SH.10 - Student Records
- SH.10.A – Student Holds
- SH.10.B – Family Educational Rights and Privacy Act (FERPA)
- SH.10.C – Directory Information
- SH.10.D – Protected Health Information (PHI)
SH.10.A – Student Holds
The College may place a hold on the release of a student's records for failure to comply with a requirement or meet an obligation of the offices of Admissions/Registrar, Bursar, Financial Aid, Learning Resource Center, Student Life, or other College offices. A hold placed on a student for disciplinary action or for violations of the Student Code of Conduct can only be released by the Associate Vice President of Student Success or a Dean of Student Success. Without the release of the "hold," a student may be prohibited from re-enrollment at the College. It is the responsibility of the student to contact the office which placed the hold on his/her records to determine if the hold can be released and the process by which that is accomplished.
SH.10.B – Family Educational Rights and Privacy Act (FERPA)
Access to Student Records
Student records at Tulsa Community College are maintained by College Officials in compliance with the Family Educational Rights and Privacy Act of 1974 as amended in 1995. A College Official is a person who serves Tulsa Community College in an academic or administrative manner and includes, but is not limited to, instructors, registrar, counselor, admissions, attorney, law enforcement, and other support and clerical personnel. This definition also includes a person or company with whom TCC has outsourced institutional services or functions, such as a contractor, consultant, or volunteer; a person serving on an official TCC committee, such as a disciplinary or grievance committee; or a person legitimately authorized to assist another TCC school official in performing their professional TCC responsibilities. The Act also affords students certain rights with respect to their educational records. These rights include annual notification of rights, the right of students to request access to their personal records, and also the right to request the amendment of the student’s education records that the student believes are inaccurate. The student must submit in writing a request precisely noting the record for review. Additionally, students have the right to consent to disclosures of personally identifiable information contained in the student’s education records, except to the extent that FERPA authorizes disclosure without consent. Upon request, the College discloses education records without consent to officials of another school in which a student seeks or intends to enroll.
Education records include any record maintained by the institution that contains information that is personally identifiable to a student (in whatever format or medium) with some narrowly defined exceptions:
- Records in the “sole possession of the maker” (e.g., private advising notes).
- Law enforcement records are created and maintained by a law enforcement agency for a law enforcement purpose.
- Employment records (unless the employment is based on student status). The employment records of student employees (e.g., work-study, wages, and graduate teaching associates) are part of their education records.
- Medical/psychological treatment records (e.g., from a health or counseling center).
- Alumni records (i.e., those created after the student graduated or left the institution).
The Act affords students the right to file a complaint with the U.S. Department of Education concerning alleged failures by the College to comply with the requirements of FERPA. The name and address of the office that administers FERPA:
Family Policy Compliance Office
U. S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202-4605
To authorize the disclosure of an educational record to a third party, the student must complete the FERPA Release Form, found on the MyTCC, My Account page.
The FERPA release form may be revoked at any time by completing a new FERPA release and selecting the revoke option.
The College may release a student’s directory information without the written release of the student as allowed by FERPA. The College is authorized to obtain or provide educational records as allowed by law.
One exception which permits disclosure without prior consent is disclosure to school officials with “legitimate educational interest.” A school official has a legitimate educational interest if the official has a “need to know” information from your educational record to fulfill his or her official responsibilities. Examples of people who may have access, depending on their official duties, and only within the context of these duties, including academic program administrators, and staff and agencies under contract with the College.
Other examples of the exceptions to the release requirement include:
- Disclosure to another institution where the student seeks to enroll or is enrolled.
- Disclosure to DOE, state/local education authorities.
- Disclosure in connection with the receipt of financial aid.
- Disclosure to state/local officials in conjunction with legislative requirements.
- Disclosure to organizations conducting studies to improve instruction, or to accrediting organizations.
- Disclosure to parents of dependent students (IRS definition).
- To comply with a judicial order or lawfully issued subpoena.
- Disclosure for a health/safety emergency (must document what the emergency was and to whom the information was released).
- Disclosure to the alleged victim of a crime of violence, such as information from disciplinary proceedings.
- Only when found in violation, and only for crimes of violence — release of the name, sanction and outcome can be made to anyone.
Process to Request Inspection, Review, or Correction of Student Records
Students should submit to the Associate Vice President of Enrollment and Retention or College Registrar, written requests that identify the record(s) they wish to inspect. The Registrar will make arrangements for access and notify the student of the time and place where the records may be inspected. If the records are not maintained to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed.
The College must comply with a request to inspect and review records within 45 days of the receipt of a request.
When a record contains information about more than one student, the student may inspect and review only the records that relate to him or her.
Correction of Student Records
Students have the right to ask to have records corrected that they believe are inaccurate, misleading, or in violation of their privacy rights.
A student must request the Registrar’s Office of Tulsa Community College to amend a record in writing. In so doing, the student should identify the part of the record to be amended and specify why the student believes it is inaccurate, misleading, or in violation of his or her privacy rights.
The College may comply with the request or it may decide not to comply. If it decides not to comply, the College will notify the student of the decision and advise the student of his or her right to a hearing to challenge the information believed to be inaccurate, misleading, or in violation of the student’s privacy rights.
Upon written request, the College will arrange for a hearing and notify the student, reasonably in advance of the date, place, and time of the hearing.
The hearing will be conducted by a hearing officer who is a disinterested party; however, the hearing officer may be an official of the institution. The student shall be afforded a full and fair opportunity to present evidence relevant to the issues raised in the original request to amend the student’s education records. One or more individuals may assist the student, including an attorney retained at his or her expense. The College may be represented by College Legal Counsel.
The College will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence presented and the reasons for the decision. If the College decides that the information in the student’s record is inaccurate, misleading, or in violation of the student’s right of privacy, it will amend the record and notify the student, in writing, that the record has been amended.
If the College decides that the challenged information is not inaccurate, misleading, or in violation of the student’s right of privacy, it will notify the student that he or she has a right to place in the record a statement commenting on the challenged information and/or a statement setting forth reasons for disagreeing with the decision.
The statement from the student will be maintained as a part of the student’s education records as long as the contested portion is maintained. If the College discloses the contested portion of the record, it must also disclose the student’s statement.
SH.10.C – Directory Information
The Family Educational Rights and Privacy Act (FERPA) further provides that certain portions of a student record may be deemed directory information and be released to a third party without the written consent of the student. TCC designates the following as directory information:
- Student name
- Mailing address
- Degrees or certificates earned
- Last term of attendance
- Honor and/or awards
A directory is developed each term listing student name, city, and state, to comply with the Oklahoma Records Act. The College receives inquiries for Directory Information from a variety of sources, including educational partners, new media, and prospective employers.
A student may request the College not to release directory information. The request to withhold information can be found on the MyTCC, My Account page and must be completed prior to the end of the fourth week of a fall or spring term or the end of the second week of a summer term. Students registering after this deadline may complete an information withholding request at the time of enrollment.
SH.10.D – Protected Health Information (PHI)
All persons involved with the creation, collection, handling, and/or dissemination of TCC Confidential Information are subject to the conditions of this policy. This includes all employees, temporary workers, Insurance/Benefit Coordinators, Board Members, Business Associates, students, contractors, and anyone who may access or view TCC Confidential Information.
General Rules: TCC shall use and disclose Protected Health Information (PHI) only as permitted or required under the Privacy Rule, and other federal or state laws and regulations.
Family Members and Friends
TCC may, but is not required to, disclose limited relevant PHI to a family member or friend who has been specifically identified by the Participant or who is directly involved in the care of the Participant, or the payment for care. Disclosure should only occur after verification of identity and authority and should utilize the minimum necessary rule defined herein.
TCC may disclose PHI pursuant to an authorization provided by the Participant that satisfies all of the Privacy Rule’s requirements for a valid authorization. All uses and disclosures must be consistent with the terms and conditions of the authorization.
Legal, Specialized Government Functions, Workers’ Compensation, or Public Health Requests
PHI may be disclosed in the following situations without a Participant’s authorization when certain requirements are satisfied. TCC shall have procedures describing the specific requirements that must be met before these types of disclosures may be made. The requirements shall include prior approval of the TCC legal counsel. These disclosures are:
- regarding victims of abuse, neglect, or domestic violence;
- for treatment purposes;
- for judicial and administrative proceedings;
- for law enforcement purposes;
- for public health activities;
- regarding an individual who has died;
- for cadaveric organ-, eye- or tissue donation purposes;
- for certain limited research purposes;
- to avert a serious threat to health or safety;
- for specialized government functions; and
- that relate to workers’ compensation programs.
Maintaining Confidentiality of Health Information
TCC shall not use or disclose PHI except as permitted or required by federal and state statutes or rules. Disclosure of PHI shall be performed by trained personnel in accordance with applicable laws, regulations, and TCC’s policies and procedures.