Policy 2200: Disclosure of University Records

Category: Operating Policies
Subcategory: Records
Covered Individuals: University Employees and Members of the Public
Responsible Executive: Vice President for Legal Affairs & General Counsel 
Policy Custodian: Legal Affairs, University Records Manager
Last Revised: 2025/10/28
Previous USU Policy Number: 548
Download the PDF File for Policy 2200

2200.1 PURPOSE AND SCOPE

Utah State University (“USU”) is committed to conducting the business of the University in an open and transparent manner.

The Government Records Access and Management Act (“GRAMA”), found at Utah Code section 63G-2-101 et seq., is Utah’s primary law regarding the public’s access to government records, and the state equivalent to the federal Freedom of Information Act (“FOIA”). Through GRAMA, the public may request access to certain physical or electronic records maintained by USU.

The purpose of this Policy is to implement GRAMA, and outline the retention, designation, and disclosure requirements for Utah State University records. This Policy applies to all records received, created, or maintained by USU.

Records that are governed by the Family Educational Rights and Privacy Act (“FERPA”) are not governed by GRAMA, and are accessed and disclosed pursuant to USU Policy 2201: Student Records (FERPA) and applicable federal laws and regulations.

2200.2 POLICY

2.1 Record Designations

2.1.1 Delegation of Authority

The University President, as the chief administrative officer, delegates to the USU Records Manager the authority to report record designations to the Utah State Archives. This delegation of authority will remain in effect until such authority is rescinded by the University President.

2.1.2 Designation of Record

The University Records Manager, working with Department Record Liaisons, designates each particular record, record series, or information within a record as public, private, controlled, protected, or exempt from disclosure under GRAMA. Pursuant to the delegation of authority from the President, the USU Records Manager reports record designations to the Utah State Archives. See Utah Code Ann. § 63G-2-307.

2.2 GRAMA Record Requests

2.2.1 Requesting a Record

In compliance with GRAMA, USU will provide access to all public records that are not otherwise protected from disclosure and are requested pursuant to a properly submitted GRAMA request. A records request must be made in writing. To request access to USU’s records an individual should complete USU’s GRAMA form, which is available online at www.usu.edu/legal/grama. The completed form will be sent to the USU Records Manager. A person that does not have an email address or is unwilling to accept electronic communications related to the person’s request shall submit, by U.S. Mail or hand delivery, the above information to the USU Records Manager at 1465 Old Main Hill, Suite 101, Logan, UT 84322-146.

Requests submitted to other departments, faculty, or staff within USU may cause USU’s response to be delayed.

2.2.2 Timing of Response

USU will comply with the time for responding outlined within GRAMA.

2.2.3 Fees

Consistent with GRAMA, USU will charge reasonable fees to cover actual costs of responding to an individual’s request. Generally, fees will be assessed for the direct and indirect costs of duplicating and/or compiling a record to respond to the request. USU will require payment of past fees and future estimated fees before beginning to process a request if the requester has not paid fees from previous requests. Charges are not made for reviewing or retrieval of records.

Fees will be assessed according to the USU Records Fee Schedule.

USU may waive fees under certain circumstances as provided for under GRAMA. Requests for the waiver of fees must be made in writing to the USU Records Manager, utilizing the GRAMA request form at www.usu.edu/legal/grama. Waiving of fees is at the sole discretion of the USU Records Manager.

2.3 Disclosures Not Made Pursuant to a GRAMA Request

2.3.1 Subpoenas or Court Orders

GRAMA, FERPA, and other federal and state laws and regulations allow for USU to release otherwise protected records without notice to the individual who is the subject of the record if it is in the receipt of a court order or subpoena signed by a judge from a court of competent jurisdiction.

2.3.2 FERPA Educational Record Requests

FERPA educational records will be released pursuant to USU Policy 2201: Student Records (FERPA) and applicable federal laws and regulations. Educational records that are not accessible and released through USU’s Registrar’s Office pursuant to Policy 2201, will be released through the USU Records Manager following FERPA guidelines and regulations.

2.4 GRAMA Record Response Appeals

2.4.1 Delegation of Authority

Pursuant to GRAMA, an individual may appeal an access denial to Utah State University records to the President, as the chief administrative officer. The President delegates to the Vice President of Finance and Administrative Services authority to issue and effectuate decisions regarding GRAMA record appeals, and the authority to effectuate the appeal process outlined within this Policy. This designation and authority will remain in effect until such authority is rescinded by the University President.

2.4.2 Appeal Process

If the USU Records Manager denies access to a record, the requestor may appeal that determination to the Vice President of Finance and Administrative Services within thirty (30) days of the determination, by providing a written notice of appeal according to Utah Code Section 63G-2-401, and as outlined in the denial USU issued pursuant to Utah Code Section 63G-2-205.

Additionally, a requestor may contest the accuracy or completeness of records concerning the requestor. Appeals from such decisions are governed by the Utah Administrative Procedures Act (“UAPA”), Utah Code Title 63G, Chapter 4. Appeals from such decisions shall be conducted informally rather than formally, per Utah Code Section 63G-4-203.

2.5 Department Record Liaisons

2.5.1 Designation of Department Record Liaisons

On or before the first day of each government fiscal year, each USU college, department, agency, and unit must designate a Department Record Liaison and provide the contact information to Legal Affairs.

Department Record Liaisons are critical to the successful management of records and information across the University’s campus. Records are the evidence of the college’s, department’s, and unit’s activities and transactions, and managing records properly can improve efficiency and reduce risk for the University. Department Record Liaisons are the official custodian for each unit’s records, and are responsible for managing the records in accordance with University policies and procedures.

Department Record Liaisons must attend an annual training regarding University record policies, procedures, and responsibilities provided by Legal Affairs.

2.5.2 Record Retention Schedules

Department Record Liaisons are responsible for identifying the records in the college, department, or unit, identifying how long to keep those records, drafting a retention schedule , and submitting the retention schedule to Legal Affairs for review and approval. Upon Legal Affairs’ approval, the Utah State University Record Manager is responsible for filing the record retention schedules with the Utah State Archives.

2200.3 RESPONSIBILITIES

3.1 Utah State University Records Manager

The USU Records Manager is the individual who has been certified, trained, and registered with the State of Utah, and is responsible for the classification, designation, access, provision, and preservation of USU records in accordance with federal and state law. The USU Records Manager, working with department-level record officers, designates each particular record, record series, or information within a record when access to the that record, record series, or information is requested. The USU Records manager is also responsible for reporting record designations to the Utah State Archives.

2200.4 REFERENCES

2200.5 RELATED USU POLICIES

Information below is not included as part of the contents of the official policy. It is provided only as a convenience for
readers/users and may be changed at any time by persons authorized by the president.

RESOURCES

Guidance

Related Forms and Tools

Contacts

POLICY HISTORY

 Original issue date: 2024/04/09
 Last review date: 2025/10/28
Next scheduled review date: 2025/12/01
Previous revision dates: N/A

This policy is codified as Utah Administrative Rule R813-2 Disclosure of University Records effective 10/22/2024.