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Employment 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.
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