Privacy Policy for Student Records

General Privacy Policy:  Western Technical College is committed to the concern for and protection of students’ rights and the privacy of information, and carefully protects all personally identifiable information (PII) in our possession regarding students and their families, in accordance with this policy. The College has a single Privacy Policy that complies with both the Federal Family Rights and Privacy Act (FERPA), and the Gramm-Leach-Bliley Act.  The Administrative Supervisor is responsible for the privacy of student records and information, and for maintaining institutional compliance with this policy campus-wide.

Family Educational Rights and Privacy Act (FERPA)

FERPA provides current and former students with the right to inspect and review educational records, the right to seek to amend those records, the right to limit disclosure of information from the records and the right to file a complaint with the U.S. Department of Education.  Students may also waive their rights under FERPA voluntarily under certain circumstances.

Students’ Rights:  Each student has the following rights under FERPA:

• Right to Be Informed:  Students have the right to be informed about their rights under FERPA and GLB.  This policy details those rights and is published through the College’s website.
• Right to Review Educational Records:  Students have certain rights with respect to their educational records. Students have the right to review their educational records within 45 days of the day the College receives a request for access. Students should submit to the College Administrative Supervisor written requests that identify the record(s) they wish to inspect, and the student will be notified of the time and place where the records may be inspected. If the records are not maintained in the office of the College Administrative Supervisor, the Administrative Supervisor will advise the student of the correct official to whom the request should be addressed.
• Right to Request an Amendment:  Students have the right to request an amendment to the educational records that are believed to be inaccurate. They should submit a written request to the Administrative Supervisor or the College official responsible for the record, clearly identify the part of the record they want changed and specify why it is inaccurate. If the College decides not to amend the record as requested by the student, the College will notify the student of the decision and advise the student of his or her right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
• Right to Consent to Disclosures:  Students have the right to consent to disclosures of personally identifiable information contained in the student’s educational records, except to the extent that this policy authorizes disclosure without consent.
• Right to File a Complaint:  Students have the right to file a complaint with the U.S. Department of Education concerning alleged failures of the College to comply with the requirements of FERPA. The office that administers FERPA can be contacted at Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue, SW, Washington, DC 20202-4605 or at the website: http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html

Parents Rights under FERPA

At the post-secondary level, parents have no inherent right to access or inspect their son’s or daughter’s educational records, including final grades, grades on exams, and other information about academic progress. This information is protected under FERPA and parents do not have access to it unless the student has provided expressed, written authorization, or unless the student is a dependent as defined in Section 152 of the Internal Revenue code of 1954.  However, the College may discuss items necessary for the awarding of financial aid with the parent(s) of a dependent student.

An applicant becomes a “student” for the purposes of FERPA upon the earlier of the date the student begins instruction at the College or the date of the expiration of the 72-hour cancellation period prescribed in Texas Workforce Commission regulations.

The Gramm-Leach-Bliley Act (GLB) provides consumers the right to the protection of their nonpublic Personally Identifiable Information (PII) in order to prevent identity theft and other related crimes. All individuals who provide PII to the College are protected under the Act, including parents of dependent students.  The Act also requires publication of this “Privacy Policy”.

In general, the College will never release personal information provided by any student, parent or prospective student (including information gathered through websites and web-applications) to any third party for marketing or advertising purposes, or for any other reason beyond those specifically addressed in this policy.

Information Security Practices: The College employs additional office procedures and password-protected computer systems to ensure the security of paper and electronic records.  The College does not disclose its security procedures to students or the general public to protect the effectiveness of those procedures.  Access to social security numbers is strictly limited to those College Officials (see definition below) with a need-to-know, as determined by the Student Financial Services Director and the Administrative Supervisor.

 Protection of Personally Identifiable Information:  College Officials may not disclose personally identifiable information about a student or other individual nor permit inspection of personal records without the individual’s written permission, unless such action is covered by certain exceptions permitted under this policy, as follows:

•   Information Available to a College Official: The student’s consent is not required when a College Official has a legitimate educational interest in the student’s educational record; that is, if the official needs to review this information in order to fulfill his/her professional responsibility. However, this does not constitute authorization to share that information with a third party without the student’s written consent.

A “College Official” is a person employed by the College in an administrative, supervisory, academic, research, or support staff position; a person or company with whom the College has contracted (such as an attorney, auditor, or accrediting agency); a person serving on the Board of Directors; or a student serving in an official position/capacity or assisting a College official in performing his/her tasks.

• Financial Aid Information: Certain information necessary for the processing of federal financial aid programs may be disclosed to parent(s) of dependent students.  For a person to be considered a “parent” for this purpose, the individual must be listed as such on the student’s FAFSA application.  Further, certain information necessary for the administration of Federal Student Aid may be released to federal and state agencies, government contractors, student loan servicers, and other parties.
• Subpoenas: Western Technical College will release information to a court or other legal entity/jurisdiction based upon a valid subpoena. Administrative subpoenas may be forwarded to the College’s Attorney, who will authorize appropriate release of information.
• Emergency Release to Law Enforcement: In cases where the health or safety of students and/or College employees may be in jeopardy, the President, Student Financial Services Director  or other department manager may release any relevant information to law enforcement and/or emergency services personnel as may be deemed necessary and appropriate to the situation.
• Directory Information: Certain information is not considered to be Personally Identifiable Information, and as such can be disclosed.  This disclosable data is known as “Directory Information”.  The College has designated the following as Directory Information:
• Student Name
• Hometown
• Curriculum (Program)
• Enrollment Status
• Dates of Enrollment
• Certificates Received
• Honors or Awards Received

Students who wish to restrict the release of directory information (high security) must notify the Administrative Supervisor in writing within five (5) school days from the student’s first day of classes and provide specific instructions of the items that the student does not want disclosed.  If no notice is received by that date, the information will be classified as directory information.

Student Choice to Release Information:  Students have a right to release information otherwise protected under the policy to persons of their choice.  Students who wish to permit the release of additional information to a specific person or persons must complete a Consent to Release Personal Information form for each person and submit it to the Administrative Supervisor’s Office.

A student may also have a person or persons accompany him/her during an office visit.  If personal information is going to be discussed, the student will be asked whether he/she would like to discuss personal information with others present, and the staff member will receive verbal consent prior to continuing the conversation.

Request for Financial/Financial Aid Information by Agencies: The College cannot directly release financial need or any other financial aid information to outside agencies and/or organizations (scholarship providers, insurance companies, etc.)   If the student needs such information to be released, he/she must:

• Be currently enrolled in a program (including students fully accepted/approved for enrollment/re-enrollment but awaiting class start).
• Submit an original, signed release form from the requesting agency (with original student signature) which clearly lists the specific information to be released and the full name, address, and contact information of the agency or organization to which the information shall be released.

Upon completion of the form by the Financial Aid or Business Office, it will be returned to the student in a sealed envelope for self-delivery by the student to the agency.

Other Records-Related Issues:  The College reserves the right to deny official transcripts or copies of other records not legally required to be released in the following situations:

• The student has any unpaid financial or other obligations to the College.
• There is unresolved disciplinary action against the student or unresolved litigation between the student and the College.