Procedure 5.6.1: Security and Confidentiality of Student Information for Financial Aid Records

Effective Date: Tue, Aug 12, 2008

The HCC Financial Aid Office complies with the Confidentiality and Security of Student Information Policy by implementing the following operational procedures. The Financial Aid Office also complies with the campus-wide Procedure for Security and Confidentiality of Student Information.

Accessing Student Information

  1. Financial Aid records are accessible by
    1. Director of Financial Aid
    2. Assistant Director of Financial Aid
    3. Financial Aid Specialist/VA
    4. Financial Aid Specialist
    5. Administrative Support (Part-time)
    6. Other college officials with “need to know” rationale
    7. Individual students to their own record based on FERPA guidelines by appointment with the Director of Financial Aid
    8. Right to Inspect and Review. A student has the right to inspect, review, or be informed of his/her financial aid records (but only with respect to information about that particular student), except that the following materials shall not be available:
    9. Financial records of parents of the student or any information contained in those records.
  2. Financial Aid records for years prior to 2008-09 are maintained in a fire resistant, combination-lock secured vault located in Student Development Services.
  3. Financial Aid records for years prior to 2008-09 may be removed from the vault during normal operating hours (M-Th 8 to 7 and F 8-4) for record processing.
  4. Current Financial Aid records are created and maintained digitally and are accessible via AIG’s archival solution, DocEscan. These files are accessible via user identification and password only.
  5. A student who wishes to access his/her financial aid record must submit a request in writing to the Director of Financial Aid and will be given access within a reasonable period of time not to exceed 45 days after receipt of the request. The FA Director will respond to reasonable requests by a student for explanations and interpretations of his/her financial aid records. If circumstances effectively prevent a student from exercising the right to inspect and review his/her financial aid records, the FA Office will provide the student with a copy of the records requested or make other arrangements for the student to inspect and review the requested records.

Collection of Student Information

  1. Financial Aid records, in general, are composed of the following
    1. Free Application for Federal Student Aid (FAFSA) completed by student and/or parent with signatures if the FAFSA has been submitted by HCC.
    2. Verification Worksheet (if selected)
    3. Appropriate year federal tax returns including W2s, 1099s and all schedules (if selected)
    4. Documentation of other untaxed income (i.e., Social Security)
    5. HCC transcript
    6. Satisfactory Academic Progress (Probation or Suspension) if applicable
    7. Award letters
    8. Signature pages (if required)
    9. Drug Worksheet (if required)
    10. Zero Income Form (if applicable)
    11. R2T4 forms/correspondence (if applicable)
    12. Other correspondence
  2. The components are collected from the student and/or parent during the financial aid application and awarding process.
  3. Any information related to federal and/or state awards specific to the student is collected, scanned and viewable via DocEscan.

Distribution of Student Information

  1. Financial Aid records are not distributed beyond the Financial Aid Office.
  2. Information from Financial Aid records may be disbursed (released) as follows
    1. Release without Consent. No release of personally identifiable information shall be made by the Financial Aid Office without a student’s prior consent, unless:
  3. The disclosure is to other school officials, including instructors, within HCC who have been determined to have legitimate educational interests. Criteria to be considered by HCC include
    1. Whether the person requesting the information is a current employee of HCC;
    2. Whether the person requesting the information is in a policy administration or enforcement role such as President of HCC.
    3. Whether the person requesting the information either is or has been (i) an instructor of the student, (ii) responsible for evaluating the student’s performance in an HCC course, (iii) responsible for assessing the student’s eligibility for an award, scholarship, or other type of recognition, (iv) responsible for administering all or part of an HCC course or program in which the student intends to participate, has participated or is participating, (v) responsible for counseling the student or determining or reviewing disciplinary action against the student; and,
    4. Whether the information requested will be used by the person requesting the information in the performance of his/her job duties.
  4. The disclosure is to officials of other schools, school systems or institutions of postsecondary education where the student intends to enroll. In the case of Financial Aid records, this disclosure of information involves a Consortium Agreement between colleges related to students taking classes at more than one college at one time.
  5. The disclosure is made in connection with an audit or evaluation of federal or state supported education programs, or for the enforcement of or compliance with federal legal requirements relating to those programs, to the Comptroller General of the United States, the Secretary of Education, or state and local educational authorities, provided that the information is protected in a manner that does not permit personal identification of individuals by anyone other than the official to whom it is disclosed and is destroyed when no longer needed for the purposes for which it was disclosed (unless the student has consented to the disclosure or the collection of the information disclosed specifically authorized by federal law).
  6. The disclosure is made in connection with the student’s application for or receipt of financial aid and the information disclosed is necessary for such purposes as to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid.
  7. The disclosure is to state and local officials to whom the information is specifically allowed to be reported related to the juvenile justice system and pursuant to state statutes adopted before and after November 19, 1974.
  8. The disclosure is to an organization conducting a study for, or on behalf of, educational agencies or institutions to develop, validate or administer …student aid programs …, provided that the study is conducted in a manner that does not permit personal identification of students by individuals other than representatives of the organization, and the information is destroyed when no longer needed for the purposes for which the study was conducted.
  9. The disclosure is to accrediting organizations in order to carry out their accrediting functions.
  10. The disclosure is to the parents of a dependent student, as defined in Section 152 of Internal Revenue Code of 1954;
  11. The disclosure is in compliance with a judicial order or pursuant to any lawfully issued subpoena.
  12. The disclosure is of information that HCC has designated as directory information. A student has the right to refuse to let the College designate any or all of the types of directory information listed in this Policy as being directory information for that student. To do this, the student must notify HCC by providing a written statement to the Director of Financial Aid within 10 days of the beginning of the applicable semester, listing those types of information about the student that he/she does not want to have designated as directory information. HCC may disclose directory information about former students without notifying them as to the types of information that have been designated by HCC as directory information and without providing them with an opportunity to refuse.
  13. The disclosure is to the student.
  14. The disclosure is to an alleged victim of an crime of violence as defined in section 16 of title 18 of the United States Code
  15. The disclosure is to any other person, entity, or organization authorized to receive personally identifiable information pursuant to FERPA, the regulations implementing FERPA, or other applicable law or regulation.
    1. Personally identifiable information may be released without a student’s prior consent to appropriate persons in connection with an emergency if knowledge of the information is necessary to protect the health or safety of the student or other persons. Specific factors should be taken into account in determining this disclosure and these factors are listed elsewhere in this document.
    2. A student may provide written consent for the release of his/her financial aid records. This request must be signed and dated by the student and delivered to the Director of Financial Aid. Upon receipt of this request, the personally identifiable information contained in the student’s financial aid record will be provided that information. The student’s written consent must include (1) the specific portion of the record that may be disclosed; (2) the purpose of the disclosure; (3) the name of the party or class of parties to whom such records may be disclosed.
      1. Notice must be given to such third parties that the information is not to be disseminated to others without further consent of the student. In the event a student wants a copy of the records released, such a copy will be provided on request and in compliance with copy requirements.

Processing Student Information

  1. Information in financial aid records is processed in the Financial Aid Office at HCC.
  2. The process consists of the following:
    1. Student completes Free Application for Federal Student Aid (FAFSA) either on-line at www.fafsa.ed.gov or in the FAO with assistance from the financial aid staff.
    2. FAFSAs completed in the FAO are submitted to the Department of Education (DOE) via the Datatel interface with the DOE.
    3. The results of the FAFSA called an Institutional Student Information Record (ISIR) are received from the DOE.
    4. The student is mailed a letter with enclosures indicating that the ISIR is being processed. The enclosures are a Scholarship Application, a Work-Study Application and an Alternative Loan Brochure.
    5. Students may complete the Scholarship Application and/or Work-Study Application and submit to the FAO for consideration.
    6. ISIRs are evaluated for missing information, verification and degree-seeking status and students are notified accordingly.
    7. Missing information and verification paperwork (including tax forms) are scanned, when possible, as received. Otherwise, copies are made and subsequently scanned.
    8. FA records are evaluated for completeness, Satisfactory Academic Progress (SAP) is checked and postcards are mailed to federal and state grant recipients.
    9. Postcards indicate the online procedure for completing the award process.
    10. Emails are received indicating that students have completed the FA Quiz and ready to be awarded.
    11. Award letters are mailed to students and awards are put on student’s electronic accounts.

Protection of Student Information

  1. All HCC Financial Aid records prior to 2008-09 are in hard copy file folders with labels showing student name and colleague identification number.
  2. All HCC Financial Aid records for 2008-09 and forward are in digital format with student name and colleague identification number.
  3. No hard copy file folders with FA records are left in individual offices unattended.
  4. All HCC FA records prior to 2008-09 are kept in a fire-resistant, combination-lock protected vault located in Student Development Services. These records are accessible to authorized personnel only.
  5. All HCC FA records for 2008-09 and forward are in digital format and accessible only to authorized personnel with password protection.
  6. At the HCC level, FA records use the colleague identification number for identification purposes.
  7. Students create their own unique password when setting up their student account in Haywired, campus email, Blackboard, etc. This is not the same as the colleague identification number which is created when the student applies to HCC.
  8. Students inquiring about or applying for financial aid are counseled in private offices except in the case of the financial aid staff on duty at the open counter in the Student Development Services lobby. When possible this staff person will take the student to a private office for counseling.
  9. All documents related to FA records are shredded before discarding.
  10. Financial Aid staffhave access to specific Datatel mnemonics which allows processing of financial aid records. This access is password protected and permitted through written authorization from the staff supervisor(s).

Storage of Student Information

  1. All FA records prior to 2008-09 are stored in a fire-resistant, combination-lock vault located in Student Development Services.
  2. All FA records for 2008-09 and forward are digitally archived and maintained on AIG’s archival solution, DocEscan which is password protected.

Usage of Student Information

  1. Financial Aid records are used for the express purpose of determining and awarding federal, state and institutional financial aid to HCC students.
  2. Any other use of FA records is unauthorized and forbidden.

Transmittal of Student Information

  1. FA records information with social security numbers and birth dates are distributed via email or posted on networks by using the last four digits of the social security number.
  2. 2.Financial Aid records require use of students’ social security numbers in the submission of the Free Application for Federal Student Aid (FAFSA). The Department of Education Central Processing Center requires a data base match between the student’s name and the social security number before the application is processed. When no match is present, a student is required to submit a copy of his/her social security card for verification purposes.
  3. FA records information (Financial Aid Transcripts) are not transmitted between colleges with the exception of Consortium Agreements between schools. Financial Aid Transcript information is available to all financial aid professionals via the web at www.nslds.ed.gov.
  4. Consortium Agreements occur between colleges when students who are attending and receiving financial aid at one college are also attending another college at the same time. Because a student may receive financial aid at only school at a time, the purpose of the Consortium Agreement between participating colleges is to combine the credit hours being taken at the non-financial aid granting school with the hours being taken at the financial aid granting school for the purpose of paying the student for the total number of hours he/she is taking in any given semester. This agreement requires documentation of tuition and fees payment and course registration. The agreement is initiated by the degree-granting financial aid granting school (home) in a letter to the financial aid office at the non-degree granting, non-financial aid granting school. That school verifies that the student is enrolled there, signs the agreement, returns it to the home school and the home school awards the student accordingly.

Disposal of Student Information

  1. All hard copies of financial aid records are shredded based on federal guidelines for records maintenance. The Federal Student Aid Handbook published annually by the Department of Education contains a chapter on Recordkeeping and Disclosure. The contents of this chapter include information on the following:
    1. Required Records
    2. Record Retention Periods
    3. Record Maintenance
  2. Examination of Records
  3. Privacy of Student Information (FERPA RULES)
  4. Establishing and Maintaining an Information Security Program

Business Continuity

HCC’s risk assessment (and in particular, the Financial Aid Office) is addressed in the HCC Business Continuity Plan referenced elsewhere in this policy.

Responsibility for Security and Confidentiality

The Director of Financial Aid is responsible for security and confidentiality of student information with regard to financial aid records and information.

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