Faculty Guidelines
Please be aware that, if requested, every student has the legal right to review all educational records maintained by the university about that student. This includes any faculty comments and/or assessments related to admission, academic performance, etc.
Posting Grades
The public posting of grades either by the student’s name, institutional student identification number or Social Security number, without the student’s written permission, is a violation of FERPA. Even with names obscured, numeric student identifiers are considered personally identifiable information and therefore violate FERPA. Instructors can assign students unique numbers or codes that can be used to post grades. However, the order of the posting must not be alphabetic.
Returning Assignments
Leaving personally identifiable, graded papers unattended for students to view is no different from posting grades in the hallway. If these papers contain “personally identifiable” information, leaving them unattended for anyone to see is a violation of FERPA if the instructor has not obtained the written permission of each student to do so. Possible solutions include leaving the graded papers (exams, quizzes, and homework) with an assistant or secretary who would ask students for proper identification prior to distributing them; or leaving them in a sealed envelope with only the student’s name on it.
Sending Grades to Students
Instructors can notify students of their final grades via the U.S. mail if the information is enclosed in an envelope. Notification of grades via postcards violates a student’s privacy. Notification of grades via email is permissible. However, there is no guarantee of confidentiality.
Access to Student Records
Faculty members are normally considered “school officials” but do not have access to student academic records unless their normal job duties specifically require access. The faculty member will have to demonstrate “a legitimate educational interest” in their request to access student records, such as advising students, retention study, etc.
Parents Requesting Information
Such things as progress in a course, deficiencies in a subject area, scores and grades on papers, exams, etc. are all examples of personally identifiable information that make up part of the student’s education record. This information is protected under FERPA, and parents may not have access unless the student has provided written authorization that specifically identifies what information may be released to the parents.
Crisis Situations and Emergencies
If non-directory information is needed to resolve a crisis or emergency situation, an education institution may release that information if the institution determines that the information is “necessary to protect the health or safety of the student or other individuals”. Factors considered in making this assessment are: the severity of the threat to the health or safety of those involved; the need for the information; the time required to deal with the emergency; and the ability of the parties to whom the information is to be given to deal with the emergency.
Letters of Recommendation
Written permission of the student is required for a letter of recommendation if any information included in the recommendation is part of the “education record” (grades, GPA and other non-directory information).
Questions or Concerns
General questions may be directed to the Office of the General Counsel or the Office of Compliance, the Office of the Vice President for Student Affairs, the Office for Student Conduct or the Office of the Registrar, as appropriate.
Comments or suggestions should be addressed to the USC Registrar’s Office, registrar@usc.edu, (213) 740-4623, MC 0912.
Staff Guidelines
Who Can Release Student Information
An institution may disclose personally identifiable information without the student’s written consent to “school officials” the institution has determined to have a “legitimate educational interest”.
Obligation to Release Record Information
An institution is not obligated to release directory information to anyone. FERPA only says that an institution MAY release information. When in doubt, do not release information.
Deceased Students
The privacy rights of an individual expire with that individual’s death. Records held by an institution for a deceased person are not a FERPA issue but a matter of institutional policy. USC will exercise its own discretion in deciding if, and under what conditions, information should be disclosed to survivors or third parties.
Student Workers
FERPA does not preclude an institution from identifying students as “school officials” with a “legitimate educational interest” for specific purposes. The same requirements and responsibilities for a full-time school official exist for student workers. Student workers must receive FERPA training just as if they were faculty or staff.
Fraternities and Sororities
Many fraternities and sororities maintain scholarship committees, academic excellence award programs and related types of activities based on personally identifiable information. However, fraternity and sorority members in charge of these activities are not “university officials” and may not have access to student record information, unless the student has provided written authorization.
Financial Holds
Students have the right to inspect the contents of their student folder, regardless of their financial status with the institution.
Subpoenas
At USC, all subpoenas are first reviewed by the Office of General Counsel to determine the appropriate course of action.
Crisis Situations and Emergencies
If non-directory information is needed to resolve a crisis or emergency situation, an education institution may release that information if the institution determines that the information is “necessary to protect the health or safety of the student or other individuals”. Factors considered in making this assessment are: the severity of the threat to the health or safety of those involved; the need for the information; the time required to deal with the emergency; and the ability of the parties to whom the information is to be given to deal with the emergency.
Questions or Concerns
General questions may be directed to the Office of the General Counsel or the Office of Compliance, the Office of the Vice President for Student Affairs, the Office for Student Conduct or the Office of the Registrar, as appropriate.
Comments or suggestions should be addressed to the USC Registrar’s Office, registrar@usc.edu, (213) 740-4623, MC 0912.