Included in this document are:

1. Lake Forest Graduate School of Management’s policies as they relate to FERPA
2. Guidelines for daily / regular access and release of education records by school officials as regulated by FERPA and Lake Forest Graduate School of Management’s FERPA Policy Statement. All questions regarding FERPA and student education record confidentiality should be directed to the Registrar’s Office.

POLICY STATEMENT

Lake Forest Graduate School of Management (LFGSM) complies with the provisions of the federal Family Educational Rights and Privacy Act (FERPA), which regulates the confidentiality of data in student education records and the terms for its disclosure. A copy of the act is on file in the Registrar’s office. The Registrar and EVP of Education Programs and Solutions are the officials responsible for ensuring compliance with the act and creating relevant policies and procedures regarding the release of student education records and related information under the Act.

RATIONALE

As an institution of higher education receiving federal funds, LFGSM is required to adhere to the provisions of FERPA. This policy identifies student rights to inspect and review their educational records under FERPA, to request amendments of their records, to consent to the release of their records under the regulation, and to file a complaint against LFGSM alleging failure to comply with FERPA requirements. Further the policy defines directory information and the process for granting or denying requests for the release of that information.

The policy also establishes the Registrar and EVP of Educational Programs and Solutions for enforcing compliance with this regulation and for communicating to those covered under the Act the annual notification of their privacy rights.

SECTION 1: Definitions

LFGSM: Hereafter in this document a reference to Lake Forest Graduate School of Management

Educational Record: All records maintained by LFGSM in any medium (print, electronic, written, video, audio, film, etc.) directly relate to a student.

Among the exceptions:

• Records kept in the sole possession of the maker and used solely as a reminder/memory jogger and is not shared with anyone except as a temporary substitute for the maker of the record.
• Records created or received after a student is no longer in attendance at LFGSM and the records do not relate to the person’s attendance as a student;
• Employment records of an individual whose employment is not contingent on the fact that he/she is a student

Student: An individual who is or has been in attendance and with respect to whom LFGSM maintains education records

Record Custodian: School official/unit which maintains specific education records

School Official:

• A person employed by LFGSM in an administrative, supervisory, academic or support staff position, including faculty.
  
• A person or company with whom LFGSM has contracted as third party consultants (such as an attorney, auditor, or collection agent) or service providers (shredding services, intern placements).
  
• Volunteers serving on University committees, boards, advisory groups, including but not limited to Board of Directors, student committees, admissions committees.
  

School officials have no inherent right to access educational records, but may have access to educational records based upon legitimate educational interest.

Legitimate Educational Interest: A school official has a legitimate educational interest when the official, in the performance of professional responsibilities assigned by LFGSM, also meets one of the following criteria:

• Performing a task that is specified in his/her job position description or by a contract agreement;
  
• Performing the task related to a student’s education;
  
• Performing a task related to the discipline of the student

Disclosure to a school official having a legitimate educational interest does not constitute authorization to share the information with a third party without a student’s written consent.

Third Parties: Non-LFGSM persons or entities, including parents, spouses, and significant others.

Directory Information: Records that are neutral or not necessarily harmful if released to third parties such as commencement bulletins, event programs, etc. LFGSM is not required to release directory information, and may do so arbitrarily.

SECTION 2: Directory Information

LFGSM designates the following items (data) as directory information:

Student's Name	Employment Affiliation
Part-Time Status	Company Title
Dates of Attendance	Company Direct Telephone Line
Degree Awarded	Company Fax Number
Major Field of Study	Email Address
Honors Awarded	Photograph

Request by the student for non-disclosure of Directory Information

Students may withhold Directory Information by notifying the Registrar’s Office by submission of a “Request for Non-Disclosure of Directory Information” form available from the Registrar’s Office.

“Non-disclosure” requests prevent release of any directory information or acknowledgement to third parties that the requestor is a student, alum, or former student of LFGSM.

“Non-disclosure” applies to all elements of directory information. LFGSM does not apply “No Release” differentially to the various directory information data elements.

“Non-disclosure” request only pertains to release of directory information to those entities not falling within other exceptions authorized under FERPA, such as school officials or to members of a classroom community in which the student is enrolled.

“Non-disclosure” requests must be filed during the first two weeks of a term and will stay in effect until removed by the student with a written request.

Release of Directory Information – Social Security Number (SSN)

LFGSM will not disclose directory information without a student’s signed and dated written consent if a student’s social security number is used to identify the student or his or her records.

SECTION 3: Providing Student Access to Their Education Records

Students may review their education records upon request. Students may access education records in the following ways:

• via LFGSM’s secure student portal
  
• a written request to the records custodian with the student’s signature

The records custodian will provide the student with access to a requested education record in a reasonable time not to exceed 45 days after receipt of the request.. When a record contains information about more than one student, the student may access and review only the records which relate to him or her.

Students having an unpaid financial obligation will not be able to access and view their grades through the student portal; however, students may contact the Registrar’s Office to request to view their grades.

LFGSM does not generally provide copies to students, but to provide access.

LFGSM is not required to provide the student access to education records that are:

• personal confidential statements of recommendation, if the student has waived his or her right to inspect them
  
• LFGSM is prohibited to provide access to records containing other student’s education records

SECTION 4: Release of Education Records to Parties other than the Student

Other than the exception listed below, in order to release education records, LFGSM’s Registrar’s Office must receive a signed and dated authorization providing the following information:

• record(s) to be released
  
• to whom
• purpose

An email request is not considered a signed release; an email containing a PDF attachment with the student’s signed release is acceptable. A Fax request with the student’s signed release is also acceptable.

Disclosures not requiring the student’s signature for release -

1. To school officials at LFGSM who have a legitimate educational interest in the records.
   
2. To certain authorized government representatives.
   
3. In connection with the student’s financial aid request or award and the information is necessary for certain purposes set forth in the regulations.
   
4. To organizations conducting studies for or on behalf of LFGSM.
   
5. To accrediting organizations to carry out their accrediting function.
   
6. To comply with a judicial order or lawfully issued subpoena.
   
7. In connection with a health or safety emergency to appropriate parties.
   
8. To the victim concerning the result of a disciplinary proceeding related to crimes of violence or a non-forcible sex offense.
   
9. Information designated as “Directory Information” unless the student has filed a “Directory hold.”
   
10. Other exceptions not listed here but authorized by 34 CFR point 99.31.

Re-disclosures to third parties:

The recipient of information from LFGSM education records agrees that Education records are protected by the federal Family Educational Rights and Privacy Act (FERPA) and the policies of the Lake Forest Graduate School of Management.

• Access and usage of these records is restricted to the purpose of which the records were released;
  
• Further disclosure of these records or information from these records is prohibited without the prior written consent of the individual identified by the record;
  
• Failure to comply with these provisions may result in the recipient’s ineligibility to receive information from LFGSM records for a period of at least five years.

SECTION 5: Authentication

In accordance with the federal FERPA regulations, LFGSM must use reasonable methods to identify and authenticate the identity of students, school officials, and any other parties to whom they disclose educational records, regardless of the medium source of the request.

SECTION 6: Record of Requests for Disclosure

Records are maintained of all requests for access to and disclosure of information from the education records of students. The record will indicate the name of the party making the request, any additional party to whom it may be disclosed, and the legitimate interest the party has in requesting or obtaining the information.

Records are not required or maintained for disclosures to the student, a LFGSM official with legitimate educational interests, a party with written consent from the student, a party seeking directory information, or for other exceptions that may be authorized per FERPA regulations.

SECTION 7: Correction of Education Records

Students have the right to seek amendment of their educational records that the student believes to be inaccurate, misleading, or otherwise in violation of the student’s privacy rights. LFGSM’s Annual Notification to Students outlines the procedures for requesting a correction to records.

SECTION 8: Notification to Students

The Notification to Students is mandatory information made available to students about their FERPA rights. LFGSM’s Annual Notification is emailed to all current students each Summer and also resides on savvyWORKS in the Student Handbook.

The notification includes:

• Right and method to inspect and review
  
• Right and methods to seek amendment
  
• Right and consent to disclosures of personally identifiable information in the student’s education records except to the extent of that
• FERPA authorizes disclosure without consent
  
• Right to file a complaint with Department of Education
  
• Definition of school official
  
• Definition of legitimate educational interest
  
• Definition of directory information