For The Record: 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, sec. 513), as amended (P.L. 93-568,sec. 2), as well as their 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 136; student loan records, 3rd floor, Garland Hall; academic records, Room 1028B, Registrar's Office. School of Medicine Student account records, Office of Business Affairs, 125 Medical Admin. Bldg; financial aid records, 128 Medical Administration Bldg; health records, University Health Service, Carnegie 1; student loan records, 3rd floor, Garland Hall. School of Nursing Student account records, Room 228, 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). SAIS 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 U.S. comptroller general (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 pursuant 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 without 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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