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.”
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.
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.
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.
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.
Students have the right to inspect the contents of their student folder, regardless of their financial status with the institution. However, an institution is NOT REQUIRED to release an official transcript if the student has a past-due account.
At USC, all subpoenas are first reviewed by the Office of General Counsel to determine the appropriate course of action.
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 to be considered or questions to be asked in making a decision to release such information in these situations are: (1) the severity of the threat to the health or safety of those involved; (2) the need for the information; (3) the time required to deal with the emergency; (4) the ability of the parties to whom the information is to be given to deal with the emergency.
General questions may be directed to the Office of the General Counsel, 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.