Student Records Policy

Policy Statement:

The Keck School of Medicine of USC maintains the privacy of student education records and allows students the right to inspect their education records consistent with the requirements of the Family Educational Rights and Privacy Act of 1974 (FERPA) and the policies of the University of Southern California. Students have three primary rights under FERPA. They have the rights to inspect and review their education records; control some of the disclosure of information from their education record; and to amend their education records under certain circumstances.

Audience:

Medical Students
Faculty and Staff
Voluntary and Affiliated Faculty and Staff

Definitions:

Education Record
An education record is any record (in handwriting, print, audio or video tape, film, electronic or other medium) maintained by the school of medicine, the university, or an agent of the university such as a clinical affiliate, which is directly related to the student. Information that is captured as a result of a student’s various activities at the university is part of the education record. This information includes, but may not be limited to, logs, databases, or other records of websites the student has visited, purchases made at university facilities, entry day/time into university facilities, university library use and biometric records.

The Keck School abides by the Association of American Medial College (AAMC) Guidelines for Maintaining Active and Permanent Individual Student Records. The medical student record includes, but is not limited to, the following:

1. AMCAS application

2. Supplemental application

3. Transcript(s) of coursework completed at other institution(s)

4. Transcript of all medical school coursework

5. Dates of enrollment in medical school, including matriculation date, start and end dates of each academic year, dates of leaves of absence, withdrawal, dismissal and/or graduation date

6. Student Photograph

7. Medical Student Performance Evaluation

8. Course Schedule

9. Clerkship and Course student performance evaluations

10. Disciplinary Record (final disposition of action only, i.e., dismissal)

Retention of medical student education records follows the AAMC’s Committee on Student Records (COSR) Guidelines for Maintaining Active and Permanent Individual Student Records.   The full guidelines are available on the AAMC COSR website. The Keck School also abides by the University’s Record Management Policy. Records are maintained for five (5) years post graduation or separation from the university to abide by these guidelines and those of external reporting agencies as needed for required reporting.

The term “education record” does not include:

1. Records of instructional, supervisory, administrative, and educational personnel ancillary to those persons that are kept in the sole possession of the maker and are not accessible or revealed to any other person except a temporary substitute for the maker of the record.

2. An employment record of an individual whose employment is not contingent on the fact that he or she is a student, provided the record is maintained in the normal course of business and is used only in relation to the individual’s employment.

3. Records maintained by the university’s Department of Public Safety when the record is maintained solely for law enforcement purposes, is revealed only to law enforcement agencies of the same jurisdiction, and is maintained separately from education records.

4. Records maintained by the Student Health Center, University Counseling Services, the School of Dentistry, or other university entity providing health or counseling services when the records are used only for treatment of a student and are made available only to persons providing the treatment.

5. Criminal background check results, toxicology screening results, and disciplinary action records proceedings.

6. Records which contain only information about an individual after he or she is no longer a student at the university, such as alumni records.

Student
Any person who attends or has attended a class, seminar, or academic program of the university. A person will be considered in attendance when they have formally enrolled in a class or seminar.

School Official
A person employed by the school of medicine in an administrative, supervisory, academic, research or support staff position. A contractor, consultant, volunteer, or other outside party providing services such as voluntary faculty, resident, or staff at a clinical affiliate.

1. A person employed by the school of medicine in an administrative, supervisory, academic, research or support staff position.

2. A contractor, consultant, volunteer, or other outside party providing services such as voluntary faculty, resident, or staff at a clinical affiliate.

3. A person defined as a University Official in the USC Student Record Policy.

Disclosure
To permit access to or the release, transfer, or other communication of education records, or the personally identifiable information contained in those records.

Legitimate Educational Interest

FERPA defines a legitimate educational interest as the need for a school official to review an education record to perform their duties.

Annual Notification:
Students will be notified annually of their FERPA rights by publication appearing in the “Student Education Records” section of the Keck School of Medicine Doctor of Medicine Program Student Handbook and the University’s student handbook.

Confidentiality of Student Educational Records
According to FERPA, personally identifiable information in an education record may not be released without prior written consent from the student. Some examples of information that may not be released without prior written consent of the student are:

• Birth date

• Religious affiliation

• Citizenship

• Disciplinary status

• Ethnicity

• Gender

• Grade point average (GPA)

• Marital status

• SSN and student ID number

• Grades and exam scores

• Course and Clerkship Narrative Evaluations

• Medical Student Performance Evaluation (MSPE)

The Keck School will not release personally identifiable information from a student’s education record without the student’s prior written consent. Exceptions are noted in the university’s policy (located in the Office of the General Counsel and in the Office of the Vice President for Student Affairs) concerning the privacy of student education records and include: access by school officials the Keck School has determined to have a legitimate educational interest; access by school officials at other schools where the student seeks to enroll; access for the purpose of awarding financial aid; and subpoenas. 

Directory Information:
FERPA has specifically identified certain information called directory information that may be disclosed without student consent. Although directory information may be disclosed without student consent, the Keck School and the university are not required to release directory information.

USC has designated the following information as directory information and may release this information, unless the student has submitted a request for non-disclosure:

• Address (local and permanent)

• Telephone number (local and permanent)

• University email address

• Student photo

• Attendance dates

• USC degrees earned (with dates)

• Academic honors

• Major, minor and degree objective

• Expected date of graduation

• Previous schools attended

• Enrollment status (class level)

• Currently enrolled (Y/N)

• Participation in officially recognized activities and sports

Access to Student Education Records:  Students

Medical students have access to all aspects of their student education record electronically via the learning management and student information systems, and education records maintained in paper files.  

1. A student wishing to review education records that are not maintained in the learning management or student information system must submit a written request to the Keck School Registrar. This request can be emailed to [email protected], submitted by mail to the address below, or delivered in person to the Keck School Registrar’s Office in the Keith Administration building, room 218.

Address: Keck School Registrar Office
1975 Zonal Avenue, KAM 218
Los Angeles, CA 90089

2. The Keck School Registrar will assemble the student education record for review as soon as possible, usually within 5 business days, but no later than 45 days after receipt of the written request as required by FERPA.

3. The Keck School Registrar will contact the student by email informing them that their education record is ready for review. The right of inspection and review includes: the right to access, with an explanation and interpretation of the record, and the right to a copy of the education record when failure to provide a copy of the record would effectively prevent the student from inspecting and reviewing the record. The school of medicine and the university may refuse to provide a copy of a student’s education record provided such refusal does not limit access.

4. Limitations exist on students’ rights to inspect and review their education records. For example, the school of medicine is not required to permit students to inspect and review the following:

o The financial statement of the student’s parents and information contained therein.

o Confidential letters and statements of recommendation for which the student has waived in writing his or her right to access, or which were placed in the student’s education record prior to January 1, 1975.

o Records connected with an application to attend the university or a component unit of the university if that application was denied.

o Records excluded from the definition of “education record” by this policy.

o Education records containing information about more than one student. (However, the institution must permit access to that part of the records that pertains only to the inquiring student.)

5. The school of medicine reserves the right to charge a reasonable fee for the cost of providing a copy of education records to students. There is no charge for a transcript for a current student.

6. With respect to education records to which students retain a right of access under this policy, the school of medicine reserves the right to deny students copies of academic transcripts and other records under any of the following circumstances: 

1. The student has an unpaid financial obligation to the university.

2. There is an unresolved disciplinary action against the student.

3. The veracity of the academic transcript or record is in question.

Restricting Release of Education Record: Students
According to FERPA, a student can request that the school of medicine not release directory information about them. Students who wish to restrict the release of their information must submit an email to [email protected] with “Request to Restrict Directory Information” in the subject line. The email request must originate from the student’s USC email account. The student must also make this request with the University’s Registrar’s Office by submitting an email request to [email protected] with “Request to Restrict Directory Information” in the subject line. The email request must originate from the student’s USC Email account. In the request, the student must specifically state whether to:

1. restrict the listing of their information on the university’s student directory, which is available only to USC students, faculty, and staff.

2. restrict the release of their information to any inquirer (for example: current enrollment at USC, class level, major, expected graduation date, degrees earned); or

3. restrict both above (remove student’s listing on the USC student directory AND refuse to provide any information about the student to an inquirer).

Students who request that the Keck School of Medicine and USC restrict the release of their information acknowledge that their names will not appear in the commencement bulletin or other university publications. Employers, credit card companies, loan agencies, scholarship committees and other similar entities will be denied any of the student’s information and will be informed that we have no information available about the student’s attendance at the Keck School of Medicine and the university.

Correction of Education Records: Students
Students have the right to request correction of records that they believe are inaccurate, misleading, or in violation of their privacy rights. This provision for amendment does not apply to disputed grades or other academic evaluation disputes. Following are the procedures for the correction of records.

1. Students are entitled to an explanation of any information contained in records to which they have a right of access under this policy. If a student believes his or her records are inaccurate, misleading, inappropriate, or otherwise in violation of his or her right of privacy, he or she may request that the records be amended. The written request should identify the part of the record the student wants changed, should specify the reason the student believes it is inaccurate, misleading or in violation of his or her privacy rights, and should indicate the nature of the change or amendment desired.

2. The Keck School registrar will review the request within ten business days and may consult the Vice Dean for Medical Education.

3. If the request is granted, the Keck School Registrar will amend the record in question. If the request is denied, the student shall be informed of the refusal and advised of the right to a hearing.

4. In instances when a dispute cannot be resolved between the student and the Keck School Registrar, the student may request a formal hearing by the university to resolve the issue. Questions about and requests for formal hearings should be directed to the Office of the General Counsel. This provision for amendment does not apply to disputed grade information on academic transcripts. More information about the hearing process can be found in the University of Southern California’s Student Records Policy.

Access to Student Education Records:  School Officials

1. Access to student education records is provided to school officials with a legitimate educational interest to perform their duties. Access is provided through the learning management and student information systems.  Access will be terminated upon separation from the school or position where access was required for the performance of duties.

2. To obtain access to the learning management system and/or student information system, a User Access Form must be submitted. A code of conduct is included in the User Access Form and school officials are required to confirm that they will adhere to this code before access to student education records is granted. School officials are only provided access to the portion of the student education record needed to perform their duties.

3. Depending on the level of access need, FERPA training will be required, and training must be redone according to USC policy to maintain access to students’ education records. 

If the student education record does not exist in these platforms, the school official will need to submit a written request to the Keck School Registrar to obtain access to the student education record. The request will be reviewed and acted upon in consultation with the Vice Dean for Medical Education and in accordance with FERPA, school of medicine and university policies.

Questions about the Student Records Policy should be directed to the Keck School Registrar.

Email:                         [email protected]
Phone:                         323-442-1875
Office Location:         Keith Administration Building, Room 218, Health Sciences Campus

Reviewed and Approved April 16, 2025

Medical Education Executive Council