University Development Office: Record Sharing Policy

This policy is created to guide Development and Alumni Relations employees (“Data Providers”) on the appropriate sharing of demographic and financial information stored in the University’s enterprise alumni and donor database with external sources (“Data Recipients”).

Unit Policy

Title

University Development Office: Record Sharing Policy

Introduction

Purpose

This policy is created to guide Development and Alumni Relations employees (“Data Providers”) on the appropriate sharing of demographic and financial information stored in the University’s enterprise alumni and donor database with external sources (“Data Recipients”).

Scope

This policy does not apply to:

• third party vendors contracted to perform services on the University’s behalf where a Risk Assessment has been completed, and approval received from the Data Governance Oversight Group (DGOG)
• volunteers conducting University fundraising and alumni relations activities who have signed a Volunteer Confidentiality Agreement.

Policy

Policy Statement

Data recipients are expressly prohibited from using this information for any commercial, political or external solicitation purpose.

If a record is marked CONFIDENTIAL, no information in that record should be shared.

If a record is marked ANONYMOUS, no giving information in that record should be shared.

This policy is intended for use with small, individual external requests. Requests for reports or data on a large group (e.g. alumni living in a particular city, donors of a certain amount, etc.) are generally not granted. These requests should be directed to either the Director of Operations at Carolina Alumni or the Associate Vice Chancellor for Campaigns & Strategy in the University Development Office.

The following information CANNOT be shared:

• Any information on a CONFIDENTIAL record
• Any patient data protected under HIPAA
• Social Security Number (does not exist on Davie record)
• Birth date
• Gender or Ethnic group
• Parents’ names and addresses gathered from the student record
• State and/or US Territory from which the student entered the University (aka “Hometown Address”)

The following directory information CAN be shared:

• Full name, including title, generational suffix, and professional suffix
• Current Addresses (home and business)
• Primary Phone
• Primary email address
• Class Year
• Major field of study (see notes)
• Dates of attendance (see notes)
• Degrees and awards received (see notes)
• Most recent previous educational institution attended
• Participation in officially recognized activities and sports
• Current Employer / Job Title

Notes

1. Inquiries pertaining to a donor’s giving history are assessed on a case-by-case basis.
2. Requests to verify educational history details (degree, major field of study, award dates, entrance dates, etc.) must be referred to the Registrar’s office. The Registrar is the only source for official degree information. For example, this applies to a potential employer looking to verify someone’s graduation status and degree information.
3. These rules are not intended to apply to commercial vendors who are contracted to assist with development work. Any commercial vendor (e.g. mailing house, data analysis) must sign a non-disclosure agreement before receiving any data, undergo a Risk Assessment, and receive DGOG approval
4. Information contained in newspaper clippings, questionnaires, correspondence — anything gathered after a student leaves UNC — is not private per FERPA and may be shared.
5. If an alumna/us is making the request, please ask them to verify their own contact information to help keep our records updated.
6. If you are concerned about the legitimacy of a request, offer to forward a message to the donor/alum as appropriate.

Student Information in the alumni & donor database

Be very careful about how student information is shared. The Family Educational Rights and Privacy Act (FERPA) restricts the external dissemination of student information. All student records maintained by an educational institution are covered by FERPA, and penalties for releasing information covered by FERPA are harsh. Generally, directory information may be shared unless the student has asked us to withhold it – those records are marked CONFIDENTIAL in our system. Once a student has invoked FERPA and has a confidential record, we must honor that request until we are asked to remove it by the student/alum. The directory information, during the time it is protected by FERPA, cannot be shared externally. It is appropriate and acceptable for the University to use this information to communicate with the student even if he/she has invoked FERPA protection.

If you have any questions about this policy, please contact the Director of Operations at Carolina Alumni or the Associate Vice Chancellor for Campaign & Strategy in the University Development Office.

NOTE: UNC-Chapel Hill’s definition of “directory information” found here, and is included below (as of 2026-06-02):

FERPA provides the university the ability to designate certain student information as “directory information.” Directory information may be made available to any person without the student’s consent unless the student gives notice to restrict. UNC Chapel Hill has designated the following as directory information: the student’s name, addresses, telephone number, email address, date/place of birth, major field of study, class (e.g., sophomore, senior), enrollment status, person identification number (PID), anticipated graduation date, participation in officially recognized activities and sports, weight and height (members of athletic teams only), dates of attendance, degrees and awards received, the most recent previous educational agency or institution attended by the student, and the county, state, and/or U.S. territory from which the student entered the University.

Definitions

• Data Provider: Employees, work-study students, and contractors granted access to Alumni and Donor data. These people may be employed by the University or an associated entity such as the UNC Health Foundation, or Carolina Alumni.
• Data Recipient: an individual or organization requesting data about specific records who is not under contract to perform advancement and/or fundraising services on the University’s behalf with the information they are requesting.

Related Requirements

External Regulations

• Policies and Procedures Under the Family Educational Rights and Privacy Act of 1974 (“FERPA”)
• HIPAA Privacy and Security Officials Policy
• University Policy Memorandum # 21: Access to Student Records

Contact Information

Primary Contact

Name: Jeff Hill, Associate Vice Chancellor for Campaigns and Strategy

Telephone: (919) 962-6561

Email: jeff_hill@unc.edu