Standard: 3.9.2 The institution protects the security, confidentiality, and integrity of its student records. Compliance Rating: Compliance Statement of Compliance: The University of West Florida protects the security, confidentiality, and integrity of its student records. To see the title of a given reference in the reference table at the end of the narrative and to access the reference document, place the cursor on the bracketed reference number and click the left mouse button. Narrative: The University of West Florida follows the guidelines established by the Family Education Records Privacy Act (FERPA) [1] in regard to the protection of student educational records. Policies regarding academic records are addressed in Standard 3.4.11. Policies related to nonacademic student records are outlined in the Student Handbook [2]. Specifically, students are notified of their FERPA rights in the Student Educational Records [3] section, and of their options regarding student disclosure of directory information in the Disclosure of Directory Information [4] section of the Student Handbook. Nonacademic student educational records are maintained in the following offices: the Dean of Students; the Health Center; the Counseling Center; Financial Aid; and Housing and Residence Life. Nonacademic records for students at the Ft. Walton Beach campus are kept at the main campus. The Office of the Dean of Students maintains student records for all academic and nonacademic conduct violations. It also maintains student records for Student Disability Resource Center. These records are accessible only to authorized program staff. Appropriate locking mechanisms or physical security are maintained at all times. The International Student Center transfers electronic tracking information on students as required by law through the federally mandated and protected Student and Exchange Visitor Information System (SEVIS) [5] network. The University Judicial Office maintains student judicial records on a network judicial database that is password protected and that possesses limited access to only full-time University employees. All students working in the Office of the Dean of Students are trained on confidentiality issues by the Office Manager at the beginning of their employment. All requests for information on student conduct records are conducted through this office and are released in compliance with appropriate federal and state guidelines. The University of West Florida Health Center maintains a clinical record system. The system includes collection, processing, maintenance, storage, retrieval, distribution, and safeguarding of clinical and other medical records. All records are treated as strictly confidential and are protected from loss, tampering, alteration, destruction, and unauthorized or inadvertent disclosure. Patient records and all clinical information relevant to the care of a patient are readily available to health care practitioners who observe established protocols for maintaining patient confidentiality. Policies have been established which address the retention of active and inactive records [6] and response to a subpoena [7]. The release of patient information is dependent on proper authorization via the Authorization for Release of Confidential Information Form [8]. Patient information is not revealed to any other college or institutional personnel without the informed consent of the patient, except in cases of extreme urgency where there is an obvious “need to know.” Health information required as a condition of matriculation is included as part of a student’s health record. Personal health care information is shared, as necessary, between counseling staff and health care services staff to assure continuity of care and to protect the health and safety of the patient without infringing upon patient’s rights of privacy and the confidentiality of provider-patient disclosures. The University of West Florida Counseling Center maintains a clinical record system from which information can be retrieved promptly. The system includes collection, processing, maintenance, storage, retrieval, distribution, and safeguarding of clinical and other counseling records. The Counseling Center follows the Florida Department of Health, Chapter 64B19-19 Psychological Records and Confidentiality regulations [9] for retention of active records, retention and destruction of inactive records, release of information contained in records [10], informed consent, and the response to subpoena and court orders. Client records and all clinical information relevant to the care of a client are readily available to health care practitioners who observe established protocols for maintaining client confidentiality outlined in the above-cited rule. Information is also shared between counseling staff and health service staff to ensure continuity of care and to protect the health and safety of the client involved. Florida State law [11] and professional ethics [12] guide the use of informed consent in order to protect the privacy and confidentiality of clients. The Financial Aid Office processes physical as well as electronic records. It is important that both types of records be maintained in a secure environment. The Financial Aid Office has established the following policy to ensure that the integrity of all student records is not compromised. For physical records, the Financial Aid Office maintains a centralized filing system that is secured by a fireproof combination door. The 4-digit code is shared only with the Financial Aid staff. Student files that are being processed by Financial Aid staff may be located in the office or workspace of staff. The door of each staff member will be locked when the staff member leaves. If the Associate Vice President for Enrollment Services requests a student file, the same security procedures will be followed. Under no circumstances will student records be taken from the campus without the written consent of the student. Most student information is easily accessed electronically by the Financial Aid Office. The information source is primarily an electronic record received from the Federal Department of Education. This electronic record includes all the data provided by students and parents on the FAFSA to determine eligibility for federal financial aid. The Financial Aid staff also enters additional information provided by students on an institutional form. In order to secure this information, Financial Aid staff will not compromise PIN numbers. Staff will position computer screens away from student traffic. The Workstation Manager will conduct updates each semester for screen authorizations. The Workstation Manager will determine which people require access to student information and their purpose for using the information. Access will be denied or revoked for those persons who are unable to provide legitimate reason to view student records. The Workstation Manager is responsible for ensuring that the same procedures followed by Financial Aid staff are followed by those outside of the Financial Aid Office who would need to access the information. The Office of Housing and Residence Life maintains a physical record for each resident which contains their Housing Contract(s), assignment information, and financial information related to their residency on campus. These records are centrally kept in the main Housing Office in secure filing cabinets. Access to these records is limited to the Housing and Residence Life staff and to the student assistants working in the main office. These records are considered confidential and are handled in accordance withthe Family Educational Rights and Privacy Act [13]. Additionally, the Office of Housing and Residence Life maintains an electronic assignment and billing database. This database is password protected and accessible only by authorized users. Rosters are kept at each Area Desk in order to provide directory information for residents. This directory information, which includes campus telephone number and Post Office Box, is provided for all residents unless the student has requested the information to be withheld through the procedures outlined in the Student Handbook [14]. Student staff members who handle student records are provided initial training by the Office Manager and are reminded regularly of the importance of maintaining confidentiality related to student files. All staff members are responsible for the security of files which includes proper filing methods, the prohibition of removing files from the main office, and the locking of the office at the end of each day. References: To access the archived copy of a document, place the cursor on the title and click the left mouse button. To return to the reference table, click the Back button. To return to your place in the text, place the cursor on the R to the left of the title and click the left mouse button. Live Link to Original Source Title No. 1 Return to Text R 2 R 3 R 4 R 5 R 6 R 7 R 8 R 9 R 10 R 11 R 12 R 13 R 14 R Titles are hyperlinked to the version of document archived in UWF SACS Compliance Certification Online Library Family Educational Rights and Privacy Act (FERPA) Student Handbook, General Information and Rights and Regulation, pp. 36-65 Student Handbook-Educational Records, p. 46 Student Handbook, Disclosure of Directory Information, p. 46 Immigration Customer and Enforcement, Web Site, Student and Exchange Visitor Information System Student Health Center Policy Medical Record Maintenance Policy, Student Health Center SUPOENA , Subpoena for Medical Records Student Health Center, Authorization For Release of Confidential Information Health, Florida Department of, Chapter 64B-19-19, Psychological Records and Confidentiality Counseling Center, Authorization For Release of Information Florida Statutes (2001), 490, Psychological Service American Psychological Association, Web Site, Ethical Principles of Psychologists and Code of Conduct Family Educational Rights and Privacy Act (FERPA) Student Handbook-Educational Records, p. 46 Warning: Live Web site links to original sources may not display same document as has been archived in UWF SACS Compliance Certification On-line Library; some links may no longer be active http://www.ed.gov/policy/gen/gui d/fpco/ferpa/index.html http://www.uwf.edu/uwfmain/stu Handbk/ http://www.uwf.edu/uwfmain/stu Handbk/ http://www.uwf.edu/uwfmain/stu Handbk/ http://www.ice.gov/graphics/enfo rce/imm/imm_sevis.htm Notes Same as 13 Same as 14 No Live Link Available No Live Link Available No Live Link Available http://fac.dos.state.fl.us/faconlin e/chapter64.pdf No Live Link Available http://www.flsenate.gov/statutes/ index.cfm?App_mode=Display_ Statute&URL=Ch0490/titl0490.h tm http://www.apa.org/ethics/code2 002.html http://www.ed.gov/policy/gen/gui d/fpco/ferpa/index.html http://www.uwf.edu/uwfmain/stu Handbk/ Same as 1 Same as 3