All third parties requesting student information for solicitation purposes
- The federal Family Educational Rights and Privacy Act of 1974 (FERPA, also known as the “Buckley Amendment”) prohibits Syracuse University from releasing protected information (i.e., educational records) on current or former students to external third parties for purposes of solicitation without students’ express written permission. No exceptions to these prohibitions are permissible pursuant to this policy statement. In addition, the University will not provide forms of Directory Information, as defined by the institutional FERPA policy, even though this information may be released without students’ permission.
- Specific exceptions to the policy described in the last sentence of Paragraph 1 regarding Directory Information will be made only when a proposed solicitation of Syracuse University students, or specific populations thereof, by a third party for business solicitation purposes is judged by the Chancellor to be consistent with the University’s educational mission and in the interests both of students and the institution. Exceptions will be made in accordance with the procedures in Paragraph 3. Requirements and limitations of such exceptions include the following:
- Students who have blocked release of their Directory Information under FERPA will be excluded from any data retrieval.
- Student information may not be used for any purpose other than that specified in an agreement to be signed and authorized by the University’s Chancellor, Vice Chancellor, Executive Vice President and CFO, or Comptroller (“Authorized Agreement”) between the University and the third party.
- The third party must agree to completely destroy all provided information after a designated time period for its use.
- The third party may not provide to others, sell to another party, store in any media, or otherwise re-use the student information.
- The Office of the Registrar will determine the feasibility of and reasonable time for providing the approved information.
- The third party (or sponsoring office – – see below) will bear all costs associated with information retrieval, media, and materials.
- Exceptions to the policy stated in Paragraph 1 may only be made by the Chancellor in accordance with the process outlined below:
- The third party must secure the sponsorship of an appropriate academic or administrative office able to judge the student and institutional interests served by the proposed solicitation.
- The chief administrator/director of the sponsoring office will prepare a written request for the student Directory Information stating the purpose of the solicitation; the reason it is consistent with the University’s educational mission and students’ interests; the sponsor’s endorsement; the specific population that will be solicited; and details of the requested data, format, and timeline. The request should be forwarded to the University Registrar, as the custodian of student data, who will determine the feasibility of arrangements for complying, based on the current information environment.
- The University Registrar will forward the request and feasibility assessment to the Chief Information Officer, who will present the request to the Chancellor’s Cabinet.
- After discussion by the Cabinet, the Chancellor will decide whether an exception to the policy will be made. Approval of requests will be communicated to the University Registrar, who will notify the sponsoring office. Denial of requests will be communicated to the sponsoring office by its respective Cabinet officer.
- Once approved, a contract, with wording that reflects the requirements stated in Paragraph 2, must be submitted to an officer noted in that paragraph.
- The Comptroller or other signer will notify the sponsor when the Authorized Agreement is signed, and provide a copy to the University Registrar.
- Upon receipt of the Authorized Agreement, the Registrar’s Office will execute the information retrieval and will maintain a copy of the Authorized Agreement.
Links to Procedures and Related Information
Amended: July 2005