All officials of Sinclair Community College will follow a strict policy that information contained in a student’s education record is confidential and may not be disclosed to third parties without the student’s prior written consent except as otherwise provided in this section of Sinclair Community College’s Student Records Policy.
The College maintains student education records in order for the administrative staff and the faculty to perform their proper functions to serve the student body. To carry out their responsibilities, these officials will have access to student education records for legitimate educational purposes.
To establish who are College officials having access to education records, Sinclair Community College will apply the criteria listed below. An official is:
A College official is a person employed by the College in an administrative, supervisory, academic, research, or support staff position (including law enforcement personnel); a person or company with whom the College has contracted or otherwise designated as its agent to perform a service on behalf of the College (such as an attorney, auditor, or collection agent); a person serving on the Board of Trustees; or a volunteer or student serving on an official committee, such as a disciplinary committee or advisory committee, or assisting another College official in performing his or her tasks.College officials who meet the criteria listed above will have access to personally identifiable information contained in student education records if they have a legitimate educational interest in doing so. A College Official has a “legitimate educational interest” if the College Official needs to review an education record in order to fulfill his or her employment and/or professional responsibilities for the College.Within the general policy that College officials must secure a student’s prior written consent before they disclose personally identifiable information contained in the student’s education records, Sinclair Community College has the right for its officials to make such disclosures without the student’s consent in the following circumstances:1. When certain Federal and State officials need information in order to audit or enforce legal conditions related to federally-supported education programs at the college.2. To parties who provide or may provide financial aid to the student in order to:a. Establish the student’s eligibility for the aid;b. Determine the amount of financial aid;c. Establish the conditions for the receipt of the financial aid; ord. Enforce the terms of the agreement between the provider and the receiver of the financial aid.3. Sinclair Community College will continue to disclose the specific items of personally identifiable information contained in a student’s education record which a State law adopted prior to November 19, 1974, required it to disclose to State or local officials.4. When Sinclair Community College has entered into a written agreement or contract for an organization to conduct a study on the college’s behalf to develop tests, administer student aid, or improve instruction.5. To persons or organizations conducting studies for educational agencies or institutions to develop tests, administer student aid, or improve instruction; provided the study is conducted in a manner that does not permit disclosure of personally identifiable information to third parties (other than the person or organization conducting the study), and the personally identifiable information is destroyed when no longer needed for the study.6. To accrediting organizations to carry out their accrediting functions.7. To parents of a student if the parents claim the student as a dependent under the Internal Revenue Code of 1954.Sinclair Community College will exercise this option only on the condition that evidence of such dependency is furnished to the FERPA Coordinator, and all requests for disclosures under this provision are referred to that office.8. To comply with a judicial order or lawfully issued subpoena. The College will make a reasonable effort to notify the student before it makes a disclosure under this provision.All requests for disclosure under the eight circumstances listed above (where the college may disclose information without prior consent to third parties other than its own officials) will be referred to the FERPA Coordinator. The FERPA Coordinator will approve or disapprove the request and an official may not make the disclosure unless it is approved. In health or safety emergencies, Sinclair Community College authorizes its officials to make provided disclosures from student educational cords, if the official deems:1. The disclosure to be warranted by the seriousness of the threat to the health or safety of the student or other persons;2. The information to be necessary and needed to meet the emergency;3. The persons to whom the information is to be disclosed to be qualified and in a position to deal with the emergency, and;4. Time to be an important and limiting factor in dealing with the emergency.Officials of Sinclair Community College may not disclose personally identifiable information contained in a student’s education record (except directory information or under the circumstances listed above) except with the student’s prior written consent. The written consent must include at least:1. A specification of the information the student consents to be disclosed;2. The purpose for which the disclosure may be made;3. The person or organization or the class of persons or organizations to whom the disclosure may be made; and,4. The date of the consent and, if appropriate, a date when the consent is to be terminated.The student may obtain a copy of any records the college discloses by the student’s prior written consent.Sinclair Community College will not release information contained in student’s education records, except directory information, to any third parties except its own officials, unless those parties agree that they will not redisclose the information without the student’s prior written consent.