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Disclosing Personally Identifiable Student Information in a Health or Safety Emergency

Overview

UW faculty and staff may encounter situations when, in connection with an emergency, there is an articulable and significant threat to the health or safety of a student or others. When acting in such situations, faculty and staff may disclose information from a student’s education record to individuals other than the student or a school official with a legitimate educational interest. This includes disclosure to anyone outside of the University, including emergency services, and non-UWPD law enforcement.

This protocol details actions university officials should take to comply with the Federal Educational Rights and Privacy Act (“FERPA,” 20 USC § 1232g, 34 CFR Part 99) when acting to protect health or safety, including the obligation to report to the UW Registrar instances when educational records were disclosed to anyone other than the student or a school official with a legitimate educational interest. It also details the Registrar’s obligation to document the disclosure.

Audiences

This protocol applies to all university officials (staff, faculty, and student employees in consultation with their supervisor). Mental health care providers must also comply with relevant state law confidentiality obligations and will document any disclosures within a student’s mental health care record.

Applicable FERPA Regulations

The Family Educational Rights and Privacy Act permits the University of Washington to disclose to appropriate parties personally identifiable information from an education record of a student without the student’s consent if the disclosure is in connection with a health or safety emergency and if knowledge of the information is necessary to protect the health or safety of the student or other individuals. 34 CFR §99.31(a)(10) and 34 CFR §99.36.

Reporting Protocol

If you believe there is a significant and articulable threat to health and safety and it is safe to consult prior to taking action, you should:

  1. Contact SafeCampus at safecampus@uw.edu or by calling:

    Safe Campus, often in collaboration with UW Seattle Police and with Campus Safety at UW Bothell and UW Tacoma, the Registrar and student affairs staff, will help you determine whether there is an articulable and significant threat to the health or safety of a student or others, then identify (a) what information from education records should be disclosed to address the health or safety concern and (b) to whom the information should be disclosed. If after consulting with SafeCampus you disclose educational records or information from a student’s educational record to someone other than the student or a school official with a legitimate educational interest, you should:

    1. E-mail your campus Registrar with the subject line “FERPA Disclosure Documentation” and include the following information in your message:
      1. Full name, if known, of the student
      2. Student number or NetID
      3. Date and time of the disclosure
      4. Brief description of the articulable and significant threat to the health or safety of a student or other individuals that was the basis for the disclosure
      5. What education records or information from education records was disclosed and to whom
      6. Your name, role at the university, and contact information
  2. At Bothell and Tacoma, report the incident to staff who can provide support and referrals to members of the UW community that were involved in the situation: Bothell CARE Team; Tacoma Care Team. At Seattle, SafeCampus will liaise with the appropriate university professionals to provide support, referrals, and possible intervention.If you have already reported a health and safety emergency and disclosed educational records to someone other than the student or a school official with a legitimate educational interest, you should:
    1. E-mail your campus’ Registrar with the subject line “FERPA Disclosure Documentation” and include the following information in your message:
      1. Full name, if known, of the student
      2. Student number or NetID
      3. Date and time of the disclosure
      4. Brief description of the articulable and significant threat to the health or safety of a student or other individuals that was the basis for the disclosure
      5. What education records or information from education records was disclosed and to whom
      6. Your name, role at the university, and contact information
    2. Notify SafeCampus of the situation by e-mailing safecampus@uw.edu or by calling:  Bothell 425-325-7233;  Seattle 206-685-7233; Tacoma 253-692-7233.
    3. At Bothell and Tacoma, report the incident to staff who can provide support and referrals to members of the UW community that were involved in the situation: Bothell CARE Team;  Tacoma Care Team. At Seattle, SafeCampus will liaise with the appropriate university professionals to provide support, referrals, and possible intervention.

Documentation of Disclosure

The Office of the University Registrar will record the appropriate information disclosed by the reporting party. The comments should include the date, a description of the situation, the specific information released, and to whom the information was released, such as:

  • Student Information disclosed on [DATE] per Health and Safety Emergency exception.
  • [Brief description of articulable and significant threat to health & safety.]
  • [Description of records or information from records disclosed, e.g. “class schedule”] was released to [name/description of individual or entity to whom records or information was released].