Departmental Policy on the Release of Student Information

Last updated: October 14, 2021

Table of Contents

 

Purpose/Goal

This document sets out the Office of Registrarial Services (ORS) Policy on the collection, use, disclosure and retention of personal information contained in student records. It also applies to the Office of Graduate and Postdoctoral Studies (OGPS). The Policy applies to all University of Guelph employees and is intended to outline University-wide procedures and criteria. 

This Policy has been created in accordance with the Freedom of Information and Protection of Privacy Act (“the Act”). The Policy is also affiliated with other policies and legislation, such as the Personal Health Information Protection Act (PHIPA), the University of Guelph Privacy Policy and the University of Guelph Records Retention and Disposition Policy. 

 

General Principles

The University will take every reasonable step to protect the privacy and confidentiality of the information contained in students’ records.  For the sake of this policy, an individual is considered a “student” from the point of collection of information as a prospective student.  The University shall refuse to disclose personal information to any person other than the individual to whom the information relates where disclosure would constitute an unjustified invasion of the personal privacy of that person or of any other individual. 

All University of Guelph employees must respect the confidential nature of the student information which they acquire in the course of their work.

Within the University, faculty and staff members are given access to information contained in student records on a need-to-know basis – in other words, information can be shared/used internally with others whose duties and functions require them to have that information.

As a general rule, the University should follow the principle of “data minimization.” This is defined as collecting the minimal amount of personal information that is required to accomplish a legitimate institutional interest.

Electronic records are retained permanently in the Student Information System. Paper records are retained for one year after graduation or seven years after the last day of the last semester in which they are registered, after which they are confidentially shred.

 

Definitions

For the purposes of this policy, 

  • “Student” means any person who is a prospective applicant, applicant, registrant, graduate or non-graduate of a diploma, undergraduate or graduate program.
  • “Applicant” means any person who applies to the University of Guelph for full-time or part-time study in a diploma, undergraduate or graduate program.
  • “Prospective applicant” means any person who submits personal information to the University of Guelph in order to receive information about its diploma, undergraduate or graduate programs.
  • “Third Party” means an entity or person that is not affiliated with the University of Guelph. This disclosure is tightly restricted by law and generally requires written consent of the individual. Examples may include parent or guardian, police, employers, media or companies. 
  • “Internal use.” This is use of personal information by other University of Guelph employees or service providers. 
  • “External disclosure.” This is disclosure of personal information to someone who is not affiliated with the University of Guelph, and generally encompasses “third parties.”

 

Types of Student Information

Overview: Information Contained in Student Records

1.1    A student’s record may contain all or some of the following types of information, which may be considered personal information:

  1. biographic personal information (examples: name, home address, University address, personal and U of G email addresses, telephone number, citizenship, social insurance number, video or photograph, gender, student ID number);
  2. basis of admission information (examples: application, previous studies/academic information, test results, letters of recommendation);
  3. enrolment information (examples: current or past programs of study, courses taken, terms attended);
  4. information related to requests for academic consideration or petitions filed by the student;
  5. medical information in support of requests for academic consideration or financial appeals;
  6. financial Invoice information (examples: tuition, fees, payments, credits);
  7. awards (scholarships/prizes are of public record and bursaries are private unless authorization is received by the student recipient); and
  8. academic performance information (examples: results on exams or tests, grades, averages, degrees obtained, distinctions, sanctions).

Personal information is collected to facilitate the student experience, in the course of university business, for advancement purposes and for the purpose of statistical reporting to government agencies. Personal information may also be used by the University, its authorized agents, approved researchers and/or the government for statistical research purposes.

 

Access to and Disclosure of Information

General Statement on Disclosure in Compelling Situations

Paramount consideration will be for the health and safety of students and other individuals in regard to the disclosure of personal information. ORS may have an obligation to use or disclose personal information, either internally or externally, in the absence of consent in compelling circumstances affecting the health or safety of an individual. Personal Information may also be disclosed in compassionate circumstances to facilitate contact with spouses, close relatives or friends of individuals who are injured, ill or deceased.

Emergency Disclosure

In some emergency situations, requests for student addresses or telephone numbers, or inquiries about the immediate whereabouts of students should be referred to the Campus Safety Office.

In the event of disclosure, whenever possible a record of the disclosure should be maintained. Notification about any disclosure in an emergency must be mailed to the last known address of the individual to whom the information relates.

Public Information

The following is considered public information and may be released to third parties over the telephone or in writing without obtaining the consent of the student:

  • degree(s), diploma(s) or certificate(s) conferred and graduation date
  • awards granted at the graduation ceremony and published in the convocation program

Address Information

Addresses and telephone numbers may be used by University personnel to contact students about university-related matters. This information is considered confidential and is not released to third parties except in emergency situations or in accordance with section 4.1.

University student organizations may request lists using University of Guelph email addresses for selected groups of students (diploma, undergraduate and graduate). These requests will only be approved if the addresses are to be used for a purpose that is consistent with the objectives of the University. Requests from student organizations should be submitted to the Office of Student Affairs for consideration. 

All Other Personal Information Contained in Student Records

Information contained in student records that is not public information or address information as defined above is considered to be personal information. Personal information contained in student records is only disclosed in accordance with governing sections of the Freedom of Information and Protection of Privacy Act. Except in limited circumstances outlined in FIPPA, the University cannot disclose personal information other than to the individual to whom the information relates. Personal information must not be released to third parties except in accordance with 4.1.

 

Disclosure to the Student

2.1    Students will normally have the right to access their own personal information in their student records, with some exemptions and exceptions to disclosure pursuant to Ontario legislation.

2.2    Students wishing to access their official hard-copy file must provide five to seven business days’ notice to support the file being reviewed and materials produced. A fee will be charged (in addition to the charge for an official transcript if ordered) to cover the cost of preparing the file. The original file is not to be released to the student. Requests should be made by email to the University Registrar or the Director of the Office of Graduate and Postdoctoral Studies. Most records are now stored electronically and accessible by students through WebAdvisor.

Evaluative or opinion material must be redacted (i.e., lines and/or pages removed) from the file before access is permitted to the student. This includes material compiled:

  1. for the purpose of determining eligibility or admission to an academic program of the University;
  2. for the purpose of determining eligibility or suitability for the awarding of a scholarship, bursary or other form of financial assistance; or
  3. that is medical information where the disclosure could reasonably be expected to prejudice the mental and physical health of the individual.

2.3    Some student records may be withheld from disclosure to a student under section 5.1 below.

2.4    Transcripts and Third-Party Documents
A student is entitled to an official transcript of their academic record upon payment of the current fee unless there is a sanction in effect (see 5.1 below). The student must request the transcript by completing the transcript request form. It will not be released to a third party without the student’s permission, which is confirmed through the completion of security questions on the form. Transcripts are issued through Enrolment Services. The Ridgetown Campus and the Guelph-Humber Campus issue their own transcripts. Other university departments must not release official transcripts. Students can access their unofficial transcript through WebAdvisor.

Documents received from other institutions and organizations on behalf of the student for admission and/or transfer credit purposes will not be re-issued by the University of Guelph to the student and will not be sent elsewhere at their request.

2.5    Students have a right to request correction to inaccurate information contained in their student records. Where a correction is requested but not made, students may ask that statement of disagreement be attached to that information. 

 

Internal Use/Disclosure to University Personnel

3.1    University Officials
University Officials who require access to student information in order to perform their duties are allowed access to the student record through a formal request process which is reviewed by the University Registrar (or designate). All departments of the University must ensure that appropriate physical and electronic security precautions are in place to safeguard all personal information in their custody.

3.2    Faculty
Faculty have access to class lists but do not normally have access to personal information such as grades and academic standing. Faculty requests for student information must be approved by the department chair. The chair must establish that the faculty member requires access in order to perform their duties before giving approval and forwarding the formal request to the Registrar for review.

 

External Disclosure

4.1    Conditions for Disclosure
Personal information may be released to:

  1. third parties with the student’s written consent;
  2. a police officer or officer of the court on the presentation of a court order;
  3. a federal or provincial government authority in order to comply with a lawful requirement;
  4. collection agencies where a student has an outstanding University of Guelph account requiring assistance in collection;
  5. Alumni Affairs and Development as a condition of a student award. Students completing a financial need assessment form or bursary application have the option to release their name if awarded;
  6. Statistics Canada and the Ministry of Colleges and Universities (see terms in Appendix A);
  7. the Campus Safety Office for emergency situations (see Emergency Disclosure above); and
  8. other parties for the purpose for which the personal information was obtained or compiled or for a consistent purpose.

4.2    Record of Disclosure
When personal information is released to third parties with the student’s consent (4.1a above), the office releasing the information must keep a copy of the signed consent form for at least one semester. However, the documentation for this type of a request will not be kept in the student’s official file.

When personal information is released to third parties without the student’s consent (4.1b, c, and d above) supporting documentation for the release of the record must be kept in the student’s file.

Documentation for the release of information to collection agencies (4.1d above) is kept by Student Financial Services.

 

Withholding Information

5.1    Academic Sanction
The University will apply academic sanction to students who have not made payment, or suitable arrangements for payment of their University account. Academic sanction will also apply to students who have been trespassed from campus for non-academic violations. Academic sanction will prevent one or more of the following:

  1. release of semester examination results
  2. release of transcripts
  3. release of a degree or diploma
  4. registration for a subsequent semester

 

Retention

The University maintains records in hard-copy and electronic format.

Electronic records are held indefinitely.  

Papers records are retained for one year after graduation or seven years after the last day of the last semester in which they are registered, after which they are confidentially shred.

 

Appendix A

Notification of Disclosure of Personal Information to Statistics Canada

Statistics Canada is the national statistical agency. As such, Statistics Canada carries out hundreds of surveys each year on a wide range of matters, including education. It is essential to be able to follow students across time and institutions to understand, for example, the factors affecting enrolment demand at post-secondary institutions. The increased emphasis on accountability for public investment means that it is also important to understand 'outcomes.' In order to conduct such studies, Statistics Canada asks all colleges and universities to provide data on students and graduates. Institutions collect and provide the following to Statistics Canada: student identification information (student's name, student ID number and Social Insurance Number if available), student contact information (address and telephone number), student demographic characteristics, enrolment information, previous education and labour force activity. The Federal Statistics Act provides the legal authority for Statistics Canada to obtain access to personal information held by educational institutions. The information may be used for statistical purposes only, and the confidentiality provisions of the Statistics Act prevent the information from being released in any way that would identify a student. Students who do not wish to have their information used can ask Statistics Canada to remove their identifying information from the national database. On request by a student, Statistics Canada will delete an individual's contact information (name, address or other personal identifiers) from the PSIS database. To make such a request, please contact Statistics Canada:
Via telephone: Monday to Friday 8:30 a.m. to 4:30 p.m. EST/EDST 1-800-263-1136 (Toll Free) OR 1-514-283-8300
Via mail: Institutional Surveys Section, Centre for Education Statistics, Statistics Canada, Main Building, SC2100-K 100 Tunney's Pasture, RHC 13th floor Ottawa, Ontario, K1A 0T6
Via e-mail: PSIS-SIEP_contact@statcan.gc.ca
Further details on the use of this information can be obtained from the Statistics Canada website.

Disclosure of Personal Information to the Ontario Ministry of Colleges and Universities

The University of Guelph is required to disclose personal information such as characteristics and educational outcomes to the Minister of Colleges and Universities under 15(6) of the Ministry of Training, Colleges and Universities Act, R.S.O. 1990, Chapter M.19, as amended. The Ministry collects this data for purposes including but not limited to planning, allocating and administering public funding to colleges, universities and other post-secondary educational and training institutions.

Amendments made to the MTCU Act, authorizing the collection and use of personal information from colleges and universities by the Minister of Colleges and Universities, which were set out in Schedule 5 of the Childcare Modernization Act, 2014, came into force on March 31, 2015. The amendments strengthen the ability of the Minister to directly or indirectly collect and use personal information about students as required to conduct research and analysis, including longitudinal studies, and statistical activities conducted by or on behalf of the Ministry for purposes that relate to post-secondary education and training, including the following:

  1. understanding the transition of students from secondary school to post-secondary education and training;
  2. understanding student participation and progress, mobility and learning and employment outcomes;
  3. understanding linkages among universities, colleges, secondary schools and other educational and training institutions prescribed by regulation;
  4. understanding trends in post-secondary education or training program choices made by students;
  5. understanding sources and patterns of student financial resources, including financial assistance and supports provided by government and post-secondary educational and training institutions;
  6. planning to enhance the affordability and accessibility of post-secondary education and training and the quality and effectiveness of the post-secondary sector;
  7. identifying conditions or barriers that inhibit student participation, progress, completion and transition to employment or future post-secondary educational or training opportunities; and
  8. developing key performance indicators.

Information that the University is required to provide includes but is not limited to: first, middle and last name, Ontario Educational Number, citizenship, date of birth, gender, first three digits of a student’s postal code, mother tongue, degree program and major(s) in which the student is enrolled, year of study and whether the student has transferred from another institution.

Further information on the collection and use of student-level enrolment-related data can be obtained from the Ministry of Colleges and Universities website (English) or Ministry of Colleges and Universities website (French) or by writing to the Director, Post-secondary Finance and Information Management Branch, Post-secondary Education Division, 7th Floor, Mowat Block, 900 Bay Street, Toronto, ON M7A 1L2.

For additional information, view the update on Institutional and MTCU Notice of Disclosure Activities (PDF) or refer to the Frequently Asked Questions related to the Ministry’s enrolment and OEN data activities.