FERPA Reference Guide for Faculty

FERPA regulates both the information that faculty can distribute and access about students. This page outlines the responsibility of faculty members to keep student records secure under FERPA requirements.

Overview

The Family Educational Rights and Privacy Act of 1974, as Amended (FERPA) requires institutions accepting federal monies to protect the privacy of student information. In addition, FERPA affords students the right to review their education records, to request correction of inaccurate records, and to limit information disclosure from those records. An institution’s failure to comply with FERPA may result in the Department of Education withdrawal of federal funds.

All UC faculty and staff are obliged to comply with FERPA regulations. 

Types of Student Information

As a faculty member, you need to know the difference between Directory InformationPersonally Identifiable Information, and Education Records.

Directory Information

Directory information may be disclosed, unless the student has requested otherwise. Please refer such requests to your department office or to the Registrar’s Office. The following items fall under the directory information category.

  • Name
  • Current mailing address
  • Current telephone number
  • UC email address
  • College
  • Class
  • Major
  • Dates of attendance
  • Enrollment status (full–time/half–time/part–time)
  • Degrees/honors/awards received

Personally Identifiable Information

Personally Identifiable Information may be released only to the student, as long as the student has produced the proper identification. Parents and spouses must present the student’s written and signed consent authorizing UC to disclose Personally Identifiable Information or must have been provided delegated access by the student within the Catalyst student portal. In all cases, refer requests to the Registrar’s Office. The office will review authorization documents, consult the instructor and other offices as necessary, and release information as appropriate.

The following items are considered to be Personally Identifiable Information, but this list is by no means exhaustive.

  • Social Security Number
  • Date of birth
  • Residency status
  • Gender
  • Race
  • Ethnicity
  • Religious preference

Education Records

Educational Records may be released only to the student, as long as the student has produced the proper identification. Parents and spouses must present the student’s written and signed consent authorizing UC to disclose Educational Records or must have been provided delegated access by the student within the Catalyst student portal. In all cases, refer requests to the Registrar’s Office. The office will review authorization documents, consult the instructor and other offices as necessary, and release information as appropriate.

The following items are considered to be Educational Records, but this list is by no means exhaustive.

  • Class schedule
  • Grades
  • GPA
  • Academic standing
  • Test scores
  • Academic transcripts

Best Practices for Protecting Student Information and Education Records

  • Do not leave exams, papers, or any documents containing a SSN/UCID/Username, grade, evaluation, or grade point average outside your office door or in any area that is open–access.
  • Do not record attendance by passing around a class list, which contains the student’s SSN/UCID/Username.
  • Do not provide tests and assignments scores, evaluations or final grades via email.
  • When contacted by phone, first ask identifying questions (e.g., “What was your mid-term score?” but not “What is your UCID?”).

Posting Grades

Under FERPA, student grades must not be released or made available to third parties.  

Instructors therefore are restricted from posting grades in classrooms (except as follows), on websites, and/or online course management systems unless the student’s identity is concealed by a secure student identifier and password entry interface. Do not post grades by SSN/UCID/Username (neither in whole nor in part).

Posting Grades in Public

  1. Ask the student to supply you with a self–chosen code identifier. This identifier may be known only to you or your teaching assistant; or
  2. You may create and assign a unique list of randomly generated numbers/characters known and available only to you (or your teaching assistant) and the student.

For each option above, arrange the grade list so students do not fall in alphabetic order. 

Records Access by University Personnel

As a faculty member, you may be allowed access to a student’s educational records if you can establish legitimate educational interest for the request, meaning that you need the information to fulfill a specific professional responsibility.

The following is a list of information items that are not considered educational records and therefore are not subject to a student’s request for review.

  • Law–enforcement records
  • Medical treatment records
  • Alumni records
  • Records maintained exclusively for individuals in their capacity as employees. Records of those who are employed as a result of their status as students (i.e., work-study, student workers, etc.), however, are considered educational records.
  • Sole–source/sole–possession documents: these are notes (memory joggers—not grade or GPA related) created and maintained by you, meant for your personal use exclusively. So long as no one other than you ever reads these notes they remain private and are not subject to FERPA. If you share them with another person, regardless of the reason, these notes no longer are considered “sole source.” They become part of the student’s educational record and are subject to disclosure under FERPA.

Grade books are not considered “sole source” documents under FERPA and must be made available to written student requests for record disclosure. If a student requests grade book disclosure, all notations pertaining to other students would be stripped out of the pages provided for review.

More Information and/or FERPA Consultations

Douglas K. Burgess, PhD
Assistant VP & University Registrar
513-556-9930
douglas.burgess@uc.edu

Lorren J. Ratley
Director Privacy, Office of the General Counsel
513-558-2733
lorren.ratley@uc.edu