FERPA Privacy Policy
California Institute of Integral Studies (CIIS) maintains student education records in compliance with the Family Educational Rights and Privacy Act of 1974 (FERPA), Public Law 93-380, as amended. FERPA affords students these rights with respect to their education records:
- The right to inspect and review the student’s education records within 45 days after the day CIIS receives a request for access. A student should submit to the registrar, Dean, head of the academic department, or other appropriate official a written request that identifies the record(s) the student wishes to inspect. The school official will make arrangements for access and notify the student of the time and place where the records may be inspected. The educational records are the property of CIIS, and CIIS will not supply copies to the student, unless the student is unable to view them otherwise (i.e., it is impossible for the student to come to CIIS). In that case, photocopies will be supplied at 25 cents per image.
- The right to request the amendment of the student’s education records that the student believes are inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA. Students who wish to ask CIIS to amend a record should write to the school official responsible for the record, clearly identify the part of the record they want changed, and specify why it should be changed. If CIIS decides not to amend the record as requested, it will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
- The right to provide written consent before CIIS discloses personally identifiable information (PII) from the student’s education records, except to the extent that FERPA authorizes disclosure without consent. Such authorization includes the following:
- To school officials with legitimate educational interests. A “school official” is a person employed by CIIS in an administrative, supervisory, academic, research, or support staff position (including security personnel); a person serving on the board of trustees; or a student serving on an official committee, such as a disciplinary or grievance committee; a volunteer or contractor outside of CIIS who performs an institutional service or function for which CIIS would otherwise use its own employees and who is under the direct control of CIIS with respect to the use and maintenance of PII from education records. Examples of the last could include an attorney, auditor, or collection agent, or a student volunteering to assist another school official in performing their tasks. A school official has “legitimate educational interests” if the official needs to review an education record in order to fulfill their professional responsibilities for CIIS.
- FERPA permits an institution, for the purposes of conducting its functions, to identify a subset of students’ PII as “directory information” that can be disclosed without the student’s prior written consent. Directory information is considered not generally harmful or an invasion of privacy if disclosed. CIIS designates only the following as a student’s directory information: full name, address, email address, telephone number, photograph, program of study, dates of attendance, enrollment status (e.g., full-time, half-time), participation in officially recognized activities, and degree and awards received. Students may direct CIIS to not disclose their directory information. To initiate or revoke this directive, students should contact the registrar.
- Upon request, to officials of another school where the student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer, subject to the requirements of §99.34. FERPA requires a school to make a reasonable attempt to notify each student of these disclosures.
To authorized representatives of the US Comptroller General, the US Attorney General, the US Secretary of Education, or state and local educational authorities. Disclosures under this provision may be made, subject to the requirements of §99.35, in connection with an audit or evaluation of federal- or state-supported education programs, or for the enforcement of or compliance with federal legal requirements that relate to those programs. These entities may make further disclosures of PII to outside entities that are designated by them as their authorized representatives to conduct any audit, evaluation, or enforcement or compliance activity on their behalf.
NOTE REGARDING POINT D: As of January 3, 2012, the US Department of Education’s FERPA regulations expand the circumstances under which student education records and PII contained in such records — including Social Security Number, grades, or other private information — may be accessed without the student’s consent. First, the US Comptroller General, the US Attorney General, the US Secretary of Education, or state and local education authorities (“Authorities”) may allow access to records and PII without consent to any third party designated by an Authority to evaluate a federal- or state-supported education program. Second, Authorities may allow access to education records and PII to researchers performing certain types of studies — in certain cases even if the school does not request or even objects to such research. The Authorities must obtain certain use-restriction and data security promises from the entities that they authorize to receive the students’ PII, but the Authorities need not maintain direct control over such entities. Additionally, in connection with Statewide Longitudinal Data Systems, state Authorities may collect, compile, permanently retain, and share without students’ consent PII from education records, and may track students’ participation in education and other programs by linking such PII to other personal information obtained from other federal or state data sources, including workforce development, unemployment insurance, child welfare, juvenile justice, military service, and migrant student records systems.
- In connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid.
- To organizations conducting studies for, or on behalf of, the school, in order to (a) develop, validate, or administer predictive tests; (b) administer student aid programs; or (c) improve instruction.
- To accrediting organizations to carry out their accrediting functions.
- To parents of an eligible student if the student is a dependent for IRS tax purposes.
- To comply with a judicial order or lawfully issued subpoena.
- To appropriate officials in connection with a health or safety emergency, subject to §99.36.
- To a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense, subject to the requirements of §99.39. The disclosure may only include the final results of the disciplinary proceedings with respect to that alleged crime or offense, regardless of the finding.
- To the general public, the final results of a disciplinary proceeding, subject to the requirements of §99.39, if the school determines the student is an alleged perpetrator of a crime of violence or non-forcible sex offense and the student has committed a violation of the school’s rules or policies with respect to the allegation made against them.
- To parents of a student regarding the student’s violation of any federal, state, or local law, or of any rule or policy of the school, governing the use or possession of alcohol or a controlled substance if the school determines the student committed a disciplinary violation and the student is under the age of 21.
FERPA requires CIIS to record the disclosure of PII from the student’s education records except for disclosures (a) to the student; (b) to school officials; (c) of directory information; and (d) as related to some judicial orders or lawfully issued subpoenas. Students have a right to inspect the record of disclosures.
- The right to file a complaint with the US Department of Education concerning alleged failures by CIIS to comply with the requirements of FERPA. The Office that administers FERPA is:
Family Policy Compliance Office
US Department of Education
400 Maryland Avenue, SW
Washington, DC 2020