Judgment of Compliance

Narrative

Sam Houston State University’s (SHSU) written policy for protecting the privacy of students enrolled in distance and correspondence education courses and programs is expressed in the Academic Policy Statement 810806, Student Educational Records [1].  Academic Policy Statement 810806 fully supports the rules and regulations set forth by the Family Educational Rights and Privacy Act (FERPA) [2] and establishes protocols for its safekeeping.  Academic Policy Statement 810806 [1] applies to all students at SHSU, regardless of course modality.  The FERPA campus official at SHSU is the Registrar.  SHSU policies supporting FERPA are outlined in the Privacy Rights [3] documentation posted on the Registrar’s website.  Clearly articulated is the university’s requirement for protecting student educational records:

“no one outside the institution shall have access to students’ education records nor will the institution disclose any information from those records without the written consent of the student” [3]

Safeguards and Protocols to Protect Student Privacy

Training

In an effort to further protect student privacy and fully support the rules and regulations set forth by FERPA, SHSU requires any faculty member, staff member, or administrator who will have access to university systems that contain students’ academic records to complete appropriate FERPA training as part of his or her New Employee Security Awareness Training before access to such systems is granted [4].  FERPA training places special emphasis on the responsibilities of each employee as they relate to maintaining the confidentiality of student records protected and governed by FERPA [5].  In addition, all faculty members are reminded that the public posting of grades by students’ names, SHSU IDs, social security numbers, or via other personally identifiable information without students’ written permission is a violation of FERPA [6].

Technical Pop-up Reminders

In addition to training efforts and widely posted information regarding FERPA, employees who enter a student ID into a university system, such as Banner, will receive the following pop-up warning message displayed below:

Figure 1. Pop-up Warning Message

Additionally, employees are instructed that if the word “confidential” is listed on the top left-hand corner of a Banner form, the employee cannot release any information on that student [3].

Custodians of Educational Records 

In addition to the Office of the Registrar, SHSU has placed responsibility for administration of the FERPA regulations with the appropriate custodian of educational records.  Each custodian is responsible for the administration of this policy.  For a listing of the FERPA custodians at SHSU, please refer to the table “Locations of Educational Records” within Academic Policy Statement 810806 [7].

FERPA Postings and Notifications 

SHSU publishes a notice to students of their rights under the FERPA in the Student Guidelines bulletin and within the registration system.  The Student Guidelines are provided to each student at orientation and are published online [8].  The FERPA rights statement included in the registration system requires students to acknowledge the notification prior to registering for classes [9].  SHSU encourages students to exercise all rights under the FERPA.  Finally, FERPA postings are also made widely available from the Registrar’s website in the Privacy Rights documentation for students [10].

Supporting Documentation