an employee. The personnel records review rules apply (see BPPM 90.07).
  • Records made by instructional, supervisory and administrative personnel, which are not accessible to any other person except the maker’s substitute or administrator.
  • Student medical records created or maintained by a WSU physician, psychiatrist, psychologist, or other recognized professional or paraprofessional acting or assisting in that capacity that are created, maintained, or used only in connection with the provision of treatment to the student, and are not available to anyone other than persons providing such treatment. Such records can be personally reviewed by a physician or other appropriate professional of the student’s choice. In addition, health care information may be disclosed if authorized by state law.
Financial Records

Financial records are considered to be a type of student education record. All provisions regarding student education records apply to student financial records held by the University.

Releasing Records

Student Access

A student may review his or her education records. The department having custody of the information must provide a response to a student’s request within a reasonable time, but in no case more than 45 days after a request. (WAC 504-21-040)

Where records or data include information on more than one student, the requesting student may view only his or her part of the record.

Students may obtain copies of their official WSU academic records from the campus registrar.

Recommendations, Evaluations, and Comments

Students may review and receive copies of recommendations, evaluations, and comments concerning themselves if these statements are provided in privacy, expressed or implied, on or after January 1, 1975.

Statements made before January 1, 1975 may be reviewed by the student only with the consent of the author.

Waiver of Right to Review

Students may waive the right to review information about themselves including confidential recommendations associated with:

  • Admission to any educational institution.
  • Applications for employment.
  • Documents filed and maintained at the student’s request at Career Services.
  • Faculty evaluation and other education records placed in departmental files when the department serves in a placement or referral capacity.

Conditions for Waiver
A student’s waiver of rights applies only if all of the following apply.

  • The student can obtain the names of all persons making confidential statements concerning him or her.
  • The confidential statements are used solely for the purpose for which they were originally intended.
  • The waivers are not required as a condition for admission, receipt of financial aid or receipt of any other services or benefits from the University.
Access by WSU Personnel

The following University personnel may access personally-identifiable student records without the written consent of the student:

  • Any WSU employee with a “need to know” based upon official University duties or concerns.
  • Faculty and students appointed to a President’s standing committee, a Faculty Senate committee, or any other WSU committee with a “need to know” based upon official University duties or concerns.

Use of student records is such cases is strictly limited to the performance of official University responsibilities. (WAC 504-21-050(a))

Employee access to secured online student education records requires approval by appropriate administrators and completion of privacy training (see BPPM 85.33).

Academic Researchers

Education records may be used for legitimate academic research; provided that:

  • The procedures utilized and the reported findings do not violate the student’s confidence.
  • Students’ names are not be included in the study or in any way linked with the data.
  • Case histories and case records are sufficiently disguised to prevent identification of the individuals involved.
  • The student’s written permission is obtained where individual identification occurs.
  • Researchers comply with the policies and procedures included in BPPM 45.50 regarding human subjects.
Access by Non-WSU Personnel
Student’s Consent

Generally, non-University personnel must have the student’s written consent in order to access personally-identifiable student information. Students may release personally-identifiable information about themselves with a written, signed, and dated consent statement. A valid written consent statement may be generated and approved electronically through an official University online application. The consent statement is to include:

  • Specifications of the information to be released.
  • The reasons for the release.
  • Identification of the parties to whom the information will be released. Exception: Career Services forwards applications and related information to prospective employers in response to employment openings based on a general signed release by the student that covers these types of releases.
Without Consent

The University permits access or release of personally-identifiable information to the following parties without the consent of the student:

  • Appropriate persons in connection with an emergency may access information if the knowledge of such information is necessary to protect the health or safety of a student or other person(s).
  • Parents or legal guardians of a student who have established the student’s dependency status according to Internal Revenue Code of 1954, Section 152, may access information about that student’s educational and financial status.
  • Federal and state officials for audits or evaluations of federally- or state-funded programs or enforcement of the federal or state legal requirements which relate to these programs may access related information about students.
  • Persons or organizations providing financial aid or making decisions relating to providing financial aid may have access to information about students associated with the individual programs.
  • Any person or entity designated by a lawfully issued subpoena or judicial order may access related student records. Contact the Attorney General’s Office regarding this type of request; telephone 335-2636.
  • Accrediting organizations carrying out accrediting functions may access student records.
Directory Information

The University may release directory information contained in a student’s education records. “Directory Information” refers to information contained in an education record that would not generally be considered harmful or an invasion of privacy if disclosed.

Directory information includes the following: name (including any former name), local and permanent addresses, telephone numbers, e-mail addresses, major and minor fields of study, participation in officially recognized sports, weight and height of members of athletic teams, dates of attendance, enrollment status (e.g., undergraduate, graduate; full-time or part-time), grade level, status as graduate assistant and assignment, degrees, certificates, and awards received (including the President’s Honor Roll), and the most recent previous educational institution attended by the student.

Directory Restriction

Students may request that the University not release directory information by indicating “restrict address” on the online MyWSU Portal’s address update screen (see BPPM 90.70), or by filing a written request with Payroll Services by the second Friday of the academic semester.

NOTE: If a student files a directory restriction, his or her name, address, telephone number, and e-mail address are not published in the online campus directory. In addition, the University does not release the student’s name in any University press releases, including President’s Honor Roll notification to hometown newspapers.

For more information regarding directory restrictions, contact the Registrar’s Office, French Administration Building, Room 346.

Appeals

To appeal the denial of a request to review his or her student records, a student submits an appeal to the appropriate dean or director, and subsequently to the Student Records Officer using the procedures in WAC 504-21-040.