Directory information 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.
JHU has established the following as directory information:
- Name of a student who is in attendance or who has been in attendance
- Name pronunciation
- Local address of a present or former student
- Hopkins e-mail address of a present or former student
- Local telephone number of a present or former student
- Major field of study of a present or former student
- Participation in Johns Hopkins Athletics (limited to hometown, sport, height, and/or weight)
- Dates of attendance
- Degrees and awards received, and pertinent dates
- Photograph (still, video, audio)
- Classification (enrollment status), and level of study
As defined by FERPA, education records are records that (1) are directly related to a student who is or has been in attendance at an educational agency or institution; and (2) are maintained by an educational agency or institution or by a party acting for the educational agency or institution. This encompasses information or data recorded in any medium, including, but not limited to, handwriting, print, computer media, video or audio tape, film, microfilm, and microfiche.
Examples of education records include transcripts; class schedules; course work including papers, exams, grades, and evaluations; disciplinary records; internship program records; and student financial records. Records relating to an individual in attendance who is employed as a result of their status as a student are also considered education records under the terms of FERPA.
Education records are not:
- records that are kept in the sole possession of the maker, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record;
- records of the law enforcement unit of an educational agency or institution;
- records relating to an individual who is employed by an educational agency or institution that are made and maintained in the normal course of business, relate exclusively to the individual in that individual’s capacity as an employee, and are not available for use for any other purpose;
- records made or maintained by a physician, psychiatrist, psychologist, or other recognized professional or paraprofessional acting in their professional capacity or assisting in a paraprofessional capacity that are made, maintained, or used only in connection with treatment of the student and disclosed only to individuals providing the treatment (although the student may have those records reviewed by a physician or other appropriate professional of the student’s choice);
- records created or received by an educational agency or institution after an individual is no longer a student in attendance and that are not directly related to the individual’s attendance as a student; and
- grades on peer-graded papers before they are collected and recorded by an instructor.
Eligible Students In Attendance
Under the terms of FERPA, “eligible students” are those who have reached 18 years of age or are attending an institution of postsecondary education; and “attendance” includes, but is not limited to, attendance in person or by paper correspondence, videoconference, satellite, Internet, or other electronic information and telecommunications technologies for students who are not physically present in the classroom; and the period during which a person is working under a work-study program.
For FERPA compliance purposes, Johns Hopkins University defines a student as an individual who is or has been in attendance at the University and for whom the University maintains education records. This definition includes early matriculants (fall semester admits attending summer term), former students, individuals who are taking classes for academic credit but have not been admitted to a degree or certificate program, visiting students, and alumni. This definition does not include prospective students, applicants who have been admitted but did not attend, applicants who have been denied admission, and individuals participating in lifelong learning/continuing education programs not taken for academic credit available through one of JHU’s academic divisions. Parents of individuals under the age of 18 in attendance at a university program that does not offer a postsecondary degree or certificate shall retain FERPA rights for the participant.
For FERPA compliance purposes, Johns Hopkins University considers students to be in attendance on the first day of the first term in which the student is enrolled for academic credit in one or more classes as part of degree or non-degree offerings under any instructional delivery method/modality.
Legitimate Educational Interest
A legitimate educational interest is any action or interest affecting the academic and administrative situation of a student who is the subject of the education record; and any action or interest relating to the planning, execution, and evaluation of academic and administrative programs of the University and organizations and institutions with which the University is affiliated, or which are utilized by the University.
Personally Identifiable Information
Under FERPA, personally-identifiable information includes, but is not limited to, the following:
- the student’s name;
- the name of the student’s parent or other family members;
- the address of the student or student’s family;
- a personal identifier, such as the student’s social security number, student number, or biometric record;
- other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name;
- other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; and
- information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
University and School Officials
University and school officials are administrators and staff members of the University; persons serving on the Johns Hopkins University Board of Trustees; students serving on official committees such as disciplinary or grievance committees; and contractors, consultants, volunteers or other parties to whom JHU has outsourced institutional services or functions, provided that the outside party is under the direct control of the University with respect to the use and maintenance of education records and performs an institutional service or function for which the University would otherwise use employees.