Johns Hopkins Gazette: October 16, 1995


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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