Privacy and Confidentiality Policy

This includes at least all of the following records:

• Records relating to eligibility and disbursement of Federal student aid funds
• Student account
• Federal work-study payroll records
• Financial aid applications
• SARs and ISIRs
• Documentation of professional judgment decisions
• Documentation relating to a refusal to certify Federal education loans
• Financial aid history information (for transfer students)
• Cost of attendance information, including documentation relating to any adjustments
• Satisfactory Academic Progress (SAP) documentation
• Documents used for verification
• Entrance and exit counseling records
• Financial records
• Educational records include any materials received from the student and/or parents. It also includes any records that were used to make decisions about the student.

Only those records that are directly related to the student are considered to be educational records.

Although employment records are not considered education records by FERPA, student employment records are considered to be education records. So the employment records of a Muhlenberg College employee who takes a class are not protected by FERPA, but the employment records of a work-study student are protected by FERPA. The distinction is whether the employment resulted from the individual's status as a student.

The Office of Financial Aid does not disclose personal or account information to any individual acting on behalf of the student, unless the student is present at the time of disclosure, or in cases here we have a valid federal tax return on file indicating the student is a dependent or if the student has indicated on the Muhlenberg College Financial Aid Application that we have permission to speak with that individual. The Office of Financial Aid will only provide account information to individuals over the phone or via e-mail if the student has authorized us to do so on the Muhlenberg College Financial Aid Application. To maintain optimal security of student’s personal information, we restrict access to student’s personal and account information only to federal, state and appropriate institutional authorities.

The access and release of a student’s non­public (non-directory) information such as educational records (or ny personally identifiable information they contain) without a student’s prior consent is prohibited under federal law. However, federal law permits access to such information without a student’s prior consent under certain circumstances or to certain individuals.  These include the following:

• Officials of the College, including professors, who have a legitimate educational interest in the information
• Officials of other schools in which you seek or intend to enroll, on the condition that the student (upon request) receive a copy of what was transferred and have an opportunity to (upon request) challenge its content
• Persons, companies or agencies with whom the College has contracted to provide services that the College, itself, would otherwise have to provide (such as attorney, auditor, collection agent, security service or other service provider) Federal, state, and local officials, authorities, or their agents as required by law or for the purpose of audit, program and institutional evaluation and improvement, and legal compliance with federally supported education programs
• Financial aid information to the extent necessary for such purpose as determining eligibility for financial aid or determining or enforcing the terms or conditions of the financial aid
• The College or its agents to the extent necessary to resolve any outstanding financial obligation to the College
• Accrediting organizations in order to carry out accrediting functions
• A student’s parents, if the student is a dependent as defined in Section 152 of the Internal Revenue code
• Appropriate parties in a health or safety emergency
• Officials of the military for recruitment purposes
• By judicial order or lawfully issued subpoena after consultation and review by Muhlenberg College’s legal counsel
• Any other condition or individual not named here but for a legitimate purpose within federal law

The Office of Financial Aid regularly reviews procedures and practices to ensure that student’s financial information is protected from unauthorized access. It is the responsibility of the student to set or remove a restriction to release his/her financial information at any time. If a student restricts the release of directory information, the restriction will remain in effect until the student removes it. To authorize release or restriction of financial account information, a student must complete and submit a Financial Aid Records Release Form. The Financial Aid Records Release Form serves as written notification of disclosure and is included in the student’s financial aid record.

In compliance with the Privacy Act of 1974 (P.L. 93-579): disclosure of an applicant’s Social Security number is required on applications for financial aid. The applicant’s Social Security number will be used to identify the student’s account, verify the student’s identity during the period of attendance, and to ascertain that there is no improper, simultaneous funding under other federal financial aid programs. As above, applicants are required by federal law to provide their Social Security numbers (SSN) on the FAFSA, Student and Parent Loan applications/promissory notes/forms and on state grant and some outside scholarship applications. SSN (as specified on the individual document) is required on all supporting documents supplied directly to the Office of Financial Aid to apply for financial aid. The SSN will be used for the College’s system of student records, for compliance with federal and state reporting requirements, as well as for debt collection. The College will not disclose the SSN to anyone outside the institution except as required by law, and will make every effort to protect the applicant’s privacy.