Charles and Sue's School of Hair Design wants our students to understand how we protect their privacy both in their educational records as well as any personal identifiable information. Please visit us in the Office of the Director of Education or call us at (979) 776-4375 if you have any questions.
General Privacy Policy
Charles and Sue's School of Hair Design is committed to the concern for and protection of students’ rights and the privacy of their information, and carefully protects all personally identifiable information (PII) in our possession regarding students and their families, in accordance with this policy. Charles and Sue's has a single Privacy Policy that complies with both the Federal Family Rights and Privacy Act (FERPA), and the Gramm-Leach-Bliley Act (GLBA). The Office of the Director of Education is responsible for the privacy of student records and information, and for maintaining compliance with this policy across all departments at the School.
The Family Educational Rights and Privacy Act of 1974 (FERPA)
FERPA provides current and former students with the right to inspect and review educational records, the right to seek to amend those records, the right to limit disclosure of information from the records and the right to file a complaint with the U.S. Department of Education. Students may also waive their rights under FERPA voluntarily under certain circumstances. An applicant becomes a “student” for the purposes of FERPA upon the earlier of the date the student makes a full or partial tuition payment (deposit) or the date the student begins instruction.
Students’ Rights Under FERPA
Right to Be Informed: Students have the right to be informed about their rights under FERPA and GLBA. This policy details those rights and is published through the School’s website.
Right to Review Educational Records: Students have certain rights with respect to their educational records. Students have the right to review their educational records within 45 days of the day the School receives a request for access. Students should submit to the Office of the Director of Education written requests that identify the record(s) they wish to inspect and the student will be notified of the time and place where the records may be inspected. If the records are not maintained in the Office of the Director of Education, the student will be advised of the correct official or office to whom the request should be addressed.
Right to Request an Amendment: Students have the right to request an amendment to the educational records that are believed to be inaccurate. Students requesting an amendment should submit a written request to the Office of the Director of Education or the School official responsible for the record, clearly identify the part of the record they want changed, and specify why it is inaccurate. If the School decides not to amend the record as requested by the student, the School will notify the student of the decision and advise the student of his or her right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
Right to Consent to Disclosures: Students have the right to consent to disclosures of personally identifiable information contained in the student’s educational records, except to the extent that this policy authorizes disclosure without consent.
Right to File a Complaint: Students have the right to file a complaint with the U.S. Department of Education concerning alleged failures of the School to comply with the requirements of FERPA. The office that administers FERPA can be contacted at Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue, SW, Washington, DC 20202-4605 or at the website: http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
The Gramm-Leach-Bliley Act (GLBA)
The Gramm-Leach-Bliley Act provides consumers the right to the protection of their nonpublic Personally Identifiable Information (PII) in order to prevent identity theft and other related crimes. All individuals who provide PII to the School are protected under the Act. The Act also requires publication of this “Privacy Policy”.
In general, Charles and Sue's School of Hair Design will never release personal information provided by any student or prospective student (including information gathered through websites and web-applications) to any third party for marketing or advertising purposes, or for any other reason beyond those specifically addressed in this policy.
Information Security Practices
Charles and Sue's employs additional office procedures and password-protected computer systems to ensure the security of paper and electronic records. The School does not disclose all of its security procedures to students or the general public to protect the effectiveness of those procedures. Access to social security numbers is strictly limited to those School Officials (see definition below) with a need-to-know, as determined by the Compliance Officer and the Registrar.
Protection of Personally Identifiable Information
School Officials may not disclose personally identifiable information about a student nor permit inspection of their records without the student’s written permission, unless such action is covered by certain exceptions permitted under this policy, as follows:
Definition of a “School Official”: A School Official is a person employed by Charles and Sue's in an administrative, supervisory, academic, research, or support staff position; a person or company with whom the School has contracted (such as an attorney, auditor or accrediting agency); a person serving on the Board of Directors; or a student serving in an official position/capacity or assisting a School Official in performing his/ her tasks.
Information Available to a School Official: The student’s consent is not required when a School Official has a legitimate educational interest in the student’s educational record; that is, if the official needs to review this information in order to fulfill his/her professional responsibility. However, this does not constitute authorization to share that information with a third party without the student’s written consent.
Financial Aid Information: Certain information necessary for the processing of federal financial aid programs may be disclosed to parent(s) of dependent students. In order for a person to be considered a “parent” for this purpose, the individual must be listed as such on the student’s FAFSA application. Further, certain information necessary for the administration of financial aid may be released to federal and state agencies, government contractors, student loan servicers, and other parties.
Subpoenas: Charles and Sue's will release information to a court or other legal entity/jurisdiction based upon a valid subpoena. Administrative subpoenas will be forwarded to the School’s Attorney, who will authorize appropriate release of information.
Emergency Release to Law Enforcement: In cases where the health or safety of students and/or School employees may be in jeopardy, the President or a department manager may release any relevant information to law enforcement and/or emergency services personnel as may be deemed necessary and appropriate to the situation.
Directory Information: Certain information is not considered to be Personally Identifiable Information, and as such can be disclosed. This disclosable data is known as “Directory Information”. The School has designated the following as Directory Information:
Student Name
Hometown
Curriculum (Program of Study)
Enrollment Status
Dates of Enrollment
Certificates Received
Honors or Awards Received
Students who wish to restrict the release of directory information (request a higher level of security) must notify the Office of the Director of Education in writing within five (5) business days from the student’s first day of instruction and provide specific directions regarding the items that the student does not want disclosed. If no notice is received by that date, the information will be classified as directory information.
Student Choice to Release Information:
Students have a right to release information otherwise protected under the policy to persons of their choice. Students who wish to permit the release of additional information to a specific person or persons must complete a Consent to Release Personal Information form for each person and submit it to the Office of the Director of Education.
A student may also have a person or persons accompany him/her during an office visit. If personal information is going to be discussed, the student will be asked whether he/she would like to discuss personal information with others present, and the staff member will receive verbal consent prior to continuing the conversation.
Request for Student Account and/or Financial Aid Information by Agencies
The School cannot directly release financial need or any other financial aid information to outside agencies and/or organizations (scholarship providers, insurance companies, etc.). If the student needs such information to be released, he/she must:
- Be currently enrolled in a program (including students fully accepted/approved for enrollment/re-enrollment but awaiting class start),
- Submit an original, signed release form from the requesting agency (with original student signature) which clearly lists the specific information to be released and the full name, address, and contact information of the agency or organization to which the information shall be released, and
- Upon ompletion of the form by the Financial Aid Office or Administration Office, the form will be returned to the student in a sealed envelope for self-delivery by the student to the agency.
Other Records-Related Issues
The School reserves the right to deny the release of other records not legally required to be released in the following situations:
- The student has any unpaid financial or other obligations to the School (not including courses funded with Federal Student Aid), and/or
- There is unresolved disciplinary action against the student or unresolved litigation between the student and the School.
Annual Risk Assessment
The School will also conduct a risk assessment exercise at least annually to: review the systems used for managing and storing Personally Identifiable Information (PII), identify threats and vulnerabilities that may put the PII at risk, and analyze strategies and actions taken or to be taken to minimize the risks to the extent practical.
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