Brad Houston, University Records OfficerNovember 15, 2012

Created whenever you interact with students Gradebooks Student Coursework Email

Correspondence Retained for grade

appeals, audits Privacy laws and

concerns: dictates disclosure

Introduce participants to relevant policies and schedules for student records

Discuss retention and privacy requirements under Family Education Rights and Privacy Act (FERPA)

Focus on electronic records and requirements for storing and producing digital files PAWS D2L

Procedures, retention, best practices

Recorded information, in any format, that allows an office to conduct business Value determined by content

Four types of record value: Administrative Legal Fiscal Historical

Personal materialsWorking notes and drafts

Once a draft is shared with colleagues, it becomes a “record”

Envelopes and routing slipsDuplicate copies

Includes vast majority of “cc” email

Any Record created in the course of dealing with students or their information Vital▪ Transcripts, accounts, enrollment lists

Administrative▪ Transcripts, Add/Drop forms, etc.

Academic▪ Grades, Coursework, Exams, etc.

Advising▪ Case files, disciplinary files, email or written

correspondence

Essential records covering student’s entire career

Most of these records either permanent, or very long-term temporary Key example: Student

Transcripts, 75-year retention

Student Accreditation records?

Copies are NOT essential and may usually be destroyed when no longer needed

Records created for day-to-day administrative tracking of students

School/Department offices most likely to have these records

Generally high administrative value, little to n0 long-term value

Credit/no-credit approvals: 1 year after submitted

Add/Drop Records: 1 year after submitted

Entrance exams/placement tests: 5 years for enrolled students, 2 years for non-enrolled

Audit authorizations: 1 year after submitted

Records created over course of academic course

Usually held by individual instructors

Very high administrative value; almost no long-term value

Academic and Grade Appeals! UWM Select Policies S-28 and S-29 Students have up to one year to appeal grades Records kept through ALL levels of appeals

Academic Records must show: No error made in grade calculation Grade conforms to announced grading policy Work done by students removing incomplete Consistent grade calculation for new

incompletes

Grade Books: 1 year after grades assigned Student Coursework: 1 year after grades

assigned Usually final exams the only example of these

materials that are retained Copies of papers, midterms, etc. fall under this

Course Syllabi: 2 years after semester ends and transfer to archives Why? Proof of grading policy consistency

Email correspondence with students IS a record (UWCOMM001)

If you discuss grading policy/rationale with students, that correspondence CAN be used in appeal or litigation

If in doubt, discuss grades only in person

Records relating to student academic career, but not necessarily academic in nature

Often copies of vital or administrative student records

Usually held by department/office; may be held by Dean’s Office or Student Life

Most inconsistently scheduled of the main categories

Honors College Student Files: 5 years after creation

Academic dishonesty records: 5 years after close of case (Dean of Students)

CIE International Student Files: 2 years after closed

See also UWSA General Schedule: http://www.wisconsin.edu/gc-off/records/schedules/GRS.Academic.Advising.pdf

The brief version: 3 years for UG+Grad, 8 for certificates, 2 for prospective

Determine any statutory requirements for retaining records

Determine administrative/reference use beyond statutory requirements

Contact UWM Records Management to create records schedule Usually about a 3 month lag between

submission and approval by state Public Records Board

Disclosure rules for Student Records

Students have right to view educational records

Educational records are only accessible to student Student may authorize disclosure

Directory Information may be made available Exception: if a student has opted-out

Certain other exceptions exist

All records pertaining to students maintained at UWM

Presumption of confidentialityMajor exceptions:

Instructor personal/sole possession notes

Employment Records Campus Security Records Alumni records

Defined as information publicly available: Name, Address, Contact Info Year in school, major, enrollment status Participation in activities Degrees, graduation date, awards received

Students may choose to opt out of directory information release Contact Enrollment Services Campus Directory?

Individual Students UWM Employees with “Genuine

Educational Interest” Exempted classes

Financial Aid Providers Other educational institutions (for transfers,

etc.) Specifically exempted officials (FERPA

Manual) Accrediting groups/student study groups

Students must provide WRITTEN consent (with signature), including: Specification of records to be released Identify to whom records may be released Indication of purpose of release

Provide requested records within 45 days No consent needed if records are

subpoenaed or requested via public records request But contact Records Custodian first to determine

validity of subpoena

Keep a log of all disclosures of FERPA-protected information Exceptions: access by student or student-

permitted party, directory info disclosure Keep a log of notifications to students

of disclosure Maintain letters of consent for AT

LEAST six years after student graduates/leaves UWM

Release FERPA-protected information to parents Exception: if student is

under 18 Post test or course

grades using social security numbers

Provide records to UWM staff without “legitimate educational interest”

Yes! But make sure first: You have the

student’s permission

You have redacted any identifying information from copies displayed or distributed

Do not disclose student information if you have ANY doubt re: permissions Contact Legal Affairs for guidance Advise requestor to direct request to

Public Records Custodian Current Legal Affairs stance: presume

ALL student information is private Why? Directory Info “Opt Outs”

Wisconsin Administrative Rule 12, D2L, PAWS

Electronic documents are records too, and subject to public records request!

Records in Content Management Systems (e.g. D2L or PAWS) may be used as evidence in grade appeals/grievances

PAWS/D2L issue: what constitutes the “record” in these databases?

D2L COURSE SITE

Components that remain the same across iterations of the course

Non-student specific Built into the site

structure Usually not used for

documentation

D2L COURSE MATERIALS

Components that change across iterations of the course Example: grade

information Usually student-specific Content created for

course Example: Discussion

Forum Threads Main source of course

documentation

“Examinations, coursework, assignments, etc. as retained by academic departments to serve as source documents for submitted official grades.”

Retention time: 6 months after grades submitted n.b. If D2L records are ONLY copy of grade

records, save for 1 year after submission instead▪ Export, export, export!

Remember to go in and remove relevant documents/records once retention expires Course data that “hangs around” could be

subject to discoveryUW System has established annual

cleanup cycle for all course sites Courses after certain retention period deleted

yearly If you do want to save something, make local

copies

In general, records created through PAWS are responsibility of Enrollment Services

Access to student records subject to same FERPA privacy/disclosure requirements

If you submit grades through PAWS, retain your own copy for record-keeping purposes

Puts forth criteria for maintaining electronic records

Mandates design and use of information systems to support e-records

Does NOT require departments to maintain records electronically

DOES apply to records already being maintained electronically exclusively

Electronic records must be: Accurate: reflects the original record Accessible: Record can be retrieved Authentic: can be substantiated as accurate Reliable: produces the original record every time Legible: letters and numbers are identifiable Readable: Groups of letters recognized as words

All of these properties must be maintained throughout a record’s active life

Online (within D2L or PAWS system) Convenient, but may involve access

restrictionsOff-line (Print out)

Most reliable, but most unwieldyNear-line (PantherFile or Dept. LAN)

Reliable, moderately accessible Don’ t rely on one hard drive for this

“Cloud computing” lets you store and access records remotely Dropbox, Google Docs,

etc. UWM does not have

contracts with any of these services Security, Access not

guaranteed Be aware of FERPA

concerns

Summary and resources

Retain most student academic records for at minimum 1 year

Retain administrative or advising student records according to schedules

Do not disclose student records outside of specific exceptions

Prepare to preserve or purge electronic records, as appropriate

UWM FERPA Guide https://www4.uwm.edu/current_students/

records_grades/ferpa_facstaff.cfm UWM Select Policy 29: Grade Records and

Retention http://www4.uwm.edu/secu/acad

%2Badmin_policies/S29.htm UWSA General Records Schedule for

Academic Records http://www.uwsa.edu/gc-off/records/schedules/

studentrecsboilerplateUWROC.pdf

UWM General Records Schedules http://www4.uwm.edu/libraries/arch/

recordsmgt/common.cfmRecords Management Guidelines

http://www4.uwm.edu/libraries/arch/recordsmgt/guidelines.cfm

D2L Cleanup Blog http://d2lcleanup.blogspot.com/

This presentation available online: http://www.uwm.edu/Libraries/arch/

recordsmgt/legal.ppt

Or, contact UWM Records Management: houstobn@uwm.edu (Brad Houston) 414-229-6979 http://www.records.uwm.edu