Management of Student Records and Information Policy

Management of Student Records and Information Policy

POLICIES
OF: The Royal Alberta College
(hereinafter shall be referred to as “the college”
and/or as “college” and/or The “Royal Alberta College”)

1.0 POLICY:

The College will safeguard the integrity of the student record and student information for the protection of the student and the institution. The Royal Alberta College will create and maintain student records necessary to meet the administrative and academic needs of the institution and shall collect, store, disclose, retain and dispose of all information contained therein in accordance with the Records and Information Management Policy of the institution and Provincial/Federal legislation pertaining to freedom of information and protection of privacy.

2.0 RATIONALE AND GUIDING PRINCIPLES

2.1 This policy is written to provide guidance in fulfilling the institution’s responsibilities under the Alberta Freedom of Information and Protection of Privacy Act (the Act) and the Records and Information Management Policy as they apply to student records. It is intended to provide an ethical and consistent standard for the collection, storage, disclosure, retention and disposal of student information in accordance with complementary institutional policies as well as provincial and federal legislation.

2.2 The Alberta FOIP Act applies to all student personal information collected, generated, and recorded by the institution in effecting its business under its charter as a post-secondary educational institution under the Alberta Private Vocational Training (PVT) Act and the Private Vocational Training Regulation and if applicable the Alberta Post-Secondary Learning Act

2.3 All student records are subject to the provisions of the Alberta FOIP Act including the reporting of collections of student records as Personal Information Banks.

2.4 Students have specific information access and privacy protection rights and protections as granted them under the Alberta FOIP Act and are responsible for safeguarding their own personal information.

3.0 SCOPE AND DEFINITIONS:

3.1 SCOPE

This policy applies to any record of a prospective student, applicant, registrant, student or past student of the College.

3.2 DEFINITIONS

3.2.1 The Royal Alberta College Student Identification Number – The Royal Alberta College Student Identification Number is the unique identifying number under the control of the Registrar assigned to each student. It is to be used to ensure records and information are correctly assigned to individual students.

3.2.2 Official Student E-mail Address – Is the unique identifying email address under the control of the Registrar assigned to each student on receipt of an application to study. It is to be used to ensure records and information are correctly assigned to individual students.

3.2.3 Official Student File – Hard copy file of key data from which is placed on the Official Student Record. (see Appendix A for a listing of documents contained within the official student file)

3.2.4 Official Student Record – Central electronic database of student related information.

3.2.5 Official Transcript – The College’s official and certified statement of a student’s academic record. It is a subset of the official student record and includes the legal name, birth date, program of study, courses, grades, academic standing, program of graduation, graduation date as well as other transcript notations as approved in policy.

3.2.6 Program or Instructor Student Records – The combination of hard copy records and electronic documents that are held by programs or instructors relating to prospective students, applicants, students and former students / alumni. Program or instructor student records may include but are not limited to the following: academic advising notes, student written comments and appeals, student absences and documentation on student discipline. The Program Student Record may contain documents relating to other admission criteria including, but not limited to, portfolios, audition information, security clearance documents, student health information and questionnaires.

3.2.7 Personal Information – Recorded information of an identifiable individual defined in detail in s. 1(n) of the Alberta FOIP Act including unique identifying numbers, contact information, health, health care and educational history, criminal records and many other elements of information about the individual.

3.2.8 Student – For the purpose of this policy only, a “student” includes any of the following: prospective student, applicant, registrant, student or past student of the College.

3.2.9 Student Record – Refers to any record in any format (papers, database, or electronic) that contains individual student information of a personal, academic or disciplinary nature. An Official Student File is a subset of a student record.

4.0 REGULATIONS:

ROLES AND RESPONSIBILITIES
4.1 The Alberta Licensee or its designate shall be responsible for overall management of this policy.

4.2 The Registrar is responsible for administration and implementation of this policy.

4.3 The Board delegates to the Registrar authority to approve admissions and registrations of all students of the institution and to maintain records for
such matters related to the students of the institution.

4.4 The Office of the Registrar shall hold a legal seal of the institution for the sole use of affixing it when required to attest to the legality of such items
under his/her authority, specifically including it on institution and on transcripts.

4.5 The Office of the Registrar is the sole authorized agent to report and/or to confirm any record, document, report required by external lawful process
and/or policy concerning student records. The Registrar may work with the FOIP Head and/or FOIP Coordinator as necessary as per related College policy.

4.6 The Registrar will provide guidance to the institution regarding information management for student records.

4.7 The Registrar is the controller of the Royal Alberta College Student Identification Number.

COLLECTION OF STUDENT PERSONAL INFORMATION

4.8 The institution will collect student personal information in an ethical manner, ensuring that personal information collected is necessary for an
operating program or activity of the College and is collected directly from individuals except as otherwise permitted by legislation.

4.9 The institution will inform students by provision of a Personal Information Collection Notice of the purpose for which the information is collected, the specific legal authority for the collection, and the title, business address, and business phone number of an officer or employee who can answer questions about the collection. Notices will be in writing except in circumstances where written notice is not feasible.

4.10 Forms, form equivalent on-line screens, or other techniques used to collect student personal information must:
(i) be approved by the College
officer with primary record responsibility for the particular category of personal information,
(ii) bear the current corporate identity of the College,
(iii) include the identity of the department / division collecting the personal information,
(iv) include a Personal Information Collection Notice, and
(v) bear a date indicating when the form or screen was created or revised.

CUSTODY AND CONTROL

4.11 All student records and files created and maintained for any student in any activity sanctioned by or contracted by the College shall be deemed to be under the custody and control of the Office of the Registrar.

4.12 Any contracts or agreements that reference how student records will be collected, stored, disclosed, retained and disposed must be reviewed by the Registrar or designate prior to the contract or agreement being finalized.

MANAGEMENT OF STUDENT PERSONAL INFORMATION

4.13 All student personal information must be maintained in a secure manner and reasonably protected against unauthorized access, and collected, used, disclosed and disposed of in accordance with institutional policy.

4.14 The College Student Identification Number is the unique identifying number assigned to each student on receipt of an application or registration to study. It is to be used to ensure records and information are correctly assigned to individual students. The College Student Identification Number is under the control of the Registrar, and any additional uses, or any planned external disclosures contemplated by offices other than the Office of the Registrar must be approved by the Registrar or designate.

4.15 The official student e-mail address is the unique identifying e-mail address assigned to each student on receipt of an application or registration. It is to be used to ensure records and information are correctly assigned to individual students. The College e-mail address is under the control of the Registrar, and any additional uses, or any planned external disclosures contemplated by offices other than the Office of the Registrar must be approved by the Registrar or designate.

PROGRAM OR FACULTY STUDENT RECORDS

4.16 Program or faculty student records, where they exist, may contain documents and information not held in the official student file; however, the information ultimately remains under the custody and control of the Office of the Registrar.

4.17 Program or faculty student records, where they exist, are to be used for the purpose of program and/or course administration.

ACCESS AND DISCLOSURE

4.18 Students shall be granted access to view information contained in their student record which is held by the institution in accordance with institutional policy and regulations and FOIP legislation. (E3101) The Registrar shall require at least 48 hours notice by written request.

4.19 Faculty and staff who have been granted access to student records and student personal information shall use the data only for academic and administrative tasks.

4.20 Only faculty and staff who have signed the institutional confidentiality agreement may be granted access to student records and personal information.

4.21 Only the Office of the Registrar may routinely, without benefit of an Informed Consent, release the following personal information of students in compliance with the Alberta FOIP Act:

4.21.1 enrolment in a school of an educational body or in a program offered by a post-secondary educational body

4.21.2 attendance at or participation in a public event or activity related to a public body, including a graduation ceremony, sporting event, cultural program or club, or field trip, or

4.21.3 receipt of an honour or award granted by or through a public body.

4.22 By written request to the Registrar, a student may have student personal information identified in 4.21 withheld from routine release.

4.23 Students who request confirmation of the following must be directed to the Office of the Registrar: enrolment, graduation, registration, grades and academic standing, and tuition and fees.

4.24 A student who wishes to have another individual obtain copies of personal information records about him/her held by the College must complete and sign the Student Personal Information Record Disclosure Request and Consent form available from the Office of the Registrar.

4.25 Requests by students to verbally share personal information with a third party require students to complete and submit a Consent to Discuss a Student with a Third Party document

(Appendix C).

RETENTION OF STUDENT RECORDS
4.26 Information used to make a decision that directly affects the student must be retained for one year.

4.27 Program or Faculty files for students who have graduated must be retained for one year from the date of graduation.

4.28 Program or Faculty Files created for admission purposes must be retained for one year from the date of the final admission decision.

4.29 The official student file in the custody of the Office of the Registrar will be retained for four years after the last recorded academic activity.

4.30 The official credit transcript in the custody and control of the Office of the Registrar shall be held for 100 years in the form of an electronic student record.

4.31 Marked materials (for example, examinations and assignments) not returned to students must be retained for one year.

SCHEDULING AND DISPOSITION OF RECORDED INFORMATION

4.32 Faculties/Schools will create a listing of and annually provide updates to the Access and Privacy Office (APO) of the Personal Information Banks (PIB) of student records in their custody or under their control, based on an outline supplied by the APO. A Directory of Personal Information Banks will be created and published based on the data provided to the APO by departments.

4.33 Records Retention Schedules covering Student Records and Transitory Student Records will be created by faculties/schools according to a standard APO format.

4.34 If a student’s personal information is used to make a decision that directly affects the individual, the institution must retain the information for at least one year.

DISPOSITION OF STUDENT RECORDS

4.35 Student records shall be securely retained and disposed of in accordance with approved retention schedules and in a manner outlined in the Records and Information Management Policy.

4.36 Disposals must occur within twelve months of a particular record series year block becoming eligible for disposition.

POSTING STUDENT MARKS AND GRADES

4.37 Official grades may only be posted and released by the Office of the Registrar. All other posted marks or grades by schools or faculties should be plainly marked UNOFFICIAL. The Office of the Registrar shall publish addition procedures, as necessary, for the posting of student marks and grades.

STUDENT REFERENCE CHECKS
4.38 Faculty and staff must ensure that a student has completed and signed the appropriate consent form prior to providing a verbal or written reference or making disclosures of a substantive nature, such as attendance or performance; employees must ensure that the student has completed and signed the appropriate consent form or provided signed authorization.

STUDENT APPEALS DOCUMENTATION
4.39 All student appeals documentation must be maintained for one (1) year from the time the document is created. Should the appeal proceed to the fourth and final level, all documentation must be forwarded to the Office of the Alberta Licensee who will retain it for six years following the final outcome as determined on the written notification to the student.

4.40 Appeal documentation will be treated in accordance with the regulations of the Student Appeals.

Appendix A
Official Student File

Documents that may be held in the Official Student File in the Office of the Registrar The Official Student File includes approved records of Program / Credit students and any non credit academic work of those students, program and non-program students and those living and deceased, organized together.

The Records of Non-Program, Non-Credit Students is held in a separate file series, organized by academic year and then with any documentation for students, organized by last name.

Official Student File Contents May Include:
Academic Standing Letters, includes Notice of Probationary Status and Final Decision Letters of Disciplinary Action Requiring Student to Withdraw, and any other related;
Acceptance / Acknowledgment Letters;
Add Drop Notice / Withdrawal Notice form;
Application forms;
Application Acknowledgements;
Assessment of International Qualifications;
Change of Address,
Change of Name forms;
Credit by Special Assessment (Prior Learning Assessment (PLAR);
Examination Requests;
Extraordinary Circumstance documentation, requesting and supporting requests for special considerations (often refunds or partial refunds), at the discretion of the Registrar;
Final Decision Letters about Disciplinary Action;
General Correspondence and Notes-To-File,
Grade Change forms;
Grades;
Graduate, Application to forms;
Immigration and Residency documentation
Incomplete Contracts;
Incomplete Contract, Extension of a;
Notice of Probationary Status;
Parchment, if in file at time of file disposition transferred to file series 8560-22
Parchment Replacement requests;
Referral form;
Registration Statements;
Transcripts;

Appendix B
Documentation Relating To Students Typically Found In Other Areas of the College
Appeals Records, Stage
Financial Records – held by Finance
Bookstore records – held by the Bookstore
Counseling and Student Disability Accommodations – held in the Student Resource Centre
Immigration Records – held in Student Resource Centre
Scholarship / Award / Bursary Records – Student Resource Centre and Foundation
Official Photo Images – held in the Library photo database
Library Records – held in the Library
Overdue Library Materials Files – held in separate file in the Library
Computer Records – held by Information and Technology Services
Field Trip Records – separate file
International Travel Records – held in separate file in International Admissions
Security Incident Records – held by Facilities Campus Security Services
Parking Records – held by Facilities Parking Services
Residence Application / Tenant Management Records – held by the Student Residence
Special Needs Students Records – College Connection, Community Outreach, SRC SSD
Alumni Records – Alumni Relations and Services
Insurance / Medical Card records – Students’ Association
Master Access to Information / Privacy Protection records – FOIP Coordinator

Appendix C
Consent to Discuss a Student with a Third Party

“Discussion type” personal information disclosure situations need to be dealt with on a case by case basis that makes it difficult to use a form to obtain appropriate Consent. Provincially provided FOIP guidance forms do not address situations like wanting a free exchange discussing information about an individual with a third party.

A Consent for “Discussions” with a third party is not authority to release copies of records of the College to a third party, nor does it allow the College to take actions based on instructions that a third party may provide. Those are separate situations with approval processes specific to each.

A Consent does not require the College to communicate with a third party. The College reserves the right to confirm details with the individual consenting, or to decline to accept a Consent to communicate with a third party at its discretion.

Approved Process:

1) Speak with your student or client ( in person or by telephone ) and discuss the concept of you communicating with the third party about the individual and why you would do this. The objective in speaking, apart from communication clarity, is to ensure that you are identifying the student and not whomever may be at the other end of an E-mail link. If necessary ask questions of the individual that only the student should be able to accurately answer, or ask for an affirmation of his/her identity and record the response.

2) Find out and document what the individual is willing to have you discuss and disclose to the particular third party. This document may be provided to help the individual craft a Consent, with section 4 below serving as an outline for their Consent.

3) Have the student provide you either (a) a signed and dated written note that includes their student number or (b) an e-mail using their College assigned Email account, again including their student number. The College will accept electronic consent from this account for this purpose. E-mails from other account providers are not acceptable as they do not “authenticate” the user.

4) That the Royal Alberta College account e-mail or signed note must include the following:

(a) the identity of the student giving consent for communication of their
personal information to a third party, authenticated by including the
student number;

(b) to whom they are giving the College Consent to communicate and disclose
their personal information;

(c) specific information types that may be communicated;

(d) any subjects that the individual specifically does not want discussed or
communicated;

(e) the use(s) to which personal information received or disclosed may be put;

(f) if this is a “one time” permission, or if it is to be taken as on-going authorization for a period not to exceed one year; and,

(g) Signature, if the Consent is in hand written or word processed format, or typed full name if on a College E-mail.

5) On receipt of an appropriate Consent you may proceed as per the authorization.

6) Consents are valid for one year from date of communication.

7) Retain the Consent(s) for as long as the individual is your student or client plus one full year. That is to meet a FOIP record retention requirement when any kind of decision about the individual results from the use of their personal information. It also protects the College if an issue comes up about whether we had permission to disclose to a third party.