What is FERPA?
FERPA is the Federal Educational Rights and Privacy Act. This law ensures that a student’s educational records are protected. Only the student may access his/her educational records (including financial information) without expressed written consent from the student.
A student may grant permission for another person to access his/her educational records by completing the FERPA Permissions Form found in MyKC. These permissions remain in effect as long as the student is enrolled at the College. These permissions may be revoked at any time by submitting a new FERPA Permissions form in MyKC and deselecting the previously chosen access options.
FERPA Policy Statement
- the right to inspect and review information contained in educational records;
- the right to request amendment of educational records to ensure they are not inaccurate, misleading, or otherwise in violation of privacy or other rights;
- the right to consent to disclosure, with certain exceptions that are specified in the Act (see below under Directory Information), of personally identifiable information contained in educational records;
- the right to be apprised of this policy on an annual basis;
- the right to file complaints with the Department of Education concerning alleged failure of the College to comply with the Act.
No one other than the student is granted access to the student’s educational records unless the student has granted that person permission through MyKC, the College’s student portal. Students have the opportunity to grant and remove permissions at any point after their initial orientation day at Keystone College. Persons identified by the student will have access to the students educational records through a unique log on for MyKC. This access does not provide the ability for the designee to act on the student’s behalf.
FERPA allows the College to release certain “Directory Information” about our students without the need for a waiver. This information includes:
- full name
- College e-mail address
- telephone number
- date and place of birth
- degrees and awards received
- dates of attendance
- most recent previous school attended
- classification (first-year, sophomore, junior, or senior)
- participation in College-recognized activities and sports
- weight and height (members of athletic teams only)
- enrollment status (full- or part-time)
Directory Information does not include:
- Social Security number
- student identification number
A student can direct the College not to release her/his Directory Information by completing Directory Information Opt-Out Procedure and submitting appropriate form in the Registrar’s Office. The College accepts no liability for any Directory Information released before a student completes this form.
Keystone College does not publish Directory Information to vendors. A student’s educational records may not be released without the student’s specific written consent, with the following exceptions:
- to College officials, including instructors, who have a legitimate educational interest and need to know;
- to officials at institutions at which the student is seeking to enroll;
- to the parents of a dependent student as defined by the Internal Revenue Code;
- upon receipt of a lawfully issued subpoena or court order;
- in a health or safety emergency; or
- in any other circumstances permitted by the regulations of the U.S. Department of Education.
Billing and Grade Reports
Bills are sent in the student’s name directly to the permanent address listed for the student. For students who have signed waivers, grade reports (mid-term and final) are mailed to the person(s) listed on the waiver upon request. Mid-term grades are unofficial records of student performance and attendance up to that point in the semester. It should be noted that mid-term grades are assigned only for the purpose of informing students of their progress. Only final grades become part of a student’s official transcript.
Student Access to their Records
In accordance with FERPA, students, upon request, will be given access to all of their evaluative or opinion records established by Keystone College. Such records include those maintained by the Registrar, Career Services, and the Office of the Vice President of Student Affairs and Dean of Students, and Dean of Students. These records will be open to inspection in the presence of the appropriate College official. A student must make an appointment at least one day in advance to review his/her records. The College will also maintain, as part of the student’s education records, a list of all outside people or agencies who have had access to the student’s records without the student’s prior consent.
Information Students May Not Access
The following information will not be released to any student:
- letters of reference and recommendation placed in a student’s file prior to January 1, 1975;
- confidential letters and statements of recommendation placed in the student’s education records after January 1, 1975, if the student has waived his or her right to inspect and review those letters
- and statements and those letters and statements are related to the student’s admission to an educational institution, application for employment, or receipt of an honor or honorary recognition;
- parents’ financial records, unless written authorization has been obtained from the parents;
- private notes created by College officials to serve as memory aids.
Other Types of Information
FERPA deals with students’ educational records. The College maintains other records on current and former students (such as medical records, counseling records, employment records of students working for the College, and alumni records). These other records, while not specifically covered by FERPA, are still carefully safeguarded in order to protect privacy rights. Specifically, medical records are covered by HIPAA (Health Insurance Portability and Accountability Act) and Keystone’s Student Counseling and Well-Being Center follow these regulations. In addition, our Office of Human Resources follows all regulations pertaining to the employment of a student. For information on records not covered by FERPA, the student should contact the appropriate office.
Definition of Terms in this Policy
A “College official” is:
- a person employed by the College in an administrative, supervisory, academic, research, or support staff position;
- a person employed by or under contract to the College to perform a special task, such as an attorney or auditor;
- a person serving on the Board of Trustees; or
- a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another school official in performing his or her tasks.
A College official has a “legitimate educational interest” if the official is:
- performing a task that is specified in his/her position description or by a contract agreement;
- performing a task related to a student’s education;
- performing a task related to the discipline of a student; or
- providing a service or benefit relating to the student or student’s family, such as health care, counseling, academic or job placement, or financial aid.
Dissemination of this Policy
FERPA requires that students be notified and reminded of this policy annually. Therefore, this policy will be published in the Student Information Guide, and on the College’s web site. In addition, students will be reminded of the policy once each semester by way of campus-wide e-mails and notices in billing statements.
Amending Educational Records and Registering Complaints
Under FERPA regulations, Keystone College must allow students to inspect and review their educational records. A student may seek to amend those records if he or she thinks the records contain inaccurate or misleading information contained in them. However, the College is not required to consider requests for amendment that seek to change a grade or disciplinary decision, or to seek to change the opinions or reflections of a school official or other person reflected in an educational record. In addition, students have the right to file a complaint with the US Department of Education if they feel their rights under FERPA have been compromised. Any student wishing to pursue such issues should contact the Registrar’s Office for appropriate processes, forms, and addresses.
Sources Consulted in Developing this Policy
FERPA Opt-Out Procedure
The Family Educational Rights and Privacy Act (FERPA), a Federal law, required that Keystone College, with certain exceptions, obtain your written consent prior to the disclosure of personally identifiable information from your education records. However, Keystone College may disclose appropriately designated “directory information” without written consent, unless you have advised us to the contrary in accordance with College FERPA policy. The primary purpose of directory information is to allow Keystone College to include this type of information from your education records in certain school publications. Examples include:
- A playbill, showing your role in a theatre production
- Honor roll or other recognition lists
- Commencement programs and news releases
- Sports activity sheets, such as for baseball, showing weight and height of team members.
Directory information, which is information that is generally not considered harmful or an invasion of privacy if released, can also be disclosed to outside organizations without your prior written consent. Outside organizations include, but are not limited to, federal and state agencies offering jobs and educational benefits, media sources, companies that manufacture class rings or publish yearbooks, etc.
In addition, two federal laws require Keystone College to provide military recruiters, upon request, with your name, addresses, and telephone number unless you have advised us that you do not want your information disclosed without prior written consent.
Directory Information Opt-Out Procedure
If you do not want Keystone College to disclose directory information from your education records without your prior written consent, you must notify us in writing. Download and complete the FERPA Directory Information Opt-Out form and return it to the Registrar’s Office. Upon receipt, your information will not be released from the time of receipt forward. If directory information is released prior to receiving your opt-out request, Keystone College may not be able to stop the use of your information.
Keystone College has designated the following information as directory information:
- Full name
- College e-mail address
- Telephone number
- Date and place of birth
- Degrees and awards received
- Dates of attendance
- Most recent previous school attended
- Classification (first-year, sophomore, junior, or senior)
- Participation in College-recognized activities and sports
- Weight and height (members of athletic teams only)
- Enrollment status (full- or part-time)
Any student with a cumulative grade point average below 2.00 is on academic probation. Students who are on academic probation have one academic year to obtain academic good standing, provided they make progress toward good academic standing at the conclusion of the first fall or spring probationary grading period (possess a higher cumulative grade point average than the cumulative grade point average that placed them on probation initially). Students on academic probation may be required to participate in special academic programs.
Department of Academic Affairs
Students who are on academic probation due to low cumulative grade point average who also then fail to make progress towards good academic standing after one semester or fail to achieve good academic standing after one academic year are excluded from registration, and their academic records are marked “academic dismissal.” Unless reinstated by the Academic Review Board, students issued an academic dismissal are ineligible to attend any courses in any capacity offered by the College for a period of at least one academic year. At the conclusion of this period of separation, they are eligible to seek readmission. For information regarding an appeal of please refer to the College Catalog (Academic Dismissal)
Department of Academic Affairs
Verification of Student Identity in Online/Distance Learning Policy
In compliance with the provisions of the United States Federal Higher Education Opportunity Act (HEOA) of 2008, Public Law 110-315, concerning the verification of student identity in distance learning, Keystone College has established and will periodically evaluate its process to confirm that a person who has registered for a distance education course is the same student who participates in and receives academic credit for the course. This policy applies to all programs beginning with the application for admission and continuing through a student’s graduation, transfer, or withdrawal from the College.
According to the HEOA, one or more of the following methods must be used:
1. An individual secure login and password issued by the College
2. Proctored examinations and/or
3. Other technologies or practices that are effective in verifying student identification.
Any online student work, assessments or activities that are graded or contribute to a student’s grade must be submitted via a system that verifies the student’s identity as noted above.
All methods of verifying student identity in distance education must protect the privacy of student information in accordance with the Family Educational Rights and Privacy Act (FERPA) and any other applicable laws or regulations regarding the confidentiality of personally identifiable information. Personally identifiable information collected by the College may be used as the basis for identity verification. This information may include a combination of the following:
1. Student ID number
2. Last 4 digits of the student’s Social Security Number
3. At least 2 other pieces of information such as the student’s email address on file, date of birth, address, or user name.
During the application and admission process, student identity is vetted in accordance with standard practices. Students are responsible for providing their complete and true identity information in any identification verification process. Upon application, each student receives a unique and secure Keystone College user account. This user account allows the student to authenticate into nearly all Keystone College systems, including the Learning Management Systems Canvas and Moodle, email, student portal (MyKC), grades, etc. Students have the ability to change their password and are encouraged to do so periodically. All systems are secured in accordance with industry best practices. The College’s Information Technology department is responsible for creating user accounts using a FERPA compliant procedure.
All users of the College’s Learning Management System (LMS) and Student Information System (SIS) are responsible for maintaining the security of their login credentials. Credentials may not be shared or given to anyone other than the user to whom they were assigned for any reason. Users are responsible for any and all uses of their account. Users are held responsible for knowledge of the information contained within the most recent Student and Employee Handbooks and the Acceptable Use of Technology policy displayed and agreed to by the user when logging on to any College computer. Failure to read College guidelines, requirements and regulations will not exempt users from responsibility.
Faculty teaching courses through distance education methods hold primary responsibility for ensuring that students comply with the College’s identity verification policy. As technology and personal accountability are not absolute in determining a student’s identity, faculty members are encouraged to design courses that use assignments and evaluations that support academic integrity.
The Provost/Vice President for Academic Affairs is responsible for ensuring compliance with this policy and that department chairs and program coordinators are informed of any change in the policy in a timely fashion. Department chairs are expected to ensure that faculty within their departments remain in compliance. Instructors teaching courses through distance education methods are responsible to ensure that their individual courses comply. If necessary, the Provost/Vice President for Academic Affairs may address non-compliance through established methods.
Both the College’s Office of Admissions and the Office of the Registrar maintain student biographic, demographic, admission, and enrollment records in the College’s SIS. Access to this information requires valid College network credentials, in addition to authorization controls within the LMS and/or SIS.
All students participating in distance education courses offered by Keystone College must log in to their course sites using their Keystone College account credentials. This secure login is a student’s only means of access to the LMS. Students are registered in their courses through the SIS, which transmits registration information directly into the LMS without any action on the part of students, faculty, or staff beyond the regular registration process. Only duly registered students and the instructor of record appear on the roster of any distance education course. Furthermore, every action within a course site registers on the extensive tracking features of the LMS, which track each user in terms of time and duration of the action and part of the site involved, even if there is no posting by the students. In the LMS, the email system, and other applicable systems, students can associate a photo with their account, allowing for visual identification of the student. Technology for live audio and/or visual communication, which can be helpful in verifying student identity, is also available for faculty, staff, and students. Faculty can view official ID photo images of students as part of their class rosters in the SIS.
Plagiarism detection tools are available to help determine the identity of those who submit the work. Exams can require a passcode as offered to students by the instructor.
Users may not create their own courses or accounts, ensuring that only those with valid user accounts may access the system and that users may only access resources designated to their user accounts.
Keystone College does not charge a fee for student identity verification.
Sources consulted in developing this policy:
Approved by: Provost & Vice President for Academic Affairs, November 2020
All other academic and student affairs policies can be found in the College Catalog or the Student Handbook on our policies page.