Number: INST.G.10.010

Defining and Establishing Ownership of HLC Information

HLC shall have ownership of the following information:

1. Information created for HLC by one of it consultants, evaluators, staff or other party in furtherance of an HLC process or review;
2. Information created for HLC by institutions or submitted to HLC by institutions in support of an application for new or continuing status, approval of substantive change or other HLC process or request for information;
3. Information collected or received by HLC from other sources including peer reviewers; and
4. Any other information known by HLC or otherwise collected or received in support of its mission and purposes.

Information referenced under this policy may exist in electronic, written or other format.

HLC Retention and Management of Information

HLC shall have the right to retain and manage such information as appropriate to fulfill its mission and purposes. Such management will include organizing, digitizing, displaying and storing such information. HLC shall adopt appropriate procedures governing the retention and management of information. These policies shall be applicable to HLC and its staff as well as to any individual acting as a reviewer or decision-maker for HLC. HLC shall work with third-party agents or contractors to ensure that information retention and management is handled in observance of such procedures to the fullest extent possible within the terms of that relationship.

HLC Information on Its Website

HLC will provide information available to public on HLC’s website about the following: the Eligibility Requirements, Criteria for Accreditation, Assumed Practices, and Obligations of Membership; accreditation and candidacy status and related policies and procedures for achieving and maintaining such status; policies and procedures related to sanctions and withdrawal or denial of status; a directory of member institutions and the date of the next comprehensive evaluation and information related to HLC monitoring; where necessary, information correcting inaccurate claims made by member institutions or other institutions regarding their accreditation status with HLC or results of a recent evaluation visit or accrediting action taken by HLC; and information about the members of HLC’s decision-making bodies, institutional liaisons and other principal HLC staff.

HLC Correction of Institutional Information. If an institution accredited by, in candidacy status with, or applying for such status with HLC inaccurately discloses its accreditation status, an action by HLC, or the contents of an HLC evaluation report, HLC will provide for public correction of that information. It will provide this correction through its website or through release of a public statement or Public Disclosure Notice. It will also act through appropriate policies to enforce its Obligations of Membership with any member institution, if any Obligation has been violated by this inaccurate disclosure.

HLC Release of Information

HLC shall release HLC information in compliance with the following policies:

Institutional File Information. HLC shall release information about a member institution in response to a request by the following:

1. the President or Chief Executive Officer of that institution officially designated as such in HLC’s records;
2. an individual designated by the President or Chief Executive Officer to receive such information; or
3. a resolution from that institution’s governing board signed by the current Chair of that board.

HLC shall release information to any other individual or to a consultant or attorney representing the institution only when HLC has received a written request from the President or CEO of the institution.

Peer Review Information. In preparation for HLC review HLC may release information to institutions about peer reviewers including contact information, credentials and other information for the purpose of assuring that HLC processes are free of conflict of interest.

HLC may provide oral or written comments or explanation in conjunction with the release of the above information and non-particularized information about HLC precedent.

Within HLC Processes or to External Agents of HLC. HLC may provide information as identified in this policy under Defining and Establishing the Ownership of HLC Information, to individuals acting as reviewers and decision-makers for HLC within its processes. HLC also may provide such information to HLC consultants or other individuals or entities retained by HLC to provide assistance, expertise or other function in support of HLC processes. As a condition of a relationship with HLC, all reviewers, decision-makers, and consultants shall agree in writing to maintain the confidentiality of such information.

Researchers. HLC may provide its information to a researcher(s) who, in the sole discretion of HLC, has appropriate academic credentials and who outlines an appropriate research project related to the work of HLC. As a condition of any relationship with HLC, all researchers must agree in writing to maintain the confidentiality of the information and to other terms as outlined in an appropriate agreement or contract.

Third Parties. HLC shall release information about an institution or peer reviewer(s) or about HLC policies, procedures or activities in furtherance of its processes to, or in response to a written request form, the following entities:

1. The U.S. Department of Education or other federal agency with appropriate jurisdiction to request the information;
2. A validly-issued subpoena from a court of law with appropriate jurisdiction; and
3. Another recognized accrediting agency with which the institution(s) may have status or be seeking such status;

HLC may, at its sole discretion, release information to a state higher education or other governmental agency with appropriate jurisdiction.

HLC may provide oral or written comments or explanation to such entities in conjunction with, or separate from, the release of such information.

Public. HLC shall release the following information to the public and any other interested parties by means of its website, fax or other disclosure:

1. the name and contact information for any institution that holds, or has held, status with HLC along with information about its campuses, additional locations and educational programs as well as any other data it regularly collects through its Institutional Update process;
2. the name and contact information of any institution scheduled for an evaluation for initial status;
3. the Statement of Accreditation Status;
4. Public Disclosure Notices and, when appropriate, certain other public statements made by HLC;
5. action letters related to the granting, reaffirmation or withdrawal of candidate for accreditation or accreditation status; to the imposition or removal of a sanction or show-cause order; and to the outcome of an advisory visit.
6. summary of all HLC actions posted within 30 days of taking such action, including voluntary withdrawals and other information within 30 days of HLC receiving such information;
7. the list of institutions being evaluated by HLC for initial status, reaffirmation of accreditation, probation or show-cause in the upcoming academic year and the invitation for third-party comment about appropriate institutions;
8. the policies and procedures of HLC and related information;
9. the results of aggregate data analyses and other information HLC staff determine to be appropriate for public release;
10. the names of all active peer reviewers and other information including title and contact information in their organization; and
11. the names, internal contact and areas of responsibility for all staff members.

HLC may provide oral or written comments or explanation of such information to the public.

Mailing or Address Lists for Marketing Purposes. HLC shall not give or sell mailing lists of institutions or peer reviewers or similar information to any company, organization, institution, or individual for use in marketing or solicitation. However, HLC may provide information about individuals who attend a conference or workshop to appropriate business partners. All such business partners must agree to provide appropriate mechanisms by which a recipient may decline to receive additional promotional material.

Other HLC Release of Information. HLC may include HLC information in any submission it shall make on behalf of HLC. Such submissions shall include, but are not limited to, HLC petitions for continued recognition from the U.S. Department of Education or the Council on Higher Education Accreditation, or HLC petition or response in any lawsuit or action it initiates or which has been initiated by another party.

HLC may release the team report or other documents to third parties or the public if the institution or one of its agents has released information or excerpts from documents created by or for HLC in such a way that information from those documents, or information with regard to HLC status or findings, has been misrepresented.

HLC may, at its sole discretion, release information about an institution publicly or to another entity if requested by that institution.

Policy History

Last Revised: November 2020
First Adopted: February 2010
Revision History: November 2012, February 2013, November 2020
Notes: Policies combined in November 2012 – 2.3, 2.3(a), 2.3(b), 2.3(b)1, 2.3(b)2, 2.3(b)3, 2.3(b)4, 2.3(b)5, 2.3(b)6, 2.3(b)7. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”