(Updated on March 22, 2013)
- to inform JIU students of their privacy rights under the Family Educational Rights and Privacy Act (together with the implementing regulations, “FERPA” or “the Act”), and
- to describe the ways JIU collects, uses, and shares the personal information we obtain when JIU students log on to the password-protected areas of the websites that comprise our online university (our “Student Sites”).
FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT NOTICE
Your rights under the Family Educational Rights and Privacy Act
The Family Educational Rights and Privacy Act (together with the implementing regulations, “FERPA” or “the Act”) protects the privacy of student educational records. Under the Act, eligible students and parents of ineligible students have the right to:
- inspect and review a student's education records;
- request an amendment to a student's education records, if s/he believes they are inaccurate, misleading or otherwise violate his/her privacy rights;
- consent to disclosures of personal information from a student's education records, unless the Act authorizes disclosure without consent; and
- file a complaint with the Family Policy Compliance Office of the U.S. Department of Education if a student believes JIU has not complied with the Act.
JIU defines an eligible student as a student who has reached the age of 18 and currently is attending or has attended JIU. An ineligible student is defined as a person who is a dependent student as defined by the IRS and/or has not been admitted to JIU. A parent is defined as a natural parent, guardian or individual acting in the absence of a parent or guardian.
A Student's Right to Inspect and Review
With certain limited exceptions (set forth in the Act), a student has the right to inspect and to review his/her education records at JIU's corporate office in Centennial, Colorado, or to request copies of them if it would be inconvenient to come to our office.
What are “education records”?
Education records are the records maintained by JIU that relate directly to a current or former student, including student applications, transcripts obtained from other schools, course schedules and grades. Education records do not include:
- information contained in the private files of JIU faculty and staff, that is used only as a personal memory aid, and is not accessible or revealed to any other person except a temporary substitute for person who created the record;
- information in JIU’s employee records about a student employee, unless the student’s employment was contingent on his/her student status;
- medical and psychological records made, used and disclosed only for providing treatment purposes;
- records that only contain information about an individual after s/he is no longer a JIU student; or
- admission records if the student was not admitted.
How do I inspect my education records?
If a student wishes to review or obtain copies of her/his education records, s/he must submit a written request by fax to the Office of the Registrar at +1.303.784.8547 or by postal mail to the Office of the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The request must include the student’s name and contact information, a description of the records s/he would like to review and the address to which s/he would like JIU to send any copies requested. For a student’s protection, JIU may ask for additional information to verify her/his identity. JIU does not charge for locating a student’s records, but it does reserve the right to charge for photocopying as permitted under the Act. JIU will respond to a student’s request and provide the opportunity to inspect and to review the student’s record within a reasonable period of time and, in any case, not more than 45 days after it has received the request.
There are some limited circumstances under which we may deny a student access to her/his education records; for example, a student will not be permitted to review certain financial records, including her/his parents’ financial information.
Your right to amend your education records.
If a student believes that her/his education records are inaccurate, misleading or otherwise in violation of her/his rights under the Act, s/he has the right to ask JIU to amend her/his education records. Note, however, that the Act does not provide a right to challenge grades, except to correct a grade that was inaccurately recorded.
How do I request amendment of my records?
To challenge information in a student’s records, s/he must submit a written, signed and dated request for amendment to the Office of the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The request must describe the record s/he wants to have amended, the amendment s/he requests and the reason for the amendment. The student also should provide contact information, in case JIU needs more information. JIU will respond to a student’s request within a reasonable period of time. If JIU determines that the information contained in the education record is inaccurate, misleading or otherwise in violation of the privacy rights of the student, the records shall be amended accordingly and the eligible student or parent will be notified of the amendment in writing. If JIU decides not to amend the record, it will explain why in a written notification and inform the eligible student or parent of his/her right to a hearing if in disagreement with the decision.
How do I request a hearing?
To request a hearing, a student must submit a written, signed and dated request for a hearing to the Office of the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. JIU will schedule a student’s hearing within a reasonable period of time and notify the eligible student or parent, in advance, of the date, time and location of the hearing.
How will the hearing be conducted?
For a student’s convenience, s/he may request that the hearing be conducted in person, via telephone or by other electronic means. The student may present evidence, and s/he may be represented by anyone s/he chooses, including an attorney, at his/her own expense. The hearing will be conducted by a JIU official who does not have an interest in the outcome. JIU will notify you in writing of its decision within a reasonable period of time and provide a summary of the evidence and the reasons for its decision.
What are my rights if the hearing official denies my request for an amendment to my records?
A student may appeal the hearing officer’s decision to the Chief Academic Officer (CAO) of JIU, but only if s/he does so in writing and within ten days after s/he receives the hearing officer’s decision. To appeal the hearing official’s decision, the student must submit a written, signed and dated request to the Office of the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The Office of the Registrar will forward the student’s request to the CAO. The CAO will consider the student’s appeal and render a decision within a reasonable period of time. The decision of the CAO represents JIU’s final decision.
Your right to place a statement in your record.
If, as a result of the hearing (or the appeal to the Chief Academic Officer), JIU decides that the information in a student’s education record is not inaccurate, misleading or otherwise in violation of his/her rights under the Act, s/he has the right to place a statement in the record commenting on the contested information or stating why s/he disagrees with JIU’s decision, or both. If the student chooses to place a statement in the record, JIU will maintain his/her statement as part of the record for as long as it maintains the record. JIU will disclose the student’s statement whenever it discloses the portion of the record to which it pertains.
Your Right to Consent to Disclosure of Your Education Records
Except as provided in the Act, and except for “directory information,” before JIU will disclose any part of a student’s education records to a third party, s/he must provide JIU with a signed and dated, written release specifying which records may be disclosed, the purpose of the disclosure and to whom the records may be disclosed. JIU will keep a record of this request and the disclosure, including the parties who requested or received the information, and the legitimate interest the parties had in requesting or obtaining the information, for as long as the student record is maintained. All student education records are held electronically in the Office of the Registrar. JIU maintains education records for which there is an outstanding request to inspect and review. At your request of an eligible student or parent, JIU will provide the eligible student or parent with a copy of the records it disclosed at the student's request. JIU will provide a copy of the disclosed records to an ineligible student with the parent’s permission. Rights under FERPA may be afforded to parent’s or legal guardians if the student is claimed as a dependent on the most recent Federal Income Tax forms and a copy is provided to the Office of the Registrar.
What is “directory information”?
Under the Act, JIU may disclose directory information without a student's consent, unless s/he specifically asks JIU not to do so. For example, we may publish directory information in a student directory, a yearbook or the program for a graduation ceremony or provide directory information in response to inquiries and requests.
JIU defines the following categories of personal information as “directory information”:
- email address
- business and home addresses
- business and home telephone numbers
- program of study and degree specialization
- participation in officially recognized JIU activities
- dates of attendance
- enrollment status (part-time or full-time/current or inactive)
- class status (freshman, sophomore, junior or senior/undergraduate or graduate)
- expected graduation date
- graduation date
- degrees granted, including any honors or awards
- most recent previous school or institution attended
- picture (photograph) and/or audio or video clip
If a current student does not want JIU to classify any or all information about him/her as “directory information,” s/he must notify JIU by completing, signing, dating and submitting a FERPA Privacy Form. A student’s request will ordinarily be processed within 10 days. The request will only apply to future requests; it will not affect previously released information. A student may change his/her direction at any time by submitting another Directory Information Request Form.
Exception for disclosure to JIU officials for a “legitimate educational purpose.”
The Act identifies a number of situations in which JIU may disclose a student’s education records without his/her prior consent to the following parties:
- school officials with legitimate educational interests
- U.S. Comptroller General, U.S. Attorney General, U.S. Department of Education
- state and local officials
- authorized organizations conducting educational research
- accrediting agencies
- alleged victim of a crime
- parent of a dependent student as defined by the IRS
- parent of a student under 21 regarding the violation of a law regarding alcohol or drug abuse
JIU may also disclose identifiable information under the health and safety emergency exception. If JIU does disclose identifiable information for this purpose, it documents the parties to whom the institution disclosed the information and the nature of the threat to the health or safety of the student or other individuals that formed the basis for the disclosure.
In the event the Office of the Registrar receives a request to disclose information in a court order or lawfully issued subpoena, JIU makes a reasonable effort to notify the student who is the subject of the subpoena or court order before complying, so that the student may seek protective action (unless the court or issuing agency has prohibited such disclosure).
JIU’s Office of Disability Services (ODS) may obtain and maintain health records for each student who applies for services or waivers. If a health record is used to make a decision in regard to a student’s education program (e.g., whether a student should receive extended time for testing or be exempt from an academic requirement, such as SAP) the health record may be construed to be an education record. In that case, the normal FERPA provisions for safeguarding the record would apply.
Your right to file a complaint
If a student believes JIU has violated the Act, s/he is encouraged to immediately notify the Office of the Registrar by email at firstname.lastname@example.org or by letter addressed to The Office of the Registrar, Jones International University, 9697 East Mineral Avenue, Centennial, Colorado 80112, USA. The Registrar will promptly review all allegations of noncompliance.
Students also have the right to file a written complaint with the Family Policy Compliance Office, United States Department of Education, 400 Maryland Avenue, SW, Washington, DC 20202-5920. The complaint must contain specific allegations of fact giving reasonable cause to believe that a violation of the Act has occurred. Unless the Office extends the time limit for good cause, the complaint must be submitted to the Office within 180 days of the date the alleged violation occurred or of the date the student knew or reasonably should have known of the alleged violation.
Questions about FERPA
If students have questions about their rights under the Act, please contact our FERPA Compliance Officer at email@example.com or by calling 800.811.5663, option 6. Additional information about FERPA is available at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
INFORMATION ABOUT JIU’S ONLINE PRIVACY PRACTICES
What Personal Information Do We Collect Through Our Student Sites?
Information You Provide. We collect the personal information you knowingly and voluntarily provide when you use one of our Student Sites, for example, the information you provide when you register for a course, participate in classroom discussion, submit coursework, complete a survey or contact us with questions or comments.
Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your web browser. This information typically includes your IP address, the address of the web page you were visiting when you accessed our Site, the name of your operating system (such as Windows® or Macintosh®), the name and version of your browser (such as Firefox® or Internet Explorer®), and the date and time of your visit. The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings.
The information provided by your browser does not identify you personally. However, we may link the information provided by your browser to information that identifies you personally and use it for the purposes described below. In addition, we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we may share our server logs -- which contain visitors’ IP addresses -- with the appropriate investigative authorities who could use that information to trace and identify individuals.
Information Collected Using “Cookies” and Other Web Technologies. We use “cookies,” and similar technologies to collect information and support the functionality of our Student Sites. A cookie is a small text file that is placed on your hard disk by a web server. Cookies cannot be used to install computer programs or deliver viruses to your computer. We may use two types of cookies -- “session cookies” and “persistent cookies.”
Session Cookies. A “session cookie” assigns a randomly-generated, unique identification number to your computer when you access one of our Student Sites. Assigning your computer a number permits us to follow you as you move from page to page during a particular visit. A session cookie expires after you close your browser. Session cookies do not identify you personally, however, we may link the information collected by our session cookies to information that identifies you personally.
Generally, we use session cookies to collect information about the ways students use the Student Sites – which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “click-stream information”) to better understand our students’ interests and needs and to improve the content and functionality of our Student Sites. Session cookies are also used to facilitate the proper functioning of certain features of our Student Sites, for example, to ensure that our streaming multimedia server functions properly.
Persistent Cookies. When you enroll in JIU, we will place one or more “persistent cookies” on your computer. These persistent cookies will identify you as a student enrolled in one of our programs and may contain other information that will allow us to provide you with a personalized online educational experience. Unlike a “session cookie,” a persistent cookie does not expire when you close your browser. It stays on your computer until it expires (for example, at the end of the academic year) or until you delete it.
Although it is possible to set your browser to reject cookies or to delete our cookies as soon as you log off, doing so would prevent you from using the functionality of our course sites and other functionality critical to your interactions with JIU. For this reason, all students are required to set their browsers to accept cookies and must not delete JIU cookies while they are “active” students.
How Do We Use the Personal Information We Collect Through Our Student Sites?
JIU uses the personal information collected through the Student Sites to provide a personalized, quality educational experience to you, as well as any information, services or products you request.
We use your contact information to communicate with you, for example, to notify you of your course schedule, to answer your questions and to tell you about upcoming events. We will also send you surveys asking you to provide feedback to us, for example, about the courses you have completed. In addition, from time to time we will send you “promotional” emails, for example, an email describing a new degree program. You may “opt-out” of receiving promotional emails at any time by clicking on the “opt-out” link at the bottom of the email.
We may use specific personal information for the purposes identified in a specific Privacy Notice posted on the page or area of our Site where you provided that information.
Finally, we may study the information we collect through our Student Sites to improve our programs and services, to improve the content, functionality, navigation,,and usability of our Student Sites, and to market our programs, services and products. We may remove all of the information that identifies specific individuals and use the rest for historical, statistical or scientific purposes.
With Whom Do We Share the Personal Information We Collect Through Our Student Sites?
We may disclose personal information we collect through our Student Sites with your prior written consent and as otherwise permitted under the Family Educational Rights and Privacy Act (FERPA). For example, we may disclose educational records to JIU staff and faculty who have a legitimate educational interest; to another school to which you are transferring; to appropriate parties in connection with financial aid for which you have applied or which you have received; and to accrediting organizations. In addition, we may disclose “directory information” to third parties or the general public unless you have asked us not to do so by completing our Directory Information Request Form. We may share specific personal information as disclosed in a specific Privacy Notice posted on the page or area of our Student Sites where you provided that information. To learn more about your privacy rights under the Act, please review our Family Educational Rights and Privacy Acts Notice.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We have industry standard measures in place to protect the confidentiality and security of the personal information in our students’ “education records,” including the information we collect through our Student Sites. It is important that you understand, however, that no website or database is completely secure or “hacker proof.”
You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse, for example, by protecting your user name and password. We have the right to assume that any individual who logs on to a Student Site using a student user name and password is the student to whom that user name and password is assigned. If you believe that your user identity has been compromised, you must immediately change your password. You will be responsible for the activities of anyone who accesses a Student Site using a user identity assigned to you, whether those activities were authorized by you or not.
TRANSFERS TO OTHER COUNTRIES
JIU is a U.S. corporation headquartered in Centennial, Colorado. Our Student Sites are currently hosted on servers located within the United States, but the locations of our servers may change from time to time. Our students’ “education records” are stored at offices or on servers located within the United States or in another country.
By enrolling in JIU as a student, you are consenting to the use and storage of your personal information in the United States or in any other country in which JIU data may be processed.
LINKS TO OTHER WEBSITES
Our Student Sites contain links to other websites operated by Jones International and its affiliates. Our Student Sites also contain links to websites that are owned and operated by unrelated third parties.