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Section
IV: Programs
SACS Comprehensive Standard for Student Affairs and Services
IV-30. The
institution protects the security, confidentiality, and integrity of its
student affairs records.
JUDGMENT OF COMPLIANCE
Yes, East
Tennessee State University is able to provide a portfolio of evidence
supporting compliance.
STATEMENT OF RATIONALE FOR JUDGMENT OF COMPLIANCE
Security, confidentiality, and integrity of student
affairs records are the responsibilities of the ETSU Division of Student
Affairs, for undergraduate and graduate students, and the ETSU
Quillen College of Medicine Office of Student Affairs, for medical
students. In addition, the division of academic affairs is responsible
for maintaining security of admissions and financial aid records. University
offices that house student affairs records comply with regulations of
the ETSU Family Education Rights and Privacy Act and the Tennessee
Board of Regents (TBR Manual, Confidentiality of Student Records)
concerning student record security and maintenance. Pertinent policy
and regulations are made available to all ETSU staff, students, and faculty
(ETSU Faculty Handbook; ETSU Office of the Registrar; ETSU Spectrum;
SACS Standard IV-10).
Recently, the offices within the ETSU Division of
Student Affairs that are responsible for maintaining and releasing
student affairs records were asked to review record-keeping procedures
to ensure compliance with FERPA and TBR regulations. This review included
the identification of any improvements necessary to guarantee full compliance
(ETSU Division of Student Affairs Records Compliance Audit Questionnaire/Guidelines).
These student affairs offices were directed to file a quality assurance
form with the vice president for administration and student affairs, confirming
that they have written procedures and training mechanisms in place to
ensure proper maintenance and confidentiality of student records. As
a part of this quality assurance process, each office was asked to ensure
that all staff have read and signed the Statement of Student Records
Confidentiality And Conflict of Interest Form. This form states that
the employee understands FERPA guidelines and recognizes that working
with one's own record or the record of a relative or close acquaintance
is prohibited. One improvement identified was that this process be conducted
annually as a quality assurance of compliance. Offices that maintain
student affairs records at ETSU, but which are excluded by FERPA regulations
(ETSU Student Health Services, Counseling Center), have
written policies in compliance with state and federal law and professional
standards.
Student affairs records for undergraduate, graduate,
and medical students are stored in a closed and/or locked facility and
unauthorized access is prohibited. Each office that maintains student
records has at least one trained and designated individual responsible
for securing and releasing such records. Each office also has procedures
to prohibit casual access to confidential information by visitors, especially
with regard to the placement of desks, reception areas, workstations,
photocopier, fax, and computer screens. The ETSU Office of Information
Technology has specified policies and procedures (ETSU Administrative
Computer Access Policy) that govern which university personnel are
granted access rights to computerized educational records maintained on
the campus student information database system (SACS Standard IV-10).
Individual offices that handle computerized student affairs records also
have similar policies and procedures to safeguard the privacy and security
of these records.
Admissions records for undergraduate prospects and applicants
are maintained by the ETSU Office of Admissions. Information,
maintained in both hard copy and electronic formats, is treated confidentially
and is accessible to campus personnel on a need-to-know basis. Staff
and student workers in the office of admissions are counseled in regard
to confidentiality and security of records; each reads and signs a Statement
of Student Records Confidentiality and Conflict of Interest form.
Hard-copy information is stored in a secure area of the office under the
supervision of admissions personnel. Electronic information is protected
through the password and access-limiting procedures of the Student Information
System. When an applicant is admitted and enrolls at the university,
the admission record is transferred to the office of the registrar. Hard-copy
information for applicants who are not admitted or do not enroll is periodically
shredded; electronic information for similar situations is deleted from
computer files.
The ETSU School of Graduate Studies maintains student
affairs records on graduate students from admission through completion.
Confidentiality standards are maintained (ETSU Family Education Rights
and Privacy Act; TBR Manual, Confidentiality of Student Records)
and records are located in a secure facility that is monitored by a security
system. Only permanent staff has access to the facility after normal
operating hours. All employees and student and part-time workers are
trained in records policies and complete a confidentiality and conflict
of interest statement.
Financial aid records are protected and maintained by
the ETSU Office of Financial Aid. Only ETSU staff with the need
to use this information are permitted access to any financial data maintained
electronically (SIS). Access is limited primarily to financial aid and
administrative personnel. Each person who applies for access is required
to sign a confidentiality and conflict of interest form each year. A
reminder concerning the confidentiality of student information is displayed
on access to SIS. Hard copy student files are kept locked within the
financial aid office, and no one except financial aid staff and auditors
have access to these files.
A defined procedure for disposal of any student record
at ETSU is specified (ETSU Financial Procedures Directory, Records
Disposal) and complies with TBR guidelines (TBR Guideline, Disposal
of Records). These procedures and guidelines stipulate that
disposal of all confidential records be accomplished through a recycling
service, which is provided for ETSU by the sanitation department of Johnson
City, Tenn. This service provides for the secure pickup, shredding, and
recycling of confidential documents. The staff of the ETSU Office
of the Registrar has investigated this disposal method and found it
acceptable for and in compliance with the secure disposal of confidential
records.
DOCUMENTATION
SOURCE
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LOCATION
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ETSU Division of Student Affairs
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ETSU James H. Quillen College of Medicine,
Office of Student Affairs
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ETSU Family Education Rights and Privacy Act
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Tennessee Board of Regents Policies and Guidelines
Manual, Policy 3:02:03:00, Confidentiality of Student Records
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ETSU Faculty Handbook, Section 5.10, Student
Records and Privacy
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ETSU Office of the Registrar, Student Records
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Office of the Registrar, 101-102 Dossett Hall
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ETSU Spectrum (Student Handbook), Family Educational
Rights and Privacy
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SACS Standard IV-10
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ETSU Division of Student Affairs
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Division of Student Affairs, Third-level, D. P.
Culp University Center
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ETSU Division of Student AffairsRecords ComplianceAudit
Questionnaire/Guidelines Form
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SACS Documentation Files
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Statement of Student Records Confidentiality
and Conflict of Interest Form
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SACS Documentation Files
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ETSU Student Heath Services, Records Confidentiality
Policy
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ETSU Counseling Center, Confidentiality Policy
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ETSU Office of Information Technology
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ETSU Administrative Computer Access Policy
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ETSU Office of Admissions, Admissions Records
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Office of Admissions, 106 Dossett Hall
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ETSU School of Graduate Studies, Student Records
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School of Graduate Studies, 920 W. Maple Street
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ETSU Office of Financial Aid, Student Records
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Office of Financial Aid, 105 Dossett Hall
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ETSU Financial Procedures Directory FP-9, Record
Disposal
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Tennessee Board of Regents Guideline G-070,
Disposal of Records
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