PRIVACY & IDENTITY

STUDENT IDENTITY VERIFICATION POLICY

Students enrolled in programs offered by Wright Graduate University are subject to one or more of the following student identity verification methods.

Government-Issued Photo Identification: Students provide a government-issued photo identification during the admissions process. The University uses this identification to verify students’ identity during monthly learning sessions, at least one of which must be attended synchronously per quarter, resulting in the University verifying student identity real-time either in-person or live, on camera, in case of online participation four times a year throughout enrollment.

Secure, Individual Login and Passcode: Students are assigned a secure, individual username and password upon enrollment at Wright Graduate University. These assigned identifiers are used to access Canvas learning management system where students complete and submit coursework and access grade information.

Administrative or Academic Practices: Students are subject to identity verification, at the University’s discretion, through the use of personally identifiable information provided by the student upon application to the University. Students must provide two pieces of identifying information that can be verified by University faculty or staff using information contained within the Student Information System prior to having personally identifiable information released to them by phone. In addition, faculty may commence verification of student identity following review of student work. Changes in academic performance or writing style is monitored and may prompt a request for identity verification.  

Synchronous Attendance (Proctored Exam Policy): Wright Graduate University requires students to participate in monthly weekend learning sessions either in-person at the Milwaukee, Wisconsin, campus or remotely via video conference. Students are required to attend a minimum of one such learning session real-time (synchronously) either in-person or via online meeting with active video and audio participation. Students are encouraged to attend all three weekends synchronously; if a student is unable to do so, he or she may review the video from the weekend and submit notes to verify the video was reviewed in its entirety for no more than two weekends. During these weekend learning sessions, students participate in discussions to demonstrate increasing personally applied emotional intelligence, social intelligence, contribution to others, coachability, authenticity/ presence, co-voyaging, and applying Wright Integrative. Students are graded on their level of participation and this grade contributes to their overall course grade. The University uses these monthly weekends to verify student identity throughout enrollment. The University uses these real-time (synchronous) weekends as proctored exams for the purposes of verifying that the student who enrolled in the program is the same student who earned the degree.

PRIVACY POLICY

Family Educational Rights and Privacy Act

The Family Educational Rights and Privacy Act of 1974, as amended (FERPA) sets out requirements designed to afford students certain rights with respect to their education records. In addition, it puts limits on what information The Wright Graduate University may disclose to third parties without receiving prior written consent from the student.

I. Types of Educational Records Kept

The Wright Graduate University will maintain student records for six years from graduation or last date of attendance. Such records will minimally include the following:

1. A copy of the enrollment agreement and other instruments relating to payment for educational services.
2. Student information, including student name; permanent or other address at which the student may be reached; records relating to financial payments and refunds; and, record of attendance.
3. Date of completion or termination and the reason(s) thereof.
4. Record of any student grievance and subsequent resolution.

The Wright Graduate University shall provide upon request a transcript to any student who has satisfied all financial obligations currently due and payable to the school. The original transcript will be maintained indefinitely. It will provide the name of the student, the title of the program, total number of credit hours of instruction received, dates of enrollment, grade for each course, cumulative grade for the program, and an explanation of the grading system.

II. Procedure to Inspect Education Records

Students have the right under FERPA to inspect and review their education records. A student who wishes to inspect and review his or her records should submit a written request to the appropriate school official. The request should identify as precisely as possible the records the student wishes to inspect. If the requested records are subject to inspection and review by the student, arrangements for access will be made within a reasonable period of time but in no case more than 45 days after the request was made, and the student will be notified of the time and place where the records may be inspected. The school may require the presence of a school official during the inspection and review of a student’s records.

Certain limitations exist on a student’s right to inspect and review his/her own education records. Those limitations include, for example, the following: (i) financial information submitted by parents; (ii) confidential letters and recommendations placed in his/her file prior to January 1, 1975; (iii) confidential letters and recommendations placed in his/her file after January 1, 1975 to which the student has waived his or her right to inspect and review and that are related to the student’s admission, application for employment or job placement, or receipt of honors. In addition, the term “education record” does not include certain types of records such as, by way of example, records of instructional, supervisory, administrative, and certain educational personnel that are in the sole possession of the maker thereof, and are not accessible or revealed to any other individual except a substitute.

When a record contains personally identifiable information about more than one student, the student may inspect and review only the information that relates to him/her personally.

III. Disclosure of Educational Records

The Wright Graduate University generally will not permit disclosure of personally identifiable information from the records of a student without prior written consent of the student. Personally identifiable information is disclosed (some items are mandatory, some discretionary) from the records of a student without that student’s prior written consent to the following individuals or institutions or in the following circumstances:

A. To Wright Graduate University officials who have been determined by the school to have legitimate educational interests in the records.

A school official is: 1) a person employed by the school in an administrative, supervisory, academic or research, or support staff position; or 2) a person employed by or under contract to the school to perform specific tasks, such as an auditor, consultant, or attorney, a person on the Board of Directors.

Legitimate interest: A student serving on an official committee or assisting another school official, or any school official who needs information about a student in the course of performing instructional, supervisory, advisory, or administrative duties for the Wright Graduate University has a legitimate educational interest.

B. To certain officials of the United States Department of Education, the Comptroller General of the United States, the Attorney General of the United States, and state and local educational authorities in connection with state or federally supported educational programs, or in connection with the student’s request for, or receipt of, financial aid necessary to determine the eligibility, amounts or conditions of financial aid, or to enforce the terms and conditions of the aid.

C. To organizations conducting certain studies for or on behalf of the school.

D. To accrediting commissions or state licensing or regulatory bodies to carry out their functions.

E. To parents of a dependent student, as defined in Section 152 of the Internal Revenue Code.

F. To comply with a judicial order or lawfully issued subpoena.

G. To appropriate parties in health or safety emergencies.

H. To an alleged victim of a crime of violence or a non-forcible sexual offense, the final results of the disciplinary proceedings conducted by the school against the alleged perpetrator of that crime or offense with respect to that crime or offense.

I. To persons in addition to the victim of a crime of violence or non-forcible sexual offense, the final results of the disciplinary proceedings described in paragraph H above but only if the school has determined that a student is the perpetrator of a crime of violence or non-forcible sexual offense, and with respect to the allegation made against him or her, the student has committed a violation of the institution’s rules or policies. (The Wright Graduate University, in such instances, may only disclose the name of the perpetrator—not the name of any other student, including a victim or witness—without the prior written consent of the other student(s)).

J. To a parent regarding the student’s violation of any federal, state, or local law or of any rules or policy of the school governing the use or possession of alcohol or a controlled substance if the school determines that the student has committed a disciplinary violation with respect to that use or possession, and the student is under 21 at the time of the disclosure to the parent.

IV. Record of Requests for Disclosure

Except with respect to those requests made by the student him/herself, those disclosures made with the written consent of the student, or to requests by or disclosures to Wright Graduate University officials with legitimate educational interests and disclosures of directory information (or other exceptions described in the applicable regulations), the Wright Graduate University will maintain a record indicating the parties who have requested or obtained personally identifiable information from a student’s education records and the legitimate interests those parties had in requesting or obtaining the information. The student may inspect this record.

V. Directory Information

The Wright Graduate University designates the following information as directory information. (Directory information is personally identifiable information that may be disclosed without the student’s consent):

• Student’s name
• Address: local, email and Web site
• Telephone number (local)
• Date and place of birth
• Program of study
• Participation in officially recognized activities
• Dates of attendance
• Degrees and certificates awarded
• Most recent previously attended school
• Photograph of the student, if available
• Enrollment status (i.e., enrolled, continuing, future enrolled student, reentry, leave of absence, etc.)

Notice of these categories and of the right of an individual in attendance at the Wright Graduate University to request that his or her directory information be kept confidential will be given to the student annually. Students may request nondisclosure of student directory information by specifying nondisclosure, in writing, to the Campus Director’s office. Failure to request nondisclosure of directory information will result in routine disclosure of one or more of the above-designated categories of personally identifiable directory information.

VI. Correction of Educational Records

Students have the right under FERPA to ask to have records corrected which they believe are inaccurate, misleading, or in violation of their privacy rights. The following are the procedures for the correction of records:

A student must ask the Campus Director to amend a record. As part of the request, the student should identify the part of the record he/she wants to have changed and specify why he/she believes it to be inaccurate, misleading, or in violation of his or her privacy rights.

The Wright Graduate University may either amend the record or decide not to amend the record. If it decides not to amend the record, it will notify the student of its decision and advise the student of the right to a hearing to challenge the information believed to be inaccurate, misleading, or in violation of the student’s privacy rights.

Upon request, the Wright Graduate University will arrange for a hearing and notify the student reasonably in advance of the date, place, and time of the hearing. The hearing will be conducted by an individual who does not have a direct interest in the outcome of the hearing. That individual may be an official of the Wright Graduate University. The student shall be afforded a forum for the opportunity to present evidence relevant to the issues raised in the original request to amend the student’s education records. The student may be assisted by other people, including an attorney.

The Wright Graduate University will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence, and the reasons for the decision.

If, as a result of the hearing, the Wright Graduate University decides that the information is inaccurate, misleading, or otherwise in violation of the privacy rights of the student, it will (a) amend the record accordingly; and (b) inform the student of the amendment in writing.

If a statement is placed in the education records of a student in the paragraph above, the Wright Graduate University will: (a) maintain the statement with the contested part of the record for as long as the record is maintained; and (b) disclose the statement whenever it discloses the portion of the record to which the statement relates.

If, as a result of the hearing, the Wright Graduate University decides that the information in the education record is not inaccurate, misleading, or otherwise in violation of the privacy rights of the student, it shall inform the student of the right to place a statement in the record commenting on the contested information in the record or stating why he or she disagrees with the decision of the school.

VII. Student Right to File Complaint

A student has the right to file a complaint with the United States Department of Education concerning alleged failures by the Wright Graduate University to comply with the requirements of FERPA. The name and address of the governmental office that administers FERPA is:

Family Policy Compliance Office
United States Department of Education
400 Maryland Avenue SW
Washington, DC 20202-4605

Wright Graduate University encourages students to resolve issues or complaints regarding privacy using the institution’s published grievance process.