Student Data Practices Policy and Procedure

This policy is based upon federal and state laws and regulations covered by the Family Educational Rights and Privacy Act (FERPA) and the Minnesota Government Data Practices Act (MGDPA).

Definitions

A student is an individual who has either applied for enrollment, who is currently enrolled, or has been formerly enrolled at Inver Hills Community College. All students have the same rights regarding their educational data.

Educational records are those records directly related to a student and maintained by Inver Hills Community College. Educational records include, but are not limited to admissions materials, financial aid records, transcripts, class lists, class schedules, graded exams or papers, records of disciplinary proceedings, photographs, work study records and much more. Certain information is exempted from the definition of "education record," including:

• "Sole possession" notes of individuals records which remain in the sole possession of the maker, are used only as a personal memory aid, are not accessible or revealed to any other individual, and are destroyed at the end of the school year;
• Law enforcement unit records- not shared with school officials and maintained for law enforcement purpose;
• Alumni records - information about individuals when no longer students;
• Medical treatment records - only accessible by treatment providers

A school official is a person employed by Inver Hills Community College in an administrative, supervisory, academic, or support staff position; a person or company with whom Inver Hills Community College has contracted; a person serving on the Board of Trustees or in the Office of the Chancellor; a student serving on an official college committee; a college security officer acting in a health or safety emergency; or a person assisting another school official in performing his or her tasks. A school official has a legitimate educational interest if the official needs to review an educational record in order to fulfill his or her professional responsibility.

Student rights under FERPA and MGDPA 

A student has a right to inspect and review his or her educational records. Requests should be made in writing to the Director of Enrollment Services/ Registrar. Inver Hills Community College will provide access to view educational records immediately if possible, or within ten days of the student's request. A student requesting a copy of his or her educational records will be assessed the cost according to current college fee rates. More information is below under "Procedure to inspect education records."

A student has a right to consent to disclosures of information, which identify him or her personally, except to the extent that these disclosures are allowed without student consent under state and federal law.

A student has the right to request that the Office of Enrollment Services correct educational records, which he or she believes to be inaccurate or misleading. The student should petition the Director of Enrollment Services/Registrar and clearly identify the part of the record they want changed as well as why the record is inaccurate or misleading. More information is below under "Procedure to correct education records." Note: The right to challenge a grade does not apply under this policy unless the grade assigned was allegedly inaccurately recorded. Students will be notified of their FERPA and MGPDA rights through publications of the policy on the college website and in the Catalog. Copies are also available from the Office of Enrollment Services.
A student has the right to file a complaint with the U.S. Department of Education concerning alleged failures by Inver Hills Community College to comply with the requirements of FERPA. Students desiring to file a complaint should address the complaint to:

Family Policy Compliance Office
U.S. Department of Education
600 Independence Avenue, SW
Washington, DC 20202-4605

Consent for release

Inver Hills Community College will not permit access to or the release of personally identifiable information contained in student educational records without the written consent of the student to any third party (including parent/guardian, dependent, or spouse/domestic partner), except as authorized by FERPA and MGDPA or other applicable law. A student may grant consent by completing an

Authorization to Release Student Information form (a pdf document), available from the college website or from the Office of Enrollment Services. The student must present a photo ID in person when submitting this form.

Directory information

Directory information is information not generally considered harmful or an invasion of privacy if disclosed to the public. Inver Hills Community College has the authority to release the following information classified as directory information to the public:

• Student's name
• Institution assigned email address
• Major/Program
• Enrollment status
• Dates of attendance or graduation
• Previous school attended Degrees, honors and awards received
• Photographs taken individually or in groups

Inver Hills will not sell or release lists of students and their directory information to any individuals or agencies other than those listed in the following section. 
 

Identity Verification

College personnel will verify a student's identity before sharing non-directory information. The following steps will be taken to verify a student's identity:

• In person: College personnel will ask for a government or college-issued picture ID. 
• By phone: College personnel will ask to verify at least two pieces of information about the student that exists in the Student Information System (SIS).  The information to be verified includes student ID, social security number, birthdate, or current address. If this information is not in the SIS or if the student provides conflicting information, they will be prompted to come to campus and show a government or college issued picture ID.
• By e-mail: College personnel will only respond with non-directory information if the e-mail is a college-issued e-mail address. Questions coming from other e-mail addresses will be answered with general or directory information.

Release without consent

As allowed under FERPA and MGDPA, Inver Hills Community College has the right to release student records without student consent. Examples of release without consent include the following individuals and agencies:

• Appropriate school officials with a legitimate educational interest.
• Specified officials for audit, accrediting, or evaluation purposes.
• Appropriate parties in connection with providing financial aid to a student.
• Appropriate officials in cases of health and safety emergencies.
• State and local authorities pursuant to specific state law.
• Compliance with a judicial order or lawfully issued subpoena.
• Military recruiting personnel, under the Solomon Amendment of the National Defense
  Authorization  Act. In addition to directory information, Inver Hills Community College must
  disclose address, telephone number, and date of birth.
• The National Student Clearinghouse for the purpose of providing enrollment and graduation
  verification to employers and financial lenders.
• Another educational agency or institution, where a student intends to enroll, is enrolled, or from 
  which a student receives services. Inver Hills will automatically send official transcripts to other
  MnSCU institutions where the student is enrolled or has applied for admission.
• Inver Hills Community College Foundation (alumni).

A student may direct that any or all of the directory information be withheld from public disclosure by notifying the Director of Enrollment Services/Registrar in writing. The non-disclosure request will be permanent unless the student requests otherwise. For questions concerning your rights, please contact the Office of Enrollment Services.

Course grades and student transcripts

Course grades and transcripts are an essential element of student records and the following supplemental policies shall govern these records at Inver Hills Community College:

• Instructors will take care to not reveal individual student grades. If grades are posted at a location accessible to all students, no personal identification, including name, social security number, or any part of those identifiers may be used in conjunction with posted grades
• Student grades will not be revealed over the phone
• All requests for transcripts must be received in writing via secure web form, fax, mail, or in person. 

Procedure to inspect education records

Students may inspect and review records upon request to the Director of Enrollment Services/Registrar. Students should submit a written request which identifies as precisely as possible the record or records he or she wishes to inspect.

The Director of Enrollment Services/Registrar or an appropriate Inver Hills Community College staff person will make arrangements for access as promptly as possible and notify the student of the time and place where the records may be inspected. Access must be given in ten days or less from the date of receipt of the request. When a record contains information about more than one student, the student may inspect and review only the records which relate to him or her.

Students who live more than 50 miles from campus may send a written request for a copy of their education records, specifying the documents requested along with the required fee per page. The fee for copies of records other than Inver Hills Community College transcripts is $.25 per page.

Under FERPA and MGDPA, a college or university cannot deny students access to their education records; however, it may deny copies in circumstances specified by institutional policy. Inver Hills Community College reserves the right to deny copies of any of the following records:

• The financial records or statements of the student's parents or legal guardians.
• Letters and statements of recommendations for which the student has waived his or her right to access, or which were maintained before January 1, 1975.
• Those records which are excluded from the FERPA or MGDPA definition of education records.
• Official transcripts when there is a business office, records, or library hold on the student record. However, unofficial transcripts will be released regardless of holds on a student record.
• Educational records that include a set of standardized test questions. (An exam or standardized test that is not directly related to a student is not an education record and therefore is not subject to FERPA access provisions.)

Procedure to correct education records

Students have the right to ask to have records corrected that they believe are inaccurate, misleading, or in violation of their privacy rights. The following are procedures for the correction of records:

1. A student must request, in writing, that the Director of Enrollment Services/Registrar amend a record. In so doing, the student must identify the part of the record to be amended and specify why the student believes it is inaccurate, misleading or in violation of his or her privacy rights.
2. The Director of Enrollment Services/Registrar will decide whether or not to comply with the request. If the college decides not to comply, the Director of Enrollment Services/Registrar will notify the student of the decision and advise the student of his or her right to a hearing to challenge the information believed to be inaccurate, misleading, or in violation of the student's rights.
3. Upon request, Inver Hills Community College will arrange for a hearing and notify the student in advance of the date, place, and time of the hearing.
4. The hearing will be conducted by the Vice President of Student Affairs and Enrollment Management. The student shall be afforded ample opportunity to present evidence relevant to issues raised in the original request to amend the student's education records. The student may be assisted by an Inver Hills Community College faculty or staff member serving in an advisory capacity.
5. The Vice President of Student Affairs and Enrollment Management will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence presented and the reasons for the decision.
6. If Inver Hills Community College decides that the information is inaccurate, misleading, or in violation of the student's privacy rights, the record will be amended and the student notified, in writing, of the change.
7. If Inver Hills Community College decides that the challenged information is not inaccurate, misleading, or in violation of the student's privacy rights, the student will be notified that he or she has the right to place in the record a statement commenting on the challenged information and/or a statement setting forth reasons for disagreeing with the decision.
8. The statement will remain part of the student's education records as long as the contested information is maintained. If Inver Hills Community College discloses the contested portion of the record, it must also disclose the student's statement.

Applicable Laws

Copies of FERPA, MGDPA, and the Solomon Amendment can be found online.

1. FERPA

   20 U.S.C. 1232g (http://www.ed.gov/policy/gen/guid/fpco/pdf/ferparegs.pdf)
   34 CFR Part 99 (http://www.ed.gov/legislation/FedRegister/finrule/2004-2/042104a.pdf)

2. MGDPA

    Chapter 13: http://www.revisor.leg.state.mn.us/stats/13/

3. Solomon Amendment

    32 CFR Part 216: http://www.clhe.org/mil-recru.htm

Contacting the Office of Enrollment Service

Questions concerning data privacy should be directed to:

Inver Hills Community College
Office of Enrollment Services
2500 East 80th Street
Inver Grove Heights, MN 55076
651-450-3503 (phone)
651-450-3677 (fax)
http://www.inverhills.edu
enrollment@inverhills.edu

Notice of data practices access personnel

The Responsible Authority for data practices compliance and access to government data for Inver Hills Community College is Dr. Cheryl Frank, President, Liberal Arts Building, Room 222.

Requests for Student Data should be directed to Landon K. Pirius, Interim Dean of Students, College Center Building, 651-450-3680.

Requests for Personnel Data should be directed to Liz Newberry, Director of Human Resources, Liberal Arts Building, Room 233, 651-450-3654.

Students who have questions or concerns about obtaining access to data or other data practices issues may contact the campus Data Practices Compliance Officer: Landon K. Pirius, Interim Dean of Students, College Center Building, 651-450-3680.

The address for Inver Hills Community College is 2500 80th Street East, Inver Grove Heights, MN 55076. The college website address is www.inverhills.edu.