Definitions, FERPA Compliance Manual


A.	Education Records includes any information or data recorded in any medium, including but not limited to, handwriting, print, tapes, film, e-mail, microfilm, and microfiche, which is directly related to a student and maintained by the University or by a person acting for the University. The term “Education Records” does not include: Records that are kept in the sole possession of the maker of the records, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record. These records are not to be revealed in a meeting where minutes are being taken or with a secretary for the purpose of typing them or to organize private files. The records maintained solely for law enforcement purposes by University law enforcement units. Employment records made and maintained in the normal course of business and related exclusively to the individual in that individual's capacity as an employee and are not available for use for any other purpose. Records created or maintained by a physician, psychiatrist, psychologist, or other recognized professional or paraprofessional acting in his or her professional capacity and used only in the treatment of the student and not available to individuals other than those providing the treatment. Records that only contain information about an individual after that individual is no longer a student at the University (e.g., information collected by the University pertaining to alumni accomplishments). Admission records for a student who does not officially attend the program of admission. If the student completed a course at the University but never officially attended as a degree candidate in the program of admission, then the student has FERPA rights with respect to that course but does not have rights with respect to the admissions credentials for that program.
B.	Student includes any individual who is officially registered and in attendance or has been officially registered and in attendance at The University of Arizona and about whom the University maintains education records. A person who has applied for admission to, but has never been in attendance at a component unit of the University (such as the various colleges, departments, schools or degree programs which comprise the University), even if that individual is or has been in attendance at another component unit of the University, is not considered to be a student at the component unit to which an application for admission has been made. For example, a student in an undergraduate college who applies for admission to the College of Medicine would not be a student at the College of Medicine until such time as he or she has been in attendance at the College of Medicine. Postsecondary education students are divided into two groups -- those dependent on parental support while in attendance, and those not dependent on their parents. Both classes of students are accorded the same rights under the Act, except that the parents of dependent students may examine their dependent's education records without the student's consent, which is not the case with parents of independent students. Student dependency is defined by Section 152 of the Internal Revenue Code of 1986. Under the Act, the students' dependent status relates only to the right of their parents to review education records. To exercise these rights, both students and parents of dependent students should complete certain forms described in subsequent sections of this manual.

C.	Parent means a parent of a student and includes a natural parent, a guardian, or an individual acting as a parent in the absence of a parent or a guardian.

D.	Attendance at the University includes, but is not limited to, attendance in person and by correspondence, and the period during which a person is working under a work-study program. The term does not apply to applicants for admission nor does it apply to persons who have been admitted but who have not officially registered and been in attendance.

E.	Directory Information - The University designates the following categories of student records information as Directory Information: student’s name, date of birth, local/residence hall address, local/residence hall telephone number, official university electronic mail address, college, class standing/classification, academic program (degree, major, minor), dates of attendance, status (full or part-time registration), degree(s) received, honors and awards received, participation in officially recognized activities, and weight and height of members of athletic teams. The University without the consent of the student may disclose directory Information unless the student has restricted the release of this information. See also, Notice of Directory Information.

F.	Disclosure means permitting access, release, transfer or other communication of personally identifiable information contained in education records by any means to any party.

G.	Personally identifiable means that the data or information includes the name of a student, the student's parent, or other family member; the address of the student or student’s family; a personal identifier, such as the student's identification number or social security number; or a list of personal characteristics that would make the student's identity easily traceable.

H.	Legitimate educational interests means (1) the information or records requested is relevant and necessary to the accomplishment of some task or determination; and, (2) the task or determination is an employment responsibility for the inquirer or is a properly assigned subject matter for the inquirer's determination; and, (3) the task or determination is consistent with the purpose(s) for which the record, information, or data are maintained.

I.	School Officials are those members of the institution acting with legitimate educational interests including faculty, clerical, ancillary, research and professional employees, medical and legal personnel, and members of university, college, or departmental committees. School Officials also include persons, companies or agencies with whom the University has contracted to provide services that the University, itself, would otherwise have to provide (such as an attorney, auditor, collection agent, security service or other service provider).