Johns Hopkins Gazette: October 10, 1994


Updated University Policy on Student Privacy Rights

    The following policy has been adopted and promulgated by
The Johns Hopkins University in compliance with the Family
Educational Rights and Privacy Act of 1974, as amended:

1.  Each year the university will inform students of their
rights under the Family Educational Rights and Privacy Act of
1974 (P.L. 93-380, 513), as amended (P.L. 93-568 2), as well
as heir rights under regulations promulgated thereto, and
relevant university policy.

2.  It is the policy of The Johns Hopkins University to
permit students to inspect and review their education records
to the extent permitted by applicable law and regulations.

3.  The following exceptions and exclusions shall apply to
the general policy permitting inspection and review of
education records:
    a)   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;

    b)   Students will not be permitted to inspect financial
records or statements of parents or any information thereof;

    c)   Students will not be permitted to inspect
confidential letters and confidential statements of
recommendation which were placed in the education records
prior to Jan. 1, 1975, provided that (i) they were solicited
with a written assurance of confidentiality, or sent and
retained with a documented understanding of confidentiality,
and (ii) they were used only for the purposes for which they
were specifically intended.

    d)   Students will not be permitted to inspect
confidential letters and confidential statements of
recommendation which were placed in the education records of
the student after Jan. 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.

    e)   The university will not disclose documents which do
not come within the statutory and regulatory definition of
the term "education records" as, for example,

    (i)  Records of instructional, supervisory and
administrative personnel and educational personnel ancillary
thereto which are in the sole possession of the maker and are
not accessible or revealed to any other individual except a
substitute.

    (ii) Records of a university law enforcement unit which
are maintained apart from a student's education record solely
for law enforcement purposes and are not disclosed to
individuals other than law enforcement officials of the same
jurisdiction.

    (iii) Records relating to an individual who is
employed by the university which are made and maintained in
the normal course of business, relate exclusively to that
individual's capacity as an employee, and are not available
for use for any other purpose although this exclusion does
not apply to records relating to a student in attendance at
the university who is employed as a result of his or her
status as a student.

    (iv) Records which are created or maintained by a
physician, psychiatrist, psychologist or other recognized
professional or paraprofessional acting in a professional
capacity, which are created, maintained or used only in
connection with the provision of treatment to the student and
which are not disclosed to anyone other than individuals
providing the treatment although they may be personally
reviewed by a physician or other appropriate professional of
the student's choice.

    (v)  Records containing only information relating to a
person subsequent to attendance at the university.

4.  Parents of students and students desiring to inspect and
review the education records of the student should address a
written request to the registrar of the school which the
student attends or has attended. Requests from parents should
be accompanied by a written letter of permission from the
student whose record is requested. In the event that the
records requested are not in the registrar's custody, the
registrar shall direct the request to the appropriate
custodian.

5.  The university shall attempt to respond to requests for
access to records as expeditiously as practicable, and within
45 days of the receipt of the written request. Records may be
inspected by students only in the presence of the custodian
or other such persons as the custodian designates and in no
event shall a student be permitted to remove records from the
office where they are maintained. The opportunity to inspect
and review education records will be confined to normal
business hours on the days when that office is open.

6.  The university reserves the right to decline to make
copies of education records when the parent of a student
and/or a student lives within a normal commuting distance
from the school and when the task of preparing copies
presents itself as unduly burdensome or interferes with the
normal duties and operations of personnel.

7.  Students may obtain copies of education records, other
than a transcript, by paying upon delivery a charge of $.50 a
page. Copies of transcripts may be secured with payment of
any applicable fee. The university reserves the right to
decline to furnish a copy of a transcript from another
educational institution which is a part of a student's
education record unless the student demonstrates that it is
otherwise unavailable. All copies of transcripts furnished a
student shall bear a conspicuous legend indicating that the
copy has been delivered directly to the student.

8.  Education records are maintained on each student by the
registrar of the school in which the student is or has been
enrolled. (School of Health Services academic records are in
the Registrar's Office in Garland Hall.) Education records on
students also may be maintained by departments within the
school as well as in the offices of the appropriate
departments. A complete listing of the departments within the
school, the location of each department and the location of
each dean is in the university's telephone directory.
Following is a listing of other education records maintained
by the university and their locations.


Schools of Arts and Sciences/Engineering:  

    Student account records, Shriver Hall; financial aid
records, 1st floor, Garland Hall; placement records, 1st
floor, Merryman Hall; health records, ground floor, AMR2;
academic records, 2nd floor, Mergenthaler (Arts and
Sciences), 1st floor, New Engineering Building (Engineering),
and Registrar's Office, basement, Garland Hall.


School of Continuing Studies:  

    Student account records, ground level, Shriver Hall;
financial aid records, 204 Shaffer Hall; student loan
records, 3rd floor, Garland Hall; academic records,
Registrar's Office, basement, Garland Hall.


School of Hygiene and Public Health:  

    Student account records, Room 1040, Business Office;
financial aid records, Room 1031, Financial Aid Office;
health records, University Health Service, Carnegie 3;
student loan records, 3rd floor, Garland Hall; academic
records, Room 1028B, Registrar's Office.


School of Medicine:  

    Student account records, Business Office, 125 Medical
Administration Building; financial aid records, 128 Medical
Administration Building; health records, University Health
Service, Carnegie 1; student loan records, 3rd floor, Garland
Hall.


School of Nursing:  

    Student account records, Room 229, 1830 E. Monument St.;
Student Financial Services, Room 215, 1830 E. Monument St.;
admissions records, Office of Admissions and Student
Services, Room 200, 1830 E. Monument St.; academic records,
Office of the Registrar, Room 215, 1830 E. Monument St.;
health records, Alumni Memorial Residence (Homewood).


School of Advanced International Studies:        

    Student account records, Room N308, Business Office;
financial aid records, Room N215, Financial Aid Office;
placement records, Room N212, Career Services; student loan
records, Room N215, Financial Aid Office.


Peabody:  

    Student account records, Business Office, ground floor,
Leakin Hall; financial aid records, ground floor, Leakin
Hall; placement records, 105 Conservatory; health records,
Peabody Student Health Services at Mercy Medical Center, 301
St. Paul Place (active files), and JHU Student Health Clinic
at Homewood (archived files for students enrolled prior to
July 1, 1994); student loan records, 3rd floor, Garland Hall
(Homewood), and ground floor, Leakin Hall.

9.  It is the policy of the university to refrain from
disclosing personally identifiable information from the
education records of a student without the prior written
consent of the student, except that:

    a)   The university reserves the right to disclose
personally identifiable information without the prior consent
of the student to university and school officials, including
teachers, who in the opinion of the university are determined
to have legitimate educational interests.

    (i)  The term "university and school officials" refers
to administrators and staff members of the university and
school(s) in which the student is or has been enrolled.

    (ii) The term "legitimate education interest" refers to,
for example, 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.

    b)   The university may disclose as directory
information the following categories of personally
identifiable information:

    (i)  The name of a student who is in attendance or has
been in attendance

    (ii) The local and home address of a present or former
student

    (iii) The telephone number of a present or former
student

    (iv) The date and place of birth of a present or former
student

    (v)  Names of parents and spouse

    (vi) The major field of study of a present or former
student

    (vii) Participation of a student or former student in
officially recognized activities and sports

    (viii) Dates of attendance

    (ix) Degrees and awards received and pertinent dates

    (x)  The previous educational agencies or institutions
attended by a student and dates of attendance

    (xi) Photograph

    (xii) Classification and level of study

    (xiii) Sex

    A student may refuse to permit the designation as
directory information of any or all of the categories of
personally identifiable information with respect to that
student by delivering a written request to the registrar
within seven days of registration.

    c)   The university may disclose personally identifiable
information without the prior consent of the student to
officials of another school or school system in which the
student seeks or intends to enroll.

    d)   The university may disclose personally identifiable
information without the prior consent of the student to
authorized representatives of:

    (i)  The comptroller general of the United States

    (ii) The secretary of the U.S. Department of Health,
Education and Welfare

    (iii) The U.S. commissioner of education, the
director of the National Institute of Education, the
assistant secretary for education

    (iv) State educational authorities

    e)   To the extent permitted by law, the university may
disclose personally identifiable information without the
prior consent of the student in connection with financial aid
for which a student has applied or which a student has
received.

    f)   The university may disclose personally identifiable
information without the prior consent of the student to state
and local officials or authorities to whom information may be
specifically required to be reported or disclosed pur-suant
to state statute adopted prior to Nov. 19, 1974.

    g)   To the extent permitted by law, the university may
disclose personally identifiable information without the
prior consent of the student to organizations conducting
studies for, or on behalf of, educational agencies or
institutions for the purpose of developing, validating, or
administering predictive tests, administering student aid
programs and improving instruction.

    h)   The university may disclose personally identifiable
information with the prior consent of the student to
accrediting organizations in order to enable them to carry
out their accrediting functions.

    i)   The university will disclose personally
identifiable information without the prior consent of the
student to parents of a dependent student, as defined in
section 152 of the Internal Revenue Code of 1954.

    j)   The university may disclose personally identifiable
information without the prior consent of the student to
comply with a judicial order or lawfully issued subpoena;
however, the university will make a reasonable effort to
notify the student of the order or subpoena in advance of
compliance therewith.

    k)   The university may disclose personally identifiable
information without the prior consent of the student in a
health or safety emergency, subject to the conditions set
forth in applicable law and regulations.

10. The university will maintain a record of disclosures of
personally identifiable information from the education
records of a student, as required by law, and will permit a
student to inspect that record.

11. The university will provide a student who believes that
information contained in his or her education records is
inaccurate or misleading or violates his or her privacy or
other rights, with an opportunity to seek the correction of
the education records.

    a)   A student may seek to amend an education record by
submitting a written request to the registrar explaining the
basis for the request. A student whose request is denied may
request a hearing before the registrar.

    b)   The dean's designate will hold a hearing within 14
days of the receipt of a written notice of the hearing's time
and place. The hearing will be closed to all except the
university's representative(s), student, his or her
representative or attorney, and witnesses. The student will
be afforded a full opportunity to present evidence relevant
to the issue of whether information contained in his or her
education records is inaccurate, misleading or violates his
or her privacy or other rights.

    c)   The student will be informed in writing of the
university's decision.

    d)   If, as a result of the hearing, the dean's
designate decides that the information is not inaccurate,
misleading or otherwise in violation of the privacy or other
rights of the student, the student may place in the education
record a statement commenting upon the information in the
education records and/or setting forth any reasons for
disagreeing with the university's decision.

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