FERPA for Faculty and Staff

Manhattanville University's faculty and staff with access to student academic and/or personal records (electronic or paper-based) are responsible under the Family Educational Rights and Privacy Act ("FERPA") to protect the privacy of these records and use record information only for legitimate educational or student support purposes. Discussing or sharing a student's record with any person who does not have a "legitimate educational interest" (including, but not limited to: parents, guardians, spouses, and non-university employees) is a violation of FERPA.

FERPA covers all forms of record transmission, whether it be through verbal conversations, emails, electronic data, or printed media. FERPA affords students certain rights with respect to their educational record privacy. However, FERPA also respects the need for educational institutions to share student data across the enterprise to conduct their normal business operations. As long as the "need to know" has been established in relation to a student's educational record, faculty-to-faculty or faculty-to-staff communications regarding a student may occur freely.

Faculty and staff should respect the FERPA guidelines below when record sharing situations arise:

• DO NOT release a student's academic or non-directory personal information to parents, guardians or non-Manhattanville employees unless the student is present to provide permission for the release or the student has provided the university with a waiver to discuss their specific records with properly identified individual(s). Consult first with the Registrar's Office to find out if a student has a FERPA waiver on file.
• DO NOT release a student's class schedule or known whereabouts on campus to parents, guardians, or non-Manhattanville employees. This information is protected under FERPA. Check a student's FERPA waiver status first or refer inquiries to the Registrar or Advising area. EXCEPTION: In the event of an emergency that involves a student, a group of students, or the campus, you may cooperate with law enforcement, fire, medical, or other safety personnel. The Department of Education's Family Policy Compliance Office (FPCO) states that student record disclosures can be made if "there is an articulable and significant threat to the health or safety of the student or other individuals." See: FERPA Disaster Guidance Policy
• DO NOT post student grades or other academic information in any location, even if such lists contain only names without other personal identifiers (ID numbers, social security numbers, etc.). Student can access their final grades online on ServiceHub/Student Planning. Use Blackboard's Grade Center or Mville email to privately share other academic benchmarks and grades with individual students directly.
• DO NOT circulate a printed class list that displays student names and ID numbers for attendance or ask students to declare themselves present by writing their names and ID numbers on a blank sheet of paper. THIS IS A FERPA VIOLATION. Use ServiceHub to view the real-time status of students on your class roster(s). Then use Blackboard or your own private system to track student attendance. If you need to collect a name list, you may only ask for first and last names.
• DO NOT leave computers or other electronic devices unattended in a classroom or office when files are open to student records.
• DO NOT leave printed documents, assignments or exams in an unattended location that contain student names, grades or other personal data. Safeguard and secure all devices such as computers, laptops, PDAs, smart phones, and thumb drives that contain student data. If such devices are used to hold student data, password-protect the device and password-protect the directory folders that contain the data. Contact the Information Technology Department for guidance on information security and best practices.
• DO NOT share login credentials to any Manhattanville University system or software application that allows privileged access to student records. This includes Colleague, ServiceHub, Blackboard, or other systems.
• DO NOT provide student non-directory information to third parties such as prospective employers, associations, other universities, outside organizations, etc., without the student's written consent. EXCEPTION: Conversations and communications with an employer to manage a student's internship are allowed under FERPA because such discussions are required for the management of the internship. Be sure the outside employer is made aware that once they have been provided privileged student information, they too are subject to FERPA policy.
• DO refer requests for student information to the proper educational record custodian as follows:
  • Registrar's Office: Academic records, transcripts, grades
  • Financial Aid Office: Aid award amounts, loans, FAFSA, etc.
  • Student Accounts Office: Tuition billing, balances, etc.
  • Student Health and Counseling Center: Immunization, health/counseling records
• DO shred all unneeded documents related to any member of the university community (students, faculty, and staff) that contains personal information (i.e. social security numbers, grades, contact data, etc.). Proper document security protects everyone and keeps Manhattanville in compliance with FERPA and other nationally recognized privacy policies.
• Personal notes on students: If you maintain personal notes on students, be sure they are only necessary for the fulfillment of your teaching, advising, or administrative responsibilities. NOTE: The personal notes of a professor or staff member concerning a student that are intended for that individual's own use are not a part of the student's educational record and may not be included as part of a student's request for a FERPA record inspection under the "Sole possession of the maker" provision.
• If you or your office are served a subpoena by a legal entity to provide student record information, forward the subpoena to the President's Office immediately.