Purpose
The College Financial Aid Office is committed to safeguarding sensitive student information, particularly data gathered through the Free Application for Federal Student Aid (FAFSA) and Federal Tax Information (FTI). This policy outlines how the College uses, shares, and protects student financial aid data in compliance with federal laws, including the Higher Education Act (HEA), Family Educational Rights and Privacy Act (FERPA), and the Internal Revenue Code (IRC) Section 6103.
Data Covered
- FAFSA Data: Includes personal and financial information submitted by applicants and contributors, such as demographic information, income, assets, and any other information used for determining financial aid eligibility.
- Federal Tax Information (FTI): Includes federal return information transferred from the IRS through the Department of Education, including but not limited to Adjusted Gross Income (AGI), tax filing status, and untaxed income.
- Derived FAFSA Data: Includes the Student Aid Index (SAI), Pell Grant eligibility, and financial aid history obtained through the National Student Loan Data System (NSLDS).
Permissible Uses of Data
Student financial aid data, including FAFSA and FTI, will only be used for the following purposes:
- Determining eligibility for financial aid
- Administering, awarding, and monitoring aid (including federal, state, institutional, and private scholarships)
- Complying with legal reporting requirements such as IPEDS
- Research related to improving college access, persistence, and completion, provided no personally identifiable information (PII) is disclosed
Permitted Data Sharing
The College may share FAFSA and FTI data without written consent for the following purposes:
- With students directly upon their request
- With internal school officials who have a legitimate educational interest in administering financial aid
- With auditors, state, and federal agencies conducting mandatory evaluations
- With organizations such as TRIO or GEAR UP that support students in applying for aid toward cost of attendance
Sharing FAFSA data with other entities beyond these purposes, such as for academic or other non-financial purposes, requires written consent from the student.
Restrictions on Data Sharing
- FTI: The sharing of FTI is highly restricted and will only occur when necessary for administering student aid. Disclosure of FTI to external entities, even with student consent, is prohibited unless specifically allowed by federal law.
- FERPA: FAFSA data, excluding FTI, is part of a student’s educational record and is protected under FERPA. Disclosure to school officials requires a legitimate educational interest, and external sharing beyond necessary financial aid administration requires student consent.
Student Rights
Students have the right to:
- Access their financial aid information, including FTI, upon request
- Provide consent for sharing their data with external scholarship organizations or other entities assisting with financial aid applications
- Be informed of any disclosures made beyond the permissible uses stated in this policy
Data Security
The College employs robust security protocols to protect financial aid data from unauthorized access, including encryption, password protection, and limiting access to authorized personnel only. Contractors assisting in the administration of financial aid are subject to the same data protection standards.
Consent Requirements
Any disclosure of FAFSA or FTI data for purposes beyond financial aid administration will require separate, written, and dated consent from the student. This consent can be electronic and must specify the purpose and the parties involved in the disclosure.
Contact Information
For questions regarding this policy or to request data access, students may contact the College Financial Aid Office at financialaid@lafayette.edu or 610-330-5055.
Students who need financial aid information for third parties may also provide requested data directly to third parties using the following methods:
All personnel with access to FAFSA data shall be required to complete annual training on the importance of confidentiality, data security procedures, and their responsibilities under this policy. Regular training sessions and updates shall be provided to ensure ongoing awareness and compliance. Any violations of this policy shall be reported to the appropriate authorities within the institution.