Policy Governing the Maintenance of Student Records

It is the policy of Howard University that: Students should have access to information about themselves in the University record-keeping systems. Individual students shall be accorded the right to correct or amend, upon reasonable request, an inaccurate record. Information contained in a student's educational record file shall not be disclosed or used for other than authorized University purposes without his or her written consent, unless required by law. Student files shall be retained for a reasonable period of time. The Office of the Vice President for Student Affairs is hereby charged with the responsibility of implementing the policy within the following guidelines.

Guidelines

1. Confidential Nature of Student Records

Student educational records, except as herein set forth this policy statement, shall be kept confidential, with respect to requests made by all persons other than appropriate school officials, as determined by the President or other executive level officers of the University or parents of a dependent student, as defined for income tax deduction purposes in Section 152 of the U.S. Internal Revenue Code.

2. Release of Information to Investigators

When written consent has been received by the University from a student who is the subject of a governmental or employment investigation, information requested by such investigator from records of such students may be released through authorized staff personnel of the University within whose offices such records are maintained upon proper identification of the investigator. Investigators must adequately identify themselves through the display of credentials, must indicate the agency they represent and demonstrate a satisfactory basis for their request. Information in student records not yet released will be withheld if a student timely notifies Enrollment Management/ Records in writing that he or she has withdrawn his/her prior consent student consent forms with reference to their educational records be filed with the Dean of Admissions and Records will in turn notify appropriate offices of the University that such consent has been given and in the event such consent is withdrawn will direct these offices to discontinue release of such information.

3. Student Educational Records

The Office of the Vice President for Student Affairs shall prepare annually a list of the various categories of student educational records at the University. This list shall be promulgated in such a way as to afford students an opportunity to know of the kinds of records kept and their location. The list shall contain a summary explanation of the kinds of records kept under each category (i.e., Academic Records, et cetera), and the cost, it any, which will be charged to the parent or student for reproducing copies of such records. It shall be known as the Student Educational Records List.

4. Student Addresses and Telephones

Officers and employees of the University will not normally release addresses or telephone numbers of students to persons not officially connected with the University. There may be an exception in cases of emergencies. Requests under claimed emergencies will be referred to the Office of the Dean for Special Student Services or the Office of the Dean of Residence Life for the purpose of making a judgment as to whether, under the circumstances, such information should be released.

5. Student Review of Records

A student may make a written request to review an educational records of a type found on the Student Educational Record List at any appropriate University office at any reasonable time. Upon receipt of such request, the office involved will make the arrangements necessary for review of the records as soon as practicable. A student may waive in writing the right to review letters of recommendation written in his or her behalf or at his or her request which have been placed in his or her educational record after January 1, 1975.

If a student challenges the contents of his or her student educational records on the grounds that they are either inaccurate, misleading or otherwise recorded in violation of his or her rights, he or she shall be accorded a hearing in order to provide an opportunity for the correction or deletion of any inaccurate, misleading or otherwise inappropriate data contained therein, and to insert into such record, where found to be warranted, a written explanation from an appropriate source respecting the content of such records. The hearing shall be conducted by a person designated by the President of the University or his designee. Such person shall not have a direct interest in the outcome of the hearing. It should be expressly understood that such a hearing is not to be used as a forum to contest whether a teacher should have assigned a higher grade because a student or parent believes that the student was entitled to a higher grade.

6, Records Not Subject to Review

Records maintained by the University with respect to which a student does not have a right of review include but are not limited to instructors' or administrators' notes, financial statements submitted by parents in support of applications for financial aid, and letters of recommendation received by the University prior to January 1, 1975.

7. Faculty Review of Student Academic Record

Individual faculty members may review academic records of their students with the students' consent, except that such consent shall not be necessary for faculty members who serve as advisers and other administrative officers or counselors of the University in the discharge of their official functions.

8. Research Involving Student Records

The University recognizes research by graduate students, faculty, and administrative staff as a fundamental component of its overall mission. Occasionally such research involves the use of data which is to be extracted from student records which are essentially confidential. Approval to conduct such research must first be obtained from the person in charge of the involved discipline(s) and, following this, authorization to utilize student records must be obtained from the administrative officer under whose jurisdiction the records which are to be utilized are maintained. In such instances the administrative officer maintaining custody of such records shall make every effort to insure the anonymity of identifying information contained in the records utilized.

9. Removal of Records from Custodial Office

Except, as required, in cases involving litigation, a student's permanent academic records may not be removed from the Office of the Dean of Admissions and Records. Copies of the content of such records may be made available to administrative staff officials in conducting official business involving such records.

10. Retention of Student Records

Admissions applications (of individuals who actually enroll) and academic records shall be maintained indefinitely by the Office of Enrollment Management/Records.

Records of student financial indebtedness to the University shall be maintained on an indefinite basis.

Health records on students shall be kept for a period of five years after graduation or anticipated date of graduation.

Student personnel records shall be retained for two years following graduation.

Disciplinary records of students involving sanctions less than expulsion or indefinite suspension shall be maintained by the Office of the Vice President for Student Affairs for a period of five years following the graduation of such individuals except that in cases where the student does not graduate, the record shall be maintained for a period of eight years following the last enrollment. Records of students who are expelled or suspended indefinitely, whether for academic, health, or disciplinary reasons, shall be maintained on an indefinite basis.

Records of convictions of students who are convicted in civil courts of (1) misdemeanors involving moral turpitude, and (2) all felonies may be retained by the Office of the Vice President for Student Affairs for a period of five and eight years respectively, following such convictions.

11. Requests for Judicial Process

When any subpoena or other judicial order is issued -requesting information about a student, the officer receiving the order or subpoena shall immediately contact the Office of the General Counsel.

Approved by the Board of Trustees September 27, 1975.