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  • 1.  Coding scholarship name to Alum in database

    Posted 09-05-2023 09:49 AM
    We have a request to assign an affiliation code to alumni who received a particular scholarship while a student, in order to be able to target these folks in later years with an appeal to give to this particular scholarship.

    Is it okay for us to do this?  Or would this affiliation coding be a violation of FERPA or other privacy laws since they would be potentially viewable by our whole Advancement team? While the affiliation itself wouldn't identify the dollar amount of the scholarship awarded, is linking the student/alum as a scholarship recipient itself be a problem?

    Thanks!



  • 2.  RE: Coding scholarship name to Alum in database

    Posted 09-05-2023 09:53 AM
    This is a solid recommendation and I see it all the time. Doing so is a very useful stewardship and cultivation mechanism.

    It does not violate FERPA as it does not pertain to educational information (but get approval from your lawyer). However, you can cover all bases by including language in the scholarship acceptance form that you will note the receipt of the scholarship on their advancement record for stewardship purposes.

    John

    John H. Taylor
    Principal
    John H. Taylor Consulting, LLC
    2604 Sevier St.
    Durham, NC   27705
    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987






  • 3.  RE: Coding scholarship name to Alum in database

    Posted 09-05-2023 10:54 AM

    I would think that this information does fall under FERPA, since it is information maintained by the educational institution that is directly related to the former student at the time that they were in attendance.

     

    That being said, I would also think that this falls under the FERPA provision that allows the disclosure of information from the student record to school officials who have a legitimate educational interest in the information.  One of the quirks of FERPA is that each institution has to publish its own definition of "school official" and "legitimate educational interest," but assuming that your institution has followed the model disclosures from the Family Policy Compliance Office at the U.S. Department of Education, Advancement staff would be school officials and they would have a legitimate educational interest if the access is required to perform their assigned duties.

     

    With respect to the information being available to everyone in Advancement, that's true of all the information that Advancement accesses under this FERPA provision.  We don't generally segregate, say, parent information, only to those Advancement staff who specifically use that information, and block it from other Advancement staff.  With appropriate policies and non-disclosure training/documentation, there shouldn't be an issue.

     

    Always good to review your institution's FERPA definitions and to run such matters past counsel, and John's suggestion that scholarship acceptance forms address this directly (along with related permissions like being able to disclose the recipient's name to the donor, etc.) is well taken,  but I would be very surprised if there was any issue.

     

    My US$0.02 worth; the usual disclaimers apply.

     

    Good luck!

    Alan

     

    Alan S. Hejnal (he/him)

    Data Quality Manager

     

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  • 4.  RE: Coding scholarship name to Alum in database

    Posted 09-05-2023 11:16 AM
    Great clarification, Alan. I fully concur with your analysis and the "exception" rule allowing certain information sharing within the organization.

    John

    John H. Taylor
    Principal
    John H. Taylor Consulting, LLC
    2604 Sevier St.
    Durham, NC   27705
    919.816.5903 (cell/text)

    Serving the Advancement Community Since 1987