TO: Boulder Campus Faculty including TA s and GPTI s, Staff, Deans, Directors, Dept Chairs, System Administration
FROM: Office of the Registrar
SENDER: Gordon Russell
DATE: January 25, 2008
SUBJECT: FERPA Privacy Requirements - Student Educational Records
Now that the Spring semester is underway, I want to reiterate for you some of the federal student privacy requirements, as well as student directory information guidelines. Student privacy requirements are delineated in the Federal Rights and Privacy Act (FERPA) of 1974, a summary of which is available for your review at http://registrar.colorado.edu/regulations/ferpa_guide.html
FERPA sets guidelines for higher education institutions that protect students' rights with respect to their educational records and other personally identifiable information. Violations of student rights can lead to serious consequences, such as lawsuits and/or withholding of federal funds to the University.
As the semester gets underway, please recall that:
1. Circulation or posting of class/grade rosters, which display students' names and ID numbers, is a FERPA violation. Faculty may display a roster of students' names in a section of a course on a protected website or an overhead that is available to students of that section only, but may not create a public posting identifying students enrolled in a section of a course.
2. FERPA does not allow any public posting of student information with any part of the name, student identification number, social security number, or any other personally identifiable information. Students' grades may be posted without written permission, if they are not posted in a personally identifiable manner. If grade posting strips are created with random identifiers, they must not appear in alphabetical order according to students' names. The Testing and Assessment Center of Imaging Services can provide test scores and mid-term grades suitable for uploading into WebCT, the Boulder Campus Web course tool. Students may view their assessment and mid-term grades in a secure manner using WebCT. Please contact the IT Service Center at 303-735-HELP (5-4357) to have your course made available in WebCT. Visit http://www.colorado.edu/its/docs/webct/scanwebct.html to learn more about uploading grades to WebCT. Contact Imaging Services at (303) 492-6700, http://www.colorado.edu/tacenter
3. Recently, there have been a number of faculty members who maintained student grades and IDs on departmental websites. Such posting is in violation of FERPA requirements, and files containing such information should never be posted where it may be accessible to others.
4. Photographs of students are considered personally identifiable information, and as such they may not be posted to a course website or to other locations, without the prior written consent of the student.
5. Several departments on campus utilize webcams in buildings which display live streaming video of individuals walking in or through the building. Live webcam images are not subject to FERPA requirements. However, if any images are saved those images then become part of the student educational record and as such are subject to FERPA guidelines.
6. As an instructor or staff member, if you keep written notes on a student in your desk or office to which other people have access, these notes constitute part of the student educational record and are subject to all the provision of FERPA. Sole possession notes, however, are not subject to FERPA. Sole possession notes are records that are kept in the sole possession of the maker, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record.
STUDENT DIRECTORY INFORMATION
Under the terms of FERPA, the University of Colorado at Boulder has established the following "directory information." This information may be released to those requesting it, unless the student has a PRIVACY code on their record.
1. Names
2. Mailing and permanent addresses
3. Local /mailing telephone numbers
4. Campus e-mail address
5. Dates of attendance
6. Registration or enrollment status (Full-time/Part-time)
7. Class (Freshman, Sophomore, etc.)
8. College.
9. Previous education institutions attended.
10. Major field of study
11. Degree(s), honors and awards received and dates conferred
12. Past and present participation in officially recognized sports and activities
13. Physical factors (height/weight) of athletes
14. Date and place of birth
15. Classroom seating assignments.
16. Tutors and teaching/research assistants who are students (not names of tutors of individual students.
17. College Opportunity Fund application and authorization status.
18. Buff OneCard Photo (For additional information on release of Buff OneCard photos please check the website listed above.)
PRIVACY / NON-RELEASE OF DIRECTORY INFORMATION
The Family Educational Rights and Privacy Act of 1974 (FERPA) guarantees students the right of non-disclosure of directory information. We call these options privacy designations. Students may elect to withhold directory information by placing one of the two "privacy" designations on their academic records.
There are two types of privacy designations students may elect on the Boulder
Campus: S - for semi-privacy or limited privacy. This is for students who want to cut down on the volume of communication they receive from inside and outside of the university, but allows the University to release directory information to individual callers. If you see this code, there are no special restrictions on these students;
P - for full privacy. These are small in number, but these students have requested that the university disclose no information about their enrollment.
For faculty and staff that use SIS the word PRIVATE will appear under the student's name on most screens. If you use Web Operator, the privacy designation appears in the 4th column of your online class rosters. In the Faculty Course Toolkit, privacy-enabled students show up in the course roster with a red flag next to their name. In the column "Directory Listing" are the words "Privacy Enabled" instead of a link to their listing on the people search at http://www.colorado.edu. The words "Privacy Enabled" are a link to the FERPA info page on the Office of the Registrar site. In the photo roster, privacy enabled students have the words "Privacy Enabled" under their photo.
In the event that someone asks about a student with a full privacy on their records, you should reply, "I have no information about this person." In addition, if someone comes into your office claiming to be a student on full privacy, asking for information about their records, you must require a photo ID to verify their identity unless you know the student.
In conclusion, it is strongly recommended that all faculty, and any staff member that works with student data, review the information at http://registrar.colorado.edu/regulations/ferpa_training.html.
In addition, this should be incorporated into all new employee training, RA/TA training, etc. In an effort to assist your faculty and staff, the Registrar's Office has available a limited number of FERPA bookmarks. These bookmarks summarize important privacy requirements, and are available by contacting Carol Mash, Academic Records Manager, at carol.mash@colorado.edu. Thank you for your efforts to keep our campus FERPA compliant. If you have any questions, please email me at gordon.russell@colorado.edu.