Policy: Protecting Student Privacy
Students attending Trinity have privacy rights under the Federal Educational Rights and Privacy Act (FERPA) which limits access to student information. All employees of Trinity, both faculty and staff, are obliged to protect student privacy rights as both a legal and ethical concern. Faculty and staff are likely to obtain significant amounts of private information about students in the normal course of business, whether academic, co-curricular, financial, judicial, admissions, athletic, security, counseling, testing, or other kinds of information. Sometimes students will volunteer highly personal information; or staff may observe certain student actions, or have legitimate access to academic, financial or personal information about students. No matter how the information is derived, faculty and staff should observe these rules to protect student privacy:
- Faculty and staff should not discuss student business in public places, e.g., in the dining hall, on the corridor, in the bookstore, or in any other location in which other people might overhear the conversation. No professional person on Trinity’s staff should ever engage in gossip about a student or share a student’s personal information outside of a legitimate and necessary business purpose.
- Care should be exercised in the dissemination of papers, email, voicemail and any other forms of written or oral documentation in which individual students are discussed. As a general rule, sensitive student issues should not be discussed in email messages, and written documentation should be limited to the specific purpose for which the document is needed. While a written document may necessarily describe a behavior or data set concerning a student, it is never appropriate to render any characterization of the student beyond the simple description of the issue at hand, unless the characterization is rendered by a competent professional for clinical purposes.
- In order to care for students appropriately, or to ensure their academic progress, it is necessary for faculty and staff to share student information on a ‘need to know’ basis according to the nature of the information and the student’s situation. Individual staff or faculty who do not need to know individual student information should not be included in discussions about particular cases.
- Faculty or staff who misuse student information, expose student information to public view, or who otherwise violate the letter and spirit of this policy may be subject to disciplinary action. Any member of the faculty or staff who misuses student information in a way that is likely to harm the student’s reputation, to threaten or intimidate the student, or similar actions, may incur dismissal.
- Faculty and staff also have an obligation to disclose information in their possession in situations in which a student might do harm to herself or others. A pledge of confidentiality to a student may not be a basis for withholding information if the situation indicates a potential for harm. Such disclosure should be to the appropriate dean, vice president or president.