STUDENT RECORDS POLICY AND PROCEDURES
University of Southern California
(FERPA 2002)

The University of Southern California maintains the privacy of student education records and allows students the right to inspect their education records consistent with the requirements of the Family Educational Rights and Privacy Act of 1974 (FERPA).

It is the University's intention and practice that the following policy and procedures observe students' privileges and obligations as independent, responsible, adult members of the University community to the fullest degree possible allowable within the requirements of FERPA.

I. Definitions (99.3)
For the purpose of this policy, the University has adopted the following definitions of terms:
A. Education record --any record (in handwriting, print, audio or video tape, film,
electronic or other medium) maintained by the University (or an agent of the University) which is directly related to the student. The term "education record" does not include:
1. Records of instructional, supervisory, administrative and educational personnel ancillary to those persons that are kept in the sole possession of the maker and are not accessible or revealed to any other person except a temporary substitute for the maker of the record;
2. An employment record of an individual whose employment is not contingent on the fact that he or she is a student, provided the record is maintained in the normal course of business and is used only in relation to the individual's employment;
3. Records maintained by the University's Department of Public Safety when the record is maintained solely for law enforcement purposes, is revealed only to law enforcement agencies of the same jurisdiction, and is maintained separately from education records;
4. Records maintained by the Student Health Center, University Counseling Services, the Dental School or other University entity providing health or counseling services when the records are used only for treatment of a student and are made available only to persons providing the treatment; or
5. Records which contain only information about an individual after he or she is no longer a student at the University, such as alumni records.

B. Student --any person who attends or has attended a class, seminar or academic program of the University. A person will be considered in attendance when he or she has formally enrolled in a class or seminar.

C. University Official:
1. A person employed by the University in an administrative, supervisory, academic, research or support staff position;
2. A person elected to the Board of Trustees; or
3. A person employed by or under contract to the University to perform a special task (such as an attorney or auditor).

D. Disclosure --to permit access to or the release, transfer, or other communication of education records, or the personally identifiable information contained in those records.

II. Annual Notification (99.7)
Students will be notified annually of their FERPA rights by publication appearing in the "Student Education Records" section of SCampus, the student handbook.

III. Procedure to Inspect Education Records (99.10)
Students may inspect and review their education records upon request to the appropriate record custodian, except as limited under the next section of this policy.
Students should submit to the record custodian or to that custodian's designee a written request which identifies as precisely as possible the record or records he or she wishes to inspect.
The record custodian or designee will make the necessary arrangements for access within a reasonable period of time. The custodian or designee will notify the student of the time and place where the records may be inspected. Access must be provided within forty-five days of receipt of the request.
When a record contains information about more than one student, the student requesting access may inspect and review only that information which relates to him or her.

IV. Conditions Under Which Access May Be Refused (99.12)
The University reserves the right to refuse students access to the following records:
A. The financial statement of the student's parents and information contained therein;
B. Confidential letters and statements of recommendation for which the student has
waived in writing his or her right to access, or which were placed in the student's education record prior to January 1, 1975;
C. Records connected with an application to attend the University or a component unit of the University if that application was denied; or
D. Records excluded from the definition of "education record" by this policy.

V. Fees for Copies of Records (99.11)
The University reserves the right to charge a reasonable fee for the cost of providing a copy of education records to students. In the case of academic transcripts, the Office of the Registrar maintains a schedule of fees for provision of official and unofficial transcripts.

VI. Refusal to Provide Copies (99.10(d))
With respect to education records to which students retain a right of access under this policy, the University reserves the right to deny students copies of academic transcripts and other records under any of the following circumstances:
A. The student has an unpaid financial obligation to the University;
B. There is an unresolved disciplinary action against the student; or
C. The veracity of the academic transcript or record is in question.

VII. Types. Locations. and Custodians of Records
The following is a list of the types of records that the University maintains, their locations, and their custodians.
Type Location Custodian
Academic Records -Undergraduate Office of Academic Records University Registrar Graduate, Dental School, Law SAS-104
Center
Academic Records -Medical Students Office of the Dean Associate Dean of
School of Medicine Admissions and Student KAM- 500 Affairs
Athletic Records Athletics Department Athletics Director
HER-203A
Counseling Records Student Counseling Director, Student Services Counseling Services
YWCA-100
Financial Aid Records Admissions & Financial Aid Director, Financial Aid
SAS-340
Financial Aid Records -Law Students Law Center Director, Financial Aid LAW-102
Student Financial Records Student Financial Services Associate Comptroller
UGB 203
Student Disciplinary Records Office for Student Conduct Director, Office for
STU 206 Student Conduct
Occasional Records (Student education The appropriate official will The University official
records not included in the types listed collect such records and make responsible for the
above, such as correspondence and them available for inspection office in which such
progress files in offices not listed. and review occasional records
are maintained
A student seeking his or her own education records, a University official, a party with written consent from a student, and a party seeking directory information may request records from the above listed custodians. All others requesting education records must do so at the Office of the Registrar.

VIII. Disclosure of Education Records (99.31)
The University will disclose personally identifiable information from a student's education records only with written consent of the student, except under the following conditions:
A. To University officials who have a legitimate educational interest in the records;
A University official has a legitimate educational interest if the official is:
Performing a task that is specified in his or her position description or by a contract agreement;
Performing a task related to a student's education;
Performing a task related to the discipline of a student; or
Providing a service or benefit relating to the student or student's family
(such as health care, counseling, job placement or financial aid).
B. To officials of another in another school in which a student seeks or intends to enroll; (99.34) 2002/USC FERPA Policy --page 5
C. To certain officials-of the U.S. Department of Education, the Comptroller General, and state and local educational authorities, in connection with certain state or federally supported education programs; (99.35)
D. In connection with a student's request for or receipt of financial aid, as necessary to determine eligibility for, amount or conditions of the aid, or to enforce the terms and conditions of the aid;
E. To State and local officials or authorities, if required by a state law;
F. To organizations conducting certain studies for or on behalf of the University to develop, validate or administer tests, administer aid programs, or improve instruction, if such studies are conducted in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization;
G. To accrediting organizations to carry out their functions;
H. To comply with a judicial order or lawfully issued subpoena;
I. To appropriate parties in an emergency when the information is necessary to protect the health or safety of the student or of other individuals;
J. The disclosure is information the University has designated as "directory information" unless otherwise restricted by the student;
K. The disclosure is to an alleged victim of any crime of violence and concerns the final results of any disciplinary proceeding conducted by the University with respect to that crime against the alleged perpetrator of that crime;
L. To authorized representatives of the Attorney General of the United States for law enforcement purposes:
M. The disclosure is to a court when a parent or eligible student has initiated legal action against the university.
While the University reserves the right under the above stated circumstances to disclose information from a student's education records without the student's written consent, the University is under no obligation to do so.

IX. Record of Requests for Disclosure (99.32)
The University will maintain a record of all requests for and disclosures of information from a student's education record subject to the limitation hereinafter provided. The record will indicate the name of the party making the request, the name and address to which the record was sent, any additional party to whom it may be redisclosed, and the legitimate interest the party had in requesting or obtaining the information. The record may be reviewed by the student whose information was requested or disclosed.
The University will not maintain records of requests from and disclosures to (i) the student; (ii) a University official; (iii) a party with written consent from the student; or (iv) a party seeking directory information.

X. Directory Information (99.37) (20 USC1232g(a)(5) for list)
The University has designated the following items as Directory Information:
Student's address (local and permanent), telephone number.(local and permanent), university email address, student identification photo, USC attendance dates, USC degrees earned (with dates), academic honors, expected date of graduation, major/minor and degree objective, most recent previous school attended, participation in officially recognized activities and sports, whether or not the student currently is enrolled, and enrollment status.
The University may disclose any of these items without prior written consent. However, the University is under no obligation to release directory information upon request and considers such information proprietary and not for general release.
Students wishing to restrict release of directory information may do so by completing the appropriate form provided by the Registrar’s Office (SAS Lobby). Such requests remain in effect for the academic year. Students wishing only to have their information withheld from the online USC Student Directory should complete the appropriate form provided byt the Registrar’s Office (SAS Lobby).

XI. Correction of Education Records (99.20)
Students have the right to request correction of records that they believe are inaccurate, misleading, or in violation of their privacy rights. This provision for amendment does not apply to disputed grades or other academic evaluation disputes. Following are the procedures for the correction of records. It is expected that students will pursue resolution of any dispute about the content or correction of a student record through the less formal procedure described in XI.A before proceeding to a formal hearing process (XI.B).
A. Students are entitled to an explanation of any information contained in records to which they have a right of access under this policy. If a student believes his or her records are inaccurate, misleading, inappropriate, or otherwise in violation of his or her right of privacy, he or she may request of the record custodian of the University office maintaining the records that the records be amended. The written request should identify the part of the record the student wants changed, should specify the reason the student believes it is inaccurate, misleading or in violation of his or her privacy rights, and should indicate the nature of the change or amendment desired. If the request is granted, the records shall be amended by the unit responsible for their maintenance within a reasonable period of time following receipt of the request. If the request is denied, the student shall be informed of the refusal and advised of the right to a hearing.
B. Hearings shall be held pursuant to the following procedure:
1. A student should direct a request for hearing to the Office of the Vice President for Student Affairs. The hearing shall be held within a reasonable period of time after it has been requested, and the student shall be notified of the date, place and time in reasonable advance of the hearing; the student shall also be notified of the hearing official assigned to the hearing;
2. The hearing shall be conducted and the decision rendered, by a campus official or other party who does not have a direct interest in the outcome of the hearing. The hearing official shall be appointed by the Vice President for Student Affairs or his/her designee;
3. A student shall be afforded a full and fair opportunity to present evidence and information relevant to the issues raised under this section, and may be assisted or represented by individuals of the student's choice, whether legally trained or not, at the student's own expense;
The custodian of the record(s) in question, or his/her designee, shall be afforded the opportunity to explain the denial of the student's request for amendment of the record(s), to respond to evidence and information presented by the student, and to present relevant information and evidence on behalf of the unit responsible for the record. If the student is assisted or represented by legal counsel, the custodian of the record(s) or his/her designee may also be assisted or represented by legal counsel.
4. The decision rendered shall be made in writing within a reasonable period of time after the conclusion of the hearing; and
5. The decision shall be based solely on the evidence and information presented at the hearing and shall include a summary of the evidence and the reasons for the decision.
C. If, as a result of the hearing, it is decided that the information is inaccurate, misleading, inappropriate, or otherwise in violation of the privacy rights of the student, the record shall be amended accordingly and the student informed in writing of the action taken.
D. If, as a result of the hearing, it is decided that the information is not inaccurate, misleading, inappropriate, or otherwise in violation of the privacy rights of the student,
the student shall be so informed of the right to insert into the, record a statement commenting upon the information in the record and/or setting forth any reasons for disagreeing with the decision to leave the record unchanged. Such statement shall remain a permanent part of the record as long as the contested portion remains a part of the record, and it shall be revealed to any party to whom the contested portion is revealed.
In either event, the decision resulting from the hearing will represent the University's final decision concerning the challenged record.

Revised April 2002