FERPA Compliance

Overview

In compliance with FERPA, Johns Hopkins University (JHU) permits students to inspect and review their education records to the extent permitted by applicable law and regulations, with the following exceptions:

• Persons will not be permitted to inspect and review their education records maintained by a school or division in which they have not been in attendance.
• If the education records of a student contain information on more than one student, the student may inspect and review or be informed of only the specific information about that student.
• Students will not be permitted to inspect financial records or statements of parents.
• Students will not be permitted to inspect confidential letters and statements of recommendation which were placed in the education records of the student prior to January 1, 1975, provided that they were solicited with a written assurance of confidentiality or sent and retained with a documented understanding of confidentiality; and were used only for the purposes for which they were specifically intended.
• Students will not be permitted to inspect confidential letters and statements of recommendation which were placed in the education records of the student after January 1, 1975, respecting admission to an educational institution; respecting an application for employment; or respecting the receipt of an honor or honorary recognition, provided that the student has waived the right to inspect and review those letters and statements of recommendation.
• JHU will not disclose documents which do not come within the statutory and regulatory definition of the term “education records.”

Procedures: Inspecting and Reviewing Education Records

Students wishing to inspect and review their education records must submit a Request to Inspect and Review Education Records form.

JHU will comply with requests for access to records in a timely manner and no later than 45 days from the date of receipt of the official request. Copies of transcripts may be secured with payment of any applicable fee.

Overview

In compliance with FERPA, JHU will provide students who believe that the information contained in their education records is inaccurate, misleading, or in violation of their privacy rights with an opportunity to seek correction of the records.

Procedures: Requesting Amendment of Education Records

Students seeking to amend their education records must submit a Request to Amend Education Records form, which must clearly identify the part of the record the student seeks to amend and provide a rationale for their request.

If a student’s request is denied, the student will be informed of the decision and of their right to a hearing. Students seeking a hearing must submit a Request for a Hearing Under FERPA form.

The appropriate dean/designee will hold a hearing within 14 days of the receipt of the official request. JHU will provide the student with reasonable advance notice of the date, time, and place of the hearing, which will be closed to all except the University’s representative(s), the student, the student’s representative or attorney, and witnesses. During the hearing, the student will be afforded a full and fair opportunity to present evidence relevant to the issue of whether the information is inaccurate, misleading or in violation of their privacy rights. Upon the conclusion of the hearing, the student will be informed in writing of the dean/designee’s decision within a reasonable period of time after the hearing. The decision must be based solely on the evidence presented at the hearing, and must include a summary of the evidence and the reasons for the decision.

If, as a result of the hearing, the dean/designee decides that the information is inaccurate, misleading, or otherwise in violation of the student’s privacy rights, the record will be amended accordingly and the student will be informed of the amendment in writing. If the dean/designee decides that the information is not inaccurate, misleading, or otherwise in violation of the privacy rights of the student, the student may place in the education record a statement commenting upon the information and/or any reason for disagreeing with the dean/designee’s decision.

Overview

In compliance with FERPA, JHU may not disclose personally identifiable information from the education records of a student without the prior written consent of the student, except in the following circumstances:

• to university and school officials who have legitimate educational interests;
• if the disclosure is information the University has designated as directory information;
• to a contractor, consultant, volunteer, or other party to whom the University has outsourced institutional services or functions and is considered a university or school official performing an institutional service or function for which the University would otherwise use employees and is under the direct control of the university with respect to use and maintenance of education records;
• to officials of another educational institution in which the student seeks or intends to enroll, or where the student is already enrolled so long as the disclosure is for purposes related to the student’s enrollment or transfer (copies of the disclosed records will be made available to the student upon request);
• to authorized representatives of the U.S. comptroller general, the secretary of the U.S. Department of Education, the attorney general of the United States, or state and local educational authorities;
• to organizations conducting studies for, or on behalf of, the University for the purpose of developing, validating, or administering predictive tests, administering student aid programs, and improving instruction;
• to accrediting organizations to carry out their accrediting functions;
• to parents of a dependent student, as defined in section 152 of the Internal Revenue Code of 1986;
• to parents of a student under the age of 21 the student’s violation of any federal, state or local law, or of any rule or policy of the University governing the use or possession of alcohol or a controlled substance, where the University determines that the student has committed a disciplinary violation;
• to comply with a judicial order or lawfully issued subpoena, with the condition that the University makes a reasonable effort to notify the student of the order or subpoena in advance of compliance so that the student may seek protective action, if applicable;
• in a health or safety emergency if knowledge of the information is necessary to protect the health or safety of the student or other individuals;
• in connection with a disciplinary proceeding at an institution of postsecondary education; and
• in connection with financial aid for which a student has applied or which a student has received.

The University may also disclose:

• to the victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense, the final results of the disciplinary proceeding conducted by the University with respect to that crime or offense; and
• the final results of a disciplinary proceeding, where the University determines as a result of that disciplinary proceeding that a student alleged to be a perpetrator of a crime of violence or a nonforcible sex offense has committed a violation of University rules or policies with respect to the allegation made against the student. Disclosure of final results may include name of the student who is the alleged perpetrator, any violation committed and any sanction imposed (including description of disciplinary action, date imposed and the sanction’s duration).

FERPA imposes limitations on the redisclosure of personally-identifying information from student education records. JHU may disclose personally identifiable information from an education record only on the condition that the party to whom the information is disclosed will not disclose the information to any other party without the prior consent of the eligible student, and that information disclosed from student records may be used only for the purposes for which the disclosure was made.

Directory Information

Directory information is information contained in the education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. Under the terms of FERPA, universities are permitted to establish directory information that may be released upon request without the student’s consent at the discretion of the institution, provided that the student has not restricted such information from disclosure.

Procedures: Restricting Release of Directory Information

Students who wish to restrict the release of any or all of their directory information must submit a Request to Prevent Disclosure of Directory Information form.

Please note: JHU will be unable to release restricted directory information to outside entities such as prospective employers, insurance agencies, parents, relatives, the news media, and honor societies.

Procedures: Authorizing Release of Information

In compliance with FERPA, JHU must obtain written consent before disclosing non-directory information from a student’s education record. Non-directory information includes, but is not limited to, grades, disciplinary records, tuition and fees assessments, admission records, and financial aid. Students who wish to authorize JHU to release non-directory information from their education record must submit a Student Information Release Authorization form. Students must submit a separate form for each third party to whom they grant access to their education record. Students must also identify the specific information that should be released. The specific information to be released will be made available only if requested by the authorized third party.

JHU has determined that requests from parents of dependent students (as defined in section 152 of the Internal Revenue Code of 1986) should be accompanied by a written letter of permission from the student whose record is requested, unless JHU releases records to parents without consent of the student pursuant to the exclusions established by FERPA.

Students may elect to include an expiration date on the authorization form, or they may revoke the authorization at any time by submitting a Request to Revoke Release Authorization form. Completed authorization release forms will be in effect indefinitely if the student does not elect an expiration date or submit a Request to Revoke Release Authorization form.

JHU discloses personally identifiable information from students’ education records only on the condition that the party to whom the information is disclosed will not disclose the information to any other party without the prior consent of the student. Any party to whom student education record information is disclosed may use the information only for the purposes for which the disclosure was made.

Overview

Under the terms of FERPA, students have the right to file complaints concerning alleged violations of FERPA regulations with the U.S. Department of Education.

Procedures: Filing Complaints

Complaints concerning alleged violations of FERPA regulations should be addressed to the U.S. Department of Education at the following address:

U.S. Department of Education
Student Privacy Policy Office
400 Maryland Avenue, SW.
Washington, DC 20202-8520

Complaints must be made within 180 days of the alleged violation or the date that the student knew or reasonably should have known of the alleged violation, and contain specific allegations giving reasonable cause to believe that a violation occurred.