While emailing grades, GPA, and other personally identifiable information (PII) is not a best practice or recommended, it is not impermissible. If a faculty member utilizes email to send FERPA-protected PII, they may only send the email within our domain - meaning that the email must be sent to the student only from the faculty member’s Dickinson email address. In addition, the information may only be sent to the student’s Dickinson email address.
May I leave personally identifiable exams or papers in a box for students to pick up?
No, each student can flip through the pile seeing the grades of other students. Alternative practices for distributing grades papers or tests might include having the Academic Department Coordinator keep exams at his/her desk and hand them out to students as they come for them or putting the exams in sealed envelopes with the student’s name on the outside that are available for pick-up.
What should I do if I receive a subpoena to send a student/alum records?
First, please understand that even if you received the subpoena, you are likely receiving it in your capacity as a representative of Dickinson College, and it is the College’s obligation to respond. Please forward the subpoena to the College’s General Counsel, who will verify the validity of the subpoena and work with the Registrar’s Office in responding. Under most circumstances, the Registrar’s Office is required to make a reasonable effort to let the student/alum know that a subpoena has been received before anyone at the College releases information.
Are records that are not maintained in the Registrar’s Office– such as advising offices, student conduct office, athletics -- still part of the student’s educational record?
Yes – FERPA does not speak to where or how an institution maintains student education records, only that education records are (1) directly related to a student, and (2) maintained by an educational institution or by a party acting for the institution. FERPA does not mandated centralized recordkeeping, so even if a materials directly related to a student are maintained in a location other than the Registrar’s Office, they meet the definition of an education record.
What are my responsibilities for notifying the Registrar if I release information from a student’s education record?
You must notify the Registrar of each and every disclosure of information from a student’s education record that you make. Doing so is necessary so that the Registrar can fulfill Dickinson’s obligation to maintain a record of each request for access to and each disclosure of personally identifiable information from the education records of each student. For each request or disclosure, the record must include the identity of the parties who have requested or received personally identifiable information from the education records, and the legitimate interests the parties had in requesting or obtaining information. This requirement applies to letters of recommendation prepared at the request of students.
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