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1. Purpose

This document sets out the University’s policy on the collection, use and disclosure of the personal information that forms part of the Official Student Record and the personal information collected on prospective applicants and applicants who do not become students. It applies to the Office of the Registrar, the Faculty of Graduate Studies, and all other academic and administrative units that are the primary and secondary custodians of specified data collected and stored about prospective applicants, applicants, students, alumni/ae and former students of the University.

2. Definitions and General Principles

For the purposes of this policy:
(a) prospective applicant means a person who has indicated an interest in applying for admission to the University and/or who has been identified by the University as a person who will be considered for recruitment (e.g. major scholarship winners);
(b) applicant means any person who has formally applied for admission to the University and whose application is still active;
(c) current student means any person who is active in the current term and/or active in any program at the University [A student is considered to be active in the current term if he or she has taken some action, such as completing registration, paying a tuition deposit or a portion of term tuition fees, or completing an add/drop. A student is considered active in a program within a period of 2 years of being active in a term];
(d) alumnus or alumna means any person who has received a degree, diploma or certificate from the University and is not active in a program [For the purposes of this policy a Western graduate who is also a current student is considered a current student.]; and
(e) former student means any person who has attended the University but has not received a degree, diploma or certificate and is not active in a program.
During the University recruitment process, information will be collected and used to identify prospective applicants who will be encouraged to apply for admission to the University.
During the admission process, information will be collected and used to establish a record and assess an applicant’s qualification for admission to the University.

During the registration process and the student’s subsequent academic career, specific information that constitutes the Official Student Record will be collected, maintained and used by the University to:
• record performance in programs and courses;
• record decisions of academic appeals/petitions and scholastic and non-academic offence decisions and sanctions;
• provide the basis for financial aid, awards and government funding; and,
• assist the University in the academic and financial administration of its affairs which, for example, can range from the day-to-day administration of academic programs to long-range financial or capital planning.
All documentation submitted to the University in support of an application for admission, residence accommodation, or financial award, or as part of any investigation, appeal/petition or request, becomes the property of the University.

Other than disclosure of information specified in Section 4(a) below, the University is committed to taking every reasonable step to protect the confidentiality and privacy of the information contained in the Official Student Record or collected on prospective applicants and applicants who do not become students. Such information must not be disclosed to any individual or institution outside the University, its Affiliated Colleges, or organizations offering joint programs, placements, internships, etc., as part of a course or program at the University, except in the following circumstances:
• with the student’s consent (written preferred);
• under compulsion of law;
• in accordance with the requirements of professional licensing or certification bodies;
• pursuant to an investigation of possible misrepresentation concerning an individual’s references, attendance, performance, status within, or completion of an academic program at the University or at another academic institution;
• in compassionate or emergency situations, as determined by the custodian of the information; and
• in other circumstances set out in the University’s Guidelines on Access to Information and Protection of Privacy [hereafter Guidelines on Access] or as permitted under applicable federal or provincial legislation.
The University will maintain a record of all occasions on which Official Student Record information, other than information specified in Section 4(a), is provided to a third party in the absence of the consent of the student. The contents of this record will be available to the student upon request unless disclosure of the information would compromise an ongoing University or criminal investigation, or is otherwise prohibited by law.

General statistical material drawn from academic records that does not disclose the identities of prospective applicants, applicants, students, alumni/ae or former students may be released for research and information purposes authorized by the University.

3. Information Contained in Official Student Records

Official Student Records, in electronic or paper form, contain the following information relating to a student’s application, admission, and performance at the University:
(a) personal information (name, address, e-mail address, telephone, date of birth, citizenship, social insurance number, student number, photograph, etc.);
(b) basis of admission information (application, record of previous studies, letters of recommendation, test results, etc.);
(c) registration and enrollment information (programs of study, dates of attendance, academic load, courses taken, credits transferred, etc.);
(d) performance information (grades, averages and ranks, narrative evaluations, clinical evaluations, distinctions/awards, special permissions, academic counselling information, degrees obtained, requirements to withdraw, scholastic offence decisions1, etc.);
(e) decisions relating to academic appeals/petitions;
(f) decisions against a student, including appeal decisions, under the Code of Student Conduct;
(g) medical information given to a Faculty related to a student’s performance that is provided by or collected with the consent of the student; and
(h) financial information (tuition fees and other charges, payments, awards, debts, etc.).
The following information is not considered to form part of the Official Student Record and is not covered by the provisions of this policy:
• medical information provided to Student Health Services;
• information relating to the employment by the University of current students, alumni/ae or former students; and
• information other than basic demographic data that is maintained by or on behalf of Alumni Affairs and Development and which is deemed to constitute the Official Alumni Record.
4. Access to and Disclosure of Information

(a) “Public” Personal Information
It is the practice of the University to consider the following information to be publicly available and to provide it to third parties in response to requests (e.g., confirmation of information for a potential employer) without first seeking the consent of the individual each and every time a request is received:
• Full name
• Degree(s) awarded by Western and date(s) conferred, if applicable
Faculty(ies)/Schools in which student is/was enrolled, with major field of study
• Academic or other University honors or distinctions
However, at any time an individual may request that this information cease to be made publicly available by contacting the Office of the Registrar or the Faculty of Graduate Studies, as appropriate, in writing.

(b) Prospective Applicants and Applicants
Prospective Applicants and Applicants may, upon written request, be granted limited access to records containing their personal information in accordance with the Access Procedure set out in Section 6 of the Guidelines on Access. Access will not be provided to records that have been submitted to the University in confidence either implicitly or explicitly (e.g., letters of reference), that document deliberative processes, or are otherwise exempt under the Guidelines on Access. Outdated records for prospective applicants, records for unsuccessful applicants, and records for those who do not accept an offer of admission, are not retained indefinitely. They will be destroyed in accordance with approved retention and disposal schedules.

(c) Current Students
Current students normally have access to their Official Student Record, except material submitted to the University in confidence (e.g., letters of reference) or otherwise exempt from access under the Guidelines on Access, by making an informal request to the appropriate University office. However, students may also request access in accordance with the Access Procedure set out in Section 6 of the Guidelines on Access. If a student has outstanding debts to the University, access may be restricted and certain academic documents (e.g., transcripts, graduation diplomas) may be withheld until payment is received.

(d) Next of Kin
Next of kin will not be given access to information in the Official Student Record except as provided for in Section 2 above, the most common circumstance being with the prior consent of the student. This provision applies regardless of the age of the student (i.e., whether or not they are under the age of 18) as it is the student’s ability to consent, rather than their age, that is the determining factor in their right to exercise control over their own personal information.

(e) Faculty and Staff
Within the University, access to the Official Student Record is restricted to faculty and staff who have a legitimate need for the information in order to carry out the responsibilities of their position or office as it relates to the administration of student affairs and services. For example, access to information contained in the Official Student Record of current students, former students or alumni/ae who are also employees of the University will not be provided for employment related purposes without the prior consent of the individual. Similarly, details of medical information supplied to Faculty offices will not be released without the prior consent of the individual.

Access to financial assistance information of the Ontario Student Assistance Program, to other forms of assistance based on financial need, or to individual earnings is restricted to financial aid staff in the Office of the Registrar, and to a limited number of authorized staff in the Faculty of Graduate Studies, Housing and Ancillary Services, Deans’ and other administrative offices. Relevant information is routinely provided to government agencies with a legitimate need to know, such as those involved in the administration of scholarship or financial aid programs.

The Department of Advancement Services and the Department of Alumni Relations and Development will be permitted access to personal information relating to the identity and location of prospective applicants, applicants and students in order to maintain contact with the individuals and inform them of events, programs and services.

Ensuring the security and privacy of personal information is a collective responsibility of the Office of the Registrar and Faculty of Graduate Studies, and the Deans, Chairs, Directors and managers of academic and administrative units. All full-time and part-time faculty and staff who receive this information must be formally notified of the contents of the Policy, the requirement to adhere to its provisions, and the implications of non-compliance.

E-mail often provides the most efficient and timely medium for communicating with students, prospective applicants, applicants, former students and alumni/ae. However, personal information should not normally be communicated electronically. Where such communication is necessary, a reasonable effort will be made to correctly identify the requester and/or recipient prior to sending personal information.

(f) Alumni/ae and Former Students
An alumnus, alumna or a former student may request access to his or her Official Student Record in accordance with the Access Procedure set out in Section 6 of the Guidelines on Access.

(g) University Student Organizations
Student organizations recognized by the Board of Governors (i.e., the University Students’ Council, Society of Graduate Students, and MBA Association) shall have access to basic student information referred to in Sections 3(a) and (c), for the legitimate internal use of that organization. The disclosure of such information will be subject to agreements with the organizations that they will not disclose any information to a third party, or use the information for any commercial purpose, without the prior agreement of the University.

The USC, SOGS, and the MBAA shall be entitled to publish and distribute within the University community a University-wide directory of students except where students have restricted the disclosure of information. Students wishing to restrict the disclosure of information may do so by contacting the organization.
Student information will not be released to student clubs or organizations not recognized by the Board of Governors without the consent of the students. However, the University will make reasonable efforts to facilitate communication between these groups and individual students. For example, under certain circumstances an information package prepared by a club could be distributed directly to students by the University on behalf of the club, in lieu of giving the club access to student addresses.

(h) Affiliated Colleges and Other Institutions
The University will disclose information in an Official Student Record to its Affiliated Colleges on a need to know basis and in accordance with the terms of the Affiliation Agreement between the University and its Affiliated Colleges. In addition, the University will disclose information in an Official Student Record to other institutions to the extent required for a particular course or program (e.g. off-campus placements, internships, joint programs).

(i) Agents of the University
The University may contract with external agents for the provision of goods or services. These agents may range in size from nation-wide companies to individuals providing volunteer support. As part of the arrangements between the University and the agent, there may be a requirement to disclose certain student information to the agent. However, any such disclosure will be governed by a confidentiality agreement between the University and the agent that specifies the purpose(s) of the disclosure and the University’s expectations with respect to confidentiality.

5. Custody, Storage and Retention of Official Student Records

The University maintains Official Student Records in electronic or paper form. Electronic records contain information required to monitor the progress and performance of students, produce periodic performance reports, and provide attestations of achievement and official transcripts of academic records. They also form the basis of management information needed for the operation of the University and for enrollment reports and statistical information required by government agencies. All portions of the electronic student academic record needed to produce official transcripts are maintained indefinitely. As these records are retained on a permanent basis they will be reviewed periodically, especially at times of an upgrade of the electronic records system or migration to a new system. Metadata pertaining to the system itself will be maintained in hard copy form in the University Archives. Other information in electronic and paper form is retained or disposed of according to the Disposition and Retention Schedules prepared in consultation with the University Archives.

Academic Handbook, General Policy, Student Record Information Privacy Policy

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