Student Services Manual (SSM)

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Effective: 1/27/2003

Revised: 11/1/2006

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SSM 107–02: Lost, Stolen, or Inappropriately Disclosed Student Records Information

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Purpose

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To provide guidelines for reporting the loss, theft, or inappropriate disclosure of student education records containing personally identifiable information protected from disclosure by the federal Family Educational Rights and Privacy Act of 1974, as amended

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Sources

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Family Educational Rights and Privacy Act of 1974 (also referred to as the Buckley Amendment or FERPA), 20 United States Code § 1232g, as amended
University Registrar Services
Office of General Counsel

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Policy

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Offices, departments, staff, or faculty that experience the loss, theft, or inappropriate disclosure of student education records information are responsible for notifying the police, the individual students, University Registrar Services, and the Office of General Counsel. Affected departments are also required to develop procedures to avoid future loss, theft, or inappropriate disclosure.

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ProcedureD

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Responsibility
Action
Office or department reporting loss, theft, or inappropriate disclosure
  1. File police report with appropriate jurisdiction if theft has occurred.
  2. Notify the administration office of University Registrar Services and the Office of General Counsel of loss, theft, or inappropriate disclosure.
  3. Notify all students affected by letter or e-mail. Include summary of what occurred, police report number (if theft has occurred), and advice to monitor any suspicious activity involving possible misuse of information to establish unauthorized credit. If applicable, provide Social Security Administration fraud telephone number (800/269–0271) and credit bureau numbers (Equifax 800/525–6285; Experian 888/397–3742; Trans Union 800/680–7289).
  4. Inform students that the Federal Trade Commission (FTC) maintains the U. S. government’s central Web site for information about identify theft at http://www.consumer.gov./idtheft/.
  5. Submit to the administration office of University Registrar Services a copy of the letter sent to students, list of all affected students, and statement indicating proactive steps to be implemented in department to prevent future loss, theft, or inappropriate disclosure of records information.
University Registrar Services
  1. Confirm that students and the Office of General Counsel have been notified. Add department’s letter, list, and statement to FERPA file.
  2. Provide assistance to individual students involved upon request.
  3. Consult with department on prevention strategies as needed.

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Cross-Reference

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For related information, see SSM 107–01, “ Release of Student Information.”


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