Communicating with Other Employees
FERPA allows for a lot of information from a student's record to be shared with other employees of the university. This is based on the idea that a number of employees need access to student records in order to complete their job functions for the university. This is referred to in FERPA as "demonstrated need to know". For example, the Financial Aid office needs to be able to talk with the Bursar’s Office so each is able to process a student's financial records. Such communication is beneficial to the student and streamlines the process. Faculty are able to talk with each other about a student who is applying for an internship or independent study to confirm the student is a good candidate and has meet the necessary requirements. This is a regular part of the university conducting it daily business.
Not every employee has "need to know" access to every record. It is the responsibility of the record holder to review requests from other employees or departments for a student's record. If there is not a demonstrated need to know, the record holder is to deny the request, and when possible offer alternative solutions to the requester.
Where employees often get confused is what they can share not recorded in a grade book, or listed in SIS. The answer is quite a bit can be shared. FERPA allows for observed behavior, meaning a student's actions, or inactions, that are not recorded as part of an education record to be shared without restriction. For example, a student makes an off color remark during a classroom discussion. The instructor could contact their department chair and ask what to do with the situation. The chair may refer the instructor to the Dean of Students Office, who may provide advice, or deal with the student directly. This is not restricted information until it is officially recorded, and even then may be able to be shared depending on the parties responsibilities to the student and university.
At times an employee may have a concern about a student. Perhaps the student has missed a lot of class, or has been absent from a campus job for several days. A roommate could tell the housing staff she believes her roommate is failing her classes and wants to get help. The Dean of Students Office may learn a student was in a car accident and notifies the student's faculty that he will miss several days of classes due to injuries suffered. These are great opportunities for employees to share the information they have, with the proper officials on campus. By sharing this information, some of which could be part of an education record, the university is able to reach out and provide assistance to students at a time of need. The university encourages this type of sharing as a way to demonstrate to students that we care about them, and wish to retain them until their graduation.
There are times an employee is required to share information by either university policy or federal and state laws, even if the student has asked for it to be kept confidential. FERPA allows for this sharing to protect the health and safety of every member of the university. If there is a concern a student may harm themselves, or someone else, an employee must report this, either to the Dean of Students office (x2152), or UWGB Public Safety (x2300) if the threat is imminent. In the case of a victim reporting a sexual assault, a limited report must be made to the Dean of Students office (Clery Act). If a student were to disclose they were a victim of child abuse or neglect, this is to be reported to UWGB Public Safety (Act 54). These requirements are not made by FERPA, but are allowed under FERPA so the university is able to maintain compliance with other state and federal laws. For more information these requirements, please contact the Dean of Students office, Public Safety, or Human Resources.