Policy Governing the Maintenance of Student Records, the Rights of Students Regarding Such Records, and the Release of Information on Students to Third Parties
Approved by the Board of Trustees, September 27, 1975
It is the Policy of The Board of Trustees of Howard University that:
Students should have access to information about themselves in the University record-keeping systems. An individual student shall be accorded the right to correct or amend, upon reasonable request, an inaccurate record. The 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
Confidential Nature of Student Records—Student educational records, except as herein set forth in 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.
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 or 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 official credentials, must indicate the agency they represent and demonstrate a satisfactory basis for their request. Even as to such investigators, information in student records, not priority released will be withheld if a student timely notifies Office of the Registrar in writing that he or she has withdrawn his or her prior consent. Student consent forms with reference to their educational records should be filed with the Office of the Registrar that 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turn, notify appropriate offices of the University that such consent has been given and in the event, such consent is withdrawn will direct these offices to discontinue release of such information.
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 extant in the University. This list shall be promulgated in such ways 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 (e.g., Academic Records), and the cost, if 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.
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.
Student Review of Records
A student may make a written request to review an educational record of a type found on the Student. Educational Record List at any appropriate University office at any reasonable time. Upon receipt of such requests, the office involved will make the arrangements necessary to accommodate requests for review of student records as soon thereafter as practicable. A student may waive in writing the right to review letters of recommendation written on his or her behalf or at his or her request which has 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.
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.
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 advisors and other administrative officers or counselors of the University in the discharge of their official functions.
Research Involving Student Records
The University recognizes research by graduate students, faculty, and administrative staff as a fundamentalcomponentofitsoverallmission. Occasionallysuchresearchinvolvestheuseofdata that 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 ensure the anonymity of identifying information contained in the records utilized.
Removal of Records from Custodial Office
Except, as required, in cases involving litigation, a student’s permanent academic record may not be removed from the Office of the Registrar. Copies of the content of such records may be made available to administrative staff officials in conducting official business involving such records.
Retention of Student Records
Admission applications (of individuals who actually enroll) and academic records shall be maintained indefinitely by the Office of the Registrar. 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.
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.
Administrative Procedures Relating to the Rights of Students Regarding Records Maintained on them by Howard University
- The University will at least annually, provide notice to students, of the following:
- the types of educational records and information contained therein directly related to students and maintained by the University;
- the name, position, and campus location of the official responsible for the maintenance of each type of record to which students have a right of access; and
- the categories of information, if any, which the University has designated as directory information.
- A student desiring to review a reviewable University record shall execute in writing a form entitled “Request for Review of Student Record” obtained from and provided by the office concerned. A record of all requests for review of records by students, including the disposition thereof, shall be maintained by all offices of the University in which such requests are made. In instances in which a student requests a review of the contents of a University record, the office involved shall provide for such review with an appropriate official of the office within a reasonable time. Costs incurred in connection with furnishing a student a copy of anything contained in the University record and requested by such student will be borne by the student. Such appropriate costs will be established by the Vice President for Fiscal Affairs in consultation with the Vice President for Student Affairs.
- A student, who after having reviewed a University record, is of the opinion that such record contains information or material that is inaccurate, misleading or should not be maintained by the University, must first execute in writing a form entitled, “Request for Purge/Removal of University Record” obtained in the office concerned. Upon the receipt of such request, the administrative officer of the office involved shall carefully review the request and make an appropriate disposition.
In considering such request, the University official(s) involved will make a diligent effort to resolve the matter informally, amicably and in the best interests of the student and the University. If the student making the request objects to the action taken, he/she may request in writing a hearing in which the propriety of the action taken may be contested. 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 believes that he or she was entitled to a higher grade. - Upon notice that the student wishes to have a hearing, the office involved shall notify in writing the Office of the General Counsel of the University. A hearing officer, for the purpose of hearing appeals requested by students, shall be designated by the Office of the General Counsel. The hearing officer shall schedule the date, time and place of such hearing. Upon notice from the hearing office, the Dean or Director of the office involved shall provide written notification to the student as to the date, time and place of the hearing. The Dean or Director will select one person to be the University representative at such hearing.
- At all such hearings, the student and the University representative will be accorded the following procedural rights:
- Advance notice of the date, time, and place of the scheduled hearing
- Personal appearance
- To present their case or have the same presented in their behalf by anyone of their choice;
- To present evidence and to call witnesses.
- The hearing officer will render a written decision and provide the student petitioner and the University representative with a copy of the decision within a reasonable period following the conclusion of the hearing. Where the student involved receives an adverse decision, he shall have a right to petition the Vice President for Student Affairs for an appeal. Both the student and the University representative may submit a written argument in support of their position. The Vice President for Student Affairs may decide on the petition that no further hearing of the matter is required or he may decide to reopen the matter and hear the case over again. Where the Vice President for Student Affairs determines that there need be no further hearing, the decision rendered by the hearing officer will be final. Where the Vice President for Student Affairs decides to reopen the case, the decision rendered by him shall be final.
Student Educational Record List
Records the University maintains on students are described and listed below. Offices maintaining such records are specified and their locations indicated. These offices are open Monday through Friday (except holidays) from 8:30 am until 3:00 pm.
Academic records — Academic records on students contain applications for admission, (including applications for readmission), the Howard University permanent record (containing all grades duly recorded), instructors’ grade reports, and copies of official forms or reports reflecting, special grade reports and records of all total withdrawals from the University by students. The above records are maintained by and located in Office of the Registrar, Suite 104, Mordecai Wyatt Johnson (Administration) Building.
Special Note on Academic Records
Records bearing directly on the academic status of students are also maintained in the offices of the appropriate academic Dean, the department in which students’ major programs are supervised and coordinated as well as the offices of student advisors of the respective schools and colleges in which such students are enrolled. These records generally include SAT (Scholastic Aptitude Test) and CEEB (College Entrance Examination Board) scores, high school transcripts, college/university transcripts for institutions previously attended, high school equivalency (GED) scores and certificates of completion (in specialized areas), and the like, such as-in the case of international students-a certificate evidencing adequate familiarity with the English language. The locations of these specific offices may be ascertained by inquiring at the office of the appropriate academic Dean.
Violations of the University Code of Conduct and Criminal Laws Records
Records on individual students who have been implicated in violations of the University Code of Conduct and/or locally operative criminal laws and as a result of which the University Office of Security and Safety Services has become involved. Records of the above-listed incidents are maintained by and are located in the Office of Security and Safety Services, 2nd floor, Service Center Building, 2244 10th Street NW (202-806-1073).
Disciplinary Records, Student Misconduct Records, and Records of Infractions of Code of Conduct
Records of student conduct involving infractions of conduct standards established for students are maintained by and are located in the Office of the Dean for Special Student Services, Room 725, Howard Center, 2225 Georgia Avenue.
Financial Aid Records
Financial aid records of students contain applications for financial aid or part-time employment (including work study), credentials submitted in support of such applications’ loans as well as information on action taken on such applications. These records are maintained by and are located in Financial Aid. Records of specialized financial aid which is pursued through direct application to departments of one’s specialization are maintained by and located in such departments.
Student Financial Services
An individual’s account record reflects all financial transactions made with the University in connection with the payment of required tuition, fees, room rent, and special assessments such as library book charges, and the like. Any adjustment made in the account, for whatever reason, is similarly reflected. This record is maintained by and located in Student Financial Services/Student Accounts, Suite 115, Administration Building.
Student Employment
Records are maintained on students who apply for employment through the Office of Career Planning and Placement. These records contain the subject’s resume and letters of recommendation, if any, such as are submitted at his/her request. Such records are maintained by and are located in the Office of Career Planning and Placement, Wing I, Second Floor, C.B. Powell Building. Members of the faculty, student body, or staff who have questions regarding the information above are invited to inquire at the Office of the Dean for Special Student Services, Room 725, Howard Center on the main campus, or by telephone at (202) 806-2120.