Brad Houston, University Records Officer
November 15, 2012
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Created whenever you
interact with students
 Gradebooks
 Student Coursework
 Email Correspondence
Retained for grade
appeals, audits
 Privacy laws and
concerns: dictates
disclosure
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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
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Recorded information, in any format, that
allows an office to conduct business
 Value determined by content
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Four types of record value:
 Administrative
 Legal
 Fiscal
 Historical
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Personal materials
Working notes and drafts
 Once a draft is shared with colleagues, it becomes
a “record”
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Envelopes and routing slips
Duplicate copies
 Includes vast majority of “cc” email
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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
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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?
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Copies are NOT essential
and may usually be
destroyed when no longer
needed
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Students have right to view educational
records
Educational records are only accessible to
student
 Student may authorize disclosure
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Directory Information may be made available
 Exception: if a student has opted-out
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Certain other exceptions exist
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All records pertaining to students maintained
at UWM
Presumption of confidentiality
Major exceptions:
 Instructor personal/sole possession notes
 Employment Records
 Campus Security Records
 Alumni records
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Defined as information publicly available:
 Name, Address, Contact Info
 Year in school, major, enrollment status
 Participation in activities
 Degrees, graduation date, awards received
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Students may choose to opt out of directory
information release
 Contact Enrollment Services
 Campus Directory?
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Individual Students
UWM Employees with “Genuine Educational
Interest”
Exempted classes
 Financial Aid Providers
 Other educational institutions (for transfers, etc.)
 Specifically exempted officials (FERPA Manual)
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Accrediting groups/student study groups
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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
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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
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Keep a log of all disclosures of FERPAprotected information
 Exceptions: access by student or student-
permitted party, directory info disclosure
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Keep a log of notifications to students of
disclosure
Maintain letters of consent for AT LEAST six
years after student graduates/leaves UWM
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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”
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Yes! But make sure
first:
 You have the student’s
permission
 You have redacted any
identifying information
from copies displayed or
distributed
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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
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Current Legal Affairs stance: presume ALL
student information is private
 Why? Directory Info “Opt Outs”
Wisconsin Administrative Rule 12, D2L, PAWS
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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
D2L COURSE MATERIALS
Components that remain
the same across iterations
of the course
 Non-student specific
 Built into the site structure
 Usually not used for
documentation
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Components that change
across iterations of the
course
 Example: grade information
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Usually student-specific
Content created for course
 Example: Discussion Forum
Threads
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Main source of course
documentation
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“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!
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Remember to go in and remove relevant
documents/records once retention expires
 Course data that “hangs around” could be subject
to discovery
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UW 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
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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
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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
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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
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All of these properties must be maintained
throughout a record’s active life
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Online (within D2L or PAWS system)
 Convenient, but may involve access restrictions
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Off-line (Print out)
 Most reliable, but most unwieldy
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Near-line (PantherFile or Dept. LAN)
 Reliable, moderately accessible
 Don’ t rely on one hard drive for this
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“Cloud computing” lets
you store and access
records remotely
 Dropbox, Google Docs,
etc.
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UWM does not have
contracts with any of
these services
 Security, Access not
guaranteed
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Be aware of FERPA
concerns
Summary and resources
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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
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UWM FERPA Guide
 https://www4.uwm.edu/current_students/records_grades/
ferpa_facstaff.cfm
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UWM Select Policy 29: Grade Records and Retention
 http://www4.uwm.edu/secu/acad%2Badmin_policies/S29.
htm
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UWSA General Records Schedule for Academic
Records
 http://www.uwsa.edu/gc-
off/records/schedules/studentrecsboilerplateUWROC.pdf
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UWM General Records Schedules
 http://www4.uwm.edu/libraries/arch/recordsmgt/
common.cfm
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Records Management Guidelines
 http://www4.uwm.edu/libraries/arch/recordsmgt/
guidelines.cfm
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D2L Cleanup Blog
 http://d2lcleanup.blogspot.com/
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This presentation available online:
 http://www.uwm.edu/Libraries/arch/recordsmgt/legal.ppt
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Or, contact UWM Records Management:
 houstobn@uwm.edu (Brad Houston)
 414-229-6979
 http://www.records.uwm.edu