ADMINISTRATIVE POLICY 6.2
Family Educational Rights and Privacy Act (FERPA)
Title & #: Family Educational Rights and Privacy Act - 6.2 |
Executive Sponsor: Provost; Vice President of Academics and Student Services |
Date Effective: 02/25/2026 |
Supersedes Version: 3 |
INDEX PURPOSE REASON FOR POLICY ENTITIES AFFECTED DEFINITIONS POLICY STATEMENT ROLES AND RESPONSIBILITIES COMPLIANCE AND TRAINING REQUIREMENTS EXCEPTIONS APPROVALS RELATED DOCUMENTS REVIEW AND REVISION HISTORY The purpose of this policy is to ensure compliance with the Family Educational Rights and Privacy Act (FERPA), a federal law that protects the privacy of student education records. This policy outlines the rights of students and their families regarding access to, amendment of, and control over the disclosure of educational records. It also establishes the responsibilities of KCTCS in safeguarding student information and provides guidance to faculty, staff, and administrators on appropriate handling of student data. By adhering to FERPA regulations, KCTCS upholds its commitment to student privacy, data security, and ethical stewardship of educational records.
Additional information about the law may be found at https://studentprivacy.ed.gov/ferpa. This policy shall apply to all applicable students, regardless of mode of course delivery or age. All students have rights with respect to their educational records once they become an enrolled student. All employees who have access to student educational records are bound by this policy. Directory Information is basic student data which can be disclosed by KCTCS without a student’s consent. See Section V of this policy for the specific KCTCS student data categorized as directory information. Eligible Student under FERPA is a student who is 18 years of age or older or who attends a postsecondary institution at any age. Enrolled Student is a student who has registered for classes at a KCTCS college. Legitimate Educational Interest refers to the interest a school official must have to access a student’s educational records. The information contained in the record must be necessary for that official to perform appropriate tasks that are specified in his or her position description or by a contract agreement. School Official typically includes a person employed by KCTCS in an administrative, supervisory, academic, research, or support staff position (including law enforcement unit personnel and health staff); a person serving on the board of regents; or a student serving on an official committee, such as a disciplinary or grievance committee. A school official also may include a volunteer or contractor outside of KCTCS who performs an institutional service of function for which the school would otherwise use its own employees and who is under the direct control of the school with respect to the use and maintenance of PII from education records, such as an attorney, auditor, or collection agent, or a student volunteering to assist another school official in performing his or her tasks. A school official typically has a legitimate educational interest if the official needs to review an education record to fulfill his or her professional responsibilities for KCTCS. Student Educational Records are records related to a student and maintained by KCTCS. These records include but are not limited to grades, transcripts, class rosters, student schedules, health records, student financial records, and student disciplinary records. Student records may be collected in any way, including but not limited to, electronically, handwritten, and by other types of media such as videotape, microfiche, and email. Educational records exclude records which are in the sole possession of a school official and which are not accessible by other personnel. Personally Identifiable Information (PII) is information that can be used to distinguish or trace a student’s identity, such as name, date of birth, address, telephone number, and other data that, when combined, allow a reasonable person to identify an individual student. Under this policy, student rights include: 1. The right to the privacy of their student data as protected under FERPA. Disclosure of any student data, other than those specific student data described as Directory Information below, is not permitted outside the process in this policy. 2. The right to inspect and review the student's education records within 45 calendar days after the day KCTCS receives a request for access. A student must submit to the applicable KCTCS College Registrar a written request identifying the record(s) the student wishes to inspect. The College Registrar will arrange access and notify the student of the time and place where the records may be inspected. If the records are not maintained by the College Registrar to whom the request was submitted, that College Registrar shall advise the student of the correct official to whom the request should be addressed. 3. The right to request amendment of the student’s education records that the student believes is inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA. A student who wishes to ask a KCTCS College to amend a record should write to the applicable KCTCS College Registrar, clearly identifying the part of the record the student wants to change, and specify why it should be changed. If KCTCS decides not to amend the record as requested, the KCTCS College will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment 4. The right to provide written consent before KCTCS discloses personally identifiable information (PII) from the student's education records, except to the extent that FERPA authorizes disclosure without consent (please see the “Exceptions” section below). Written consent is provided through completion of the Consent to Release Information page within the student self-service portal or by providing written authorization to the college Registrar. KCTCS only discloses education records without a student’s prior written consent under the FERPA exception for disclosure to school officials with legitimate educational interests. 5. The right to file a complaint with the U.S. Department of Education concerning alleged failures by KCTCS to comply with the requirements of FERPA. The name and address of the office that administers FERPA is: Student Privacy Policy Office U.S. Department of Education 400 Maryland Avenue Washington, DC 20202 In its discretion, KCTCS considers the following student data Directory Information:
The roles and responsibilities for each official are as follows: College Registrar: Serves as the local official for all FERPA related information. May provide additional training and information to faculty and staff to ensure awareness and knowledge of FERPA policy and practice and is responsible for communicating all known FERPA violations to the System Registrar. The College Registrar may also elect to notify students annually of the FERPA policy via electronic communication (email), or by other technology. KCTCS Senior Information Security Officer: Works in conjunction with the College Registrar and the College Director of Information Technology to resolve any known FERPA violations. This may include ensuring deletion of data which contains FERPA protected information. System Registrar: The System Registrar will keep the official record of all reported FERPA violations by each KCTCS college. The System Registrar will consult the Office of General Counsel as needed for additional guidance. The System Registrar will also provide onboarding FERPA training to new College Registrar hires within their first sixty days of employment. The System Registrar is responsible for publishing the required annual FERPA notification to students in the KCTCS Catalog each academic year. All new and continuing employees are required to complete annual mandatory training related to FERPA and to acknowledge awareness of the FERPA policy and associated procedures. Employees are responsible for complying with this policy. Any violations of this policy may result in employee disciplinary action and/or revocation of access to student data. College Registrars may provide additional local training for faculty and staff as part of local orientation or onboarding efforts. Additionally, new college Registrars must complete a one-time mandatory training session with the System Registrar within the first sixty calendar days of employment. All KCTCS Colleges will be required to inform the System Registrar of any new College Registrar within ten calendar days of the hire. If additional training or support is required by the College Registrar, the System Registrar will help support the college personnel in consultation with the Office of General Counsel. FERPA permits the disclosure of PII from students’ education records, without consent of the student, if the disclosure meets certain conditions. Except for disclosures to school officials, disclosures related to some judicial orders or lawfully issued subpoenas, disclosures of directory information, and disclosures to the student, FERPA regulations require the institution to record the disclosure. Eligible students have a right to inspect and review the record of disclosures. KCTCS may disclose PII from the education records without obtaining prior written consent of the student --
Original Adoption – February 25, 2026. Next Scheduled Revision, on or before February 25, 2029. |