Understanding Brown University Directory Information and FERPA

The Family Educational Rights and Privacy Act of 1974 (FERPA) grants students specific rights regarding their education records, including access, privacy, and protection. These rights become particularly relevant as students transition to higher education. This article outlines how FERPA applies to Brown University, detailing student rights, directory information, and procedures for managing education records.

Student Rights Under FERPA

FERPA affords students several key rights concerning their education records at Brown University:

Right to Inspect and Review: Students have the right to inspect and review their education records within 45 days of the University receiving a request. Current undergraduate students can access many records through Banner or ASK. For other records, a written request specifying the desired documents should be submitted to the Office of the Registrar. A general request for "all records" is usually insufficient.
Right to Amend: Students can request the University to amend education records they believe are inaccurate, misleading, or in violation of their privacy rights. Such requests should be directed to the University official responsible for the record, clearly identifying the part of the record to be amended and providing supporting evidence. The University will consider the request, but is not obligated to comply. If the University denies the amendment, the student has the right to a hearing. If the University still denies the change after the hearing, the student can insert a statement in the record commenting on the contested information or explaining their disagreement with the University's decision. It's important to note that the FERPA amendment procedure is for correcting factual inaccuracies, not for challenging grades, opinions, or substantive decisions about a student.
Right to Privacy: Students have the right to control the disclosure of their education records to third parties. Generally, the University requires prior written consent from the student before disclosing information from their education record, with certain exceptions outlined under FERPA.

What is Considered an Education Record?

It is important to define an education record. According to FERPA, an education record is any record that contains information directly related to a student and is maintained by an educational agency or institution or by a party acting for the agency or institution.

Exclusions from Education Records

Certain documents are excluded from student access under FERPA and are not considered education records. These include, but are not limited to:

Records of faculty and administration kept in their sole possession.
Records created and maintained by the Department of Public Safety for law enforcement purposes, if not maintained by other University units.
Employment records relating exclusively to an individual's capacity as a University employee.
Records of physicians, psychiatrists, psychologists, or paraprofessionals used only in connection with student treatment.
Records containing information about a student after graduation, withdrawal, or permanent separation from the University.
Financial records of a student's parents/guardians.
Confidential letters of recommendation for which the student has waived their right of access.

Disclosure of Education Records

As a general rule, a student’s education records may only be disclosed to third parties with the prior written consent of the student. However, there are some exceptions.

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Disclosures to University Officials

FERPA allows the disclosure of education records to University officials with legitimate educational interests. A University official includes employees in administrative, supervisory, academic, research, or support staff positions, including law enforcement and health staff. It also encompasses individuals or companies with whom the University has contracted, such as attorneys, auditors, or collection agents, as well as members of the Corporation and students serving on official committees. Parents or guardians may also be informed of significant changes in enrollment status under certain circumstances. Students can request exceptions to this rule in extenuating circumstances.

Compliance with Judicial Orders

The University may disclose education records to comply with a judicial order or a lawfully issued subpoena.

Directory Information and Directory Blocks

FERPA defines "Directory Information" as a subset of education records that can be released without a student's consent. At Brown University, students can restrict the release of Directory Information to third parties by initiating a directory block at any time.

Initiating a Directory Block

When a student initiates a directory block, their record is marked as confidential. This prevents the University from responding to any requests for information about the student, except when permitted or required under FERPA, such as in response to a subpoena. Changes to a directory block may take up to 24 hours to process and remain in effect until revoked by the student. The University honors requests to restrict Directory Information but cannot assume responsibility for contacting the student for subsequent permission to release the block.

Third-Party Requests and Transcripts

The University requires prior written consent to disclose information from a student’s Education Record to third parties (outside of the allowable methods under FERPA). The University does not share official transcripts through third-party requests for information and does not accept verbal, oral, or spoken consent as valid.

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FERPA Rights and Parental Access

When a student turns 18, is no longer a dependent for federal income tax purposes, or attends a postsecondary institution, FERPA rights transfer to the student. This can be a significant change for families as students begin college. Brown University encourages families to discuss open communication about student experiences, enrollment, and grades before the student begins attending the University.

Parental Access with Student Consent

Prior written consent from the student is required before the University can disclose information from a student’s education record to a parent or guardian outside of the allowable methods under FERPA. Students may also choose to disclose certain academic information directly with a parent or guardian by granting proxy access, initiating automated notifications, and controlling confidentiality settings in the Banner Self Service web portal.

Defining a Student Under FERPA

FERPA defines a student as an individual who has reached 18 years of age or is attending a postsecondary institution at any age. Brown University defines a student as an individual who is enrolled and actively attending the University.

Responsibilities

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. Brown University is a community in which employees are encouraged to share workplace concerns with University leadership.

Additional Information

The information provided above complements and supplements this document. The newly renovated, centralized home for the Pembroke Center for Teaching and Research on Women will enhance collaboration and expand the use of the center’s extensive archives. Forty years after joining Brown’s staff as a cook’s helper, Colarusso is a manager of structural projects in the University’s Department of Facilities and Campus Operations, helping to maintain the physical campus. In a letter to the White House, President Christina H. University leaders, faculty colleagues and former students shared reflections on Nobel Prize winner Peter Howitt’s contributions to the field of economics and to the Brown community. Brown’s renowned medical school offers an integrated medical curriculum alongside immersive clinical experiences, where students work with physician-scientists on the leading edge of biomedical innovation. Brown educates future leaders in the fundamentals of engineering in an environment of collaborative, world-class research centered on solving pressing global challenges. Brown’s School of Professional Studies offers executive education programs designed to advance the careers of accomplished professionals from across the globe. Brown is a leading nonprofit research university distinct for its student-centered learning and deep sense of purpose. Brown offers more than 80 programs, what some colleges call majors. You'll sample courses in a wide range of subjects before immersing yourself in one of these focused areas. Brown isn’t just a place where students study and learn. Readings and performances. Lectures and panels. Brown's campus is located in Providence, R.I. Spending the night in Providence?

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