12.5     Student Records

The institution protects the security, confidentiality, and integrity of its student records and maintains security measures to protect and back up data.

Judgment

x   Compliance           o  Non-Compliance           o Partial Compliance

Narrative

UL Lafayette protects the security, confidentiality, and integrity of its student records, and maintains security measures to protect and back up this data.

Types of Student Educational Records

The University considers education records to be those records that contain information directly related to a student, and which are maintained by UL Lafayette or by a party acting on behalf of UL Lafayette. Education records may exist in the form of records, files, documents, or other media/materials.

The student educational record contains directory and non-directory information. Directory information is defined as information contained in the education records of a student that would not generally be considered harmful or an invasion of privacy if disclosed. As such, directory information may be disclosed without prior consent of the student. Directory information at UL Lafayette includes: student name, address(es), telephone number(s), classification, email address, photograph, place and date of birth, major field of study, dates of attendance, degree and date received, academic awards and honors, the most recent previous education agency or institution attended by the student, participation in officially recognized activities and sports, and weight and height of members of athletic teams.   

Non-directory information is any educational record not classified as directory information. This private information is not released to anyone, including parents of the student, without written consent from the student, or under the strict exceptions as defined under the FERPA law.

Employee Access to Student Educational Records and Training

The University maintains policies that ensure compliance with FERPA. Employees of UL Lafayette may need access to student records to perform their job duties. Examples include employees in the academic colleges, academic departments, and academic/student support areas. Employees are responsible for protecting the confidentiality, integrity, and security of records that they access.

Prior to receiving access to student information via Banner, employees must submit an official security request through the Help Desk. The request requires the employee to specify the type of student information they are requesting, and to provide a justification describing the job duties that require the access. The security request must then be approved by the employee’s supervisor before it will proceed. Once the supervisor approves, the request is then submitted to the Registrar’s Office for review and action, if warranted. If it is determined that the employee legitimately requires access to the requested student information in order to perform official duties, the Registrar’s Office will conduct appropriate training with the employee on the proper use of the Banner screens and FERPA. Once training is completed, access is granted to the employee.

Integrity of Student Records

Accuracy and integrity of student records is accomplished via a number of processes, procedures, and internal controls.

Final grades are reported by instructors of record at the conclusion of a semester/term during the assigned grading period. The Registrar’s Office opens grading on Banner and communicates instructions to instructors of record. Instructors enter final grades via their secure Banner login. At the conclusion of the grade reporting period, the Registrar’s Office closes grading access on Banner and posts grades to student records.

Changes to student records are handled via established business processes and procedures. Students may initiate a change of address, change of name, change of social security number, etc., by contacting the Registrar’s Office. The student must complete the appropriate change request form and provide all appropriate documentation (such as a marriage certificate or court order for a name change). The Registrar’s Office processes all appropriate records changes and maintains appropriate documentation on file. Grade changes are initiated by faculty and must be signed by the Department Head and
Dean before being hand-delivered to the Registrar’s Office.

Security Measures

The Office of Enterprise Application Services (EAS) has established policies and procedures to protect the security of student records. Individuals requiring access to information must log in using their unique University Login Identification (ULID) through a single secure login process. The user is authenticated and then granted access to the data using Louisiana state security protocols (unique identifiers and passwords). Access by students to these services is controlled via the secure login profile established by each eligible user. The profiles and unique identifiers are maintained in a secured database or server that follows the Louisiana state security standard with regard to the creation of a username and password as per the State of Louisiana Office of Technology Services’ Information Security Policy. The password must conform to the state security and University standards established with respect to length, type, and number of symbols and characters. When appropriate or necessary, data passed over the Internet through the web applications for faculty, staff, or students are encrypted.

Student academic records are maintained in the University’s computer-based Integrated Student Information System (Banner), which is provided and maintained by the University Office of Enterprise Application Services. The student system as installed in the UL Lafayette computing platform includes integrated modules for student admissions, student records, registration, financial aid, student billing, accounts receivable, and degree audit.

Student system access for administrative users is granted based on a formal approval from the University administration and based on the user’s position responsibilities. Banner user access is controlled by standard system access profiles prescribed by administrative personnel for various user categories. The University Registrar is the designated data steward for student records and Banner subsystems that include business processes associated with registration, course catalog and scheduling, advising, grade management, degree audit, academic curriculum, and student data. Access to sensitive system functions and capabilities is restricted to the smallest practical number of administrative users. The Office of the Provost must approve all external requests for student data. Access to Banner is deleted upon student and staff exit from employment or any change of University status. The Human Resources department initiates this process when an employee separates from the University; the Information Technology department then communicates with various campus areas to ensure that the employee’s access is deactivated. This entire process takes place in and is documented on the Cherwell system.

Web-based student access to personal records requires a secured socket layer connection across the Internet (256-bit encryption). Such access requires authentication using a password selected by the student. Students can also request that certain information be repressed.

EAS has established an inventory of all devices that contain personal data in accordance with the Database Security Breach Notification Law, SB205 Act 499, of the State of Louisiana. The Database Security Breach Notification Law requires notification to any Louisiana resident whose unencrypted personal information was, or is reasonably believed to have been, acquired by an unauthorized person as a result of a security breach.

Records Storage

Educational records are maintained both centrally and within organizational units across campus. Records are housed electronically in Banner, Banner Document Management (BDM), and on shared drives on the University network.

Colleges

Education records maintained in the academic colleges for their students may include data related to admissions, transfer credits, academic progress, graduation eligibility, faculty data, advising, change of academic program, petitions, appeals, transcript data, and internal academic data. Table 12.5 – 1 lists the locations of the academic colleges and schools that house student records.

Table 12.5 – 1: Academic Colleges and Schools that house student records

College/School

College Office and Records Location

College of the Arts

Fletcher Hall, Room 205

College of Business

Moody Hall, Room 236

College of Education

Maxim Doucet Hall, Room 105

College of Engineering

Madison Hall, Room 106

College of Liberal Arts

H.L. Griffin Hall, Room 101

College of Nursing and Allied Health Professions

V.L. Wharton Hall, Room 254

College of Sciences

Oliver Hall, Room 201

Graduate School

Martin Hall, Rooms 217 and 332

University College

DeClouet Hall, Room 104

 

Academic Departments

Departmental offices maintain education records that may include limited admissions and transfer credentials, data on academic progress, faculty recommendations, advisors’ comments relating to registration and changes of program, limited placement data, departmental exam results, and foreign language proficiency information.

Administrative and Student/Academic Services

Various University support offices house student records, including the Registrar’s Office, Academic Success Center, Academic Affairs – Academic Programs, Undergraduate Admissions, and Financial Aid. Offices ensure the integrity of the data they maintain via a combination of procedures manuals, employee training, and internal control methods.

 

Supporting Documents

Banner Security Request for access form

Banner Security Request form on Help Desk

Banner Security Request to remove access form

Example FERPA material Covered During Training

Faculty Grade Entry Training Guide

FERPA Policy University Catalog

FERPA training handout

LA Information Security Policy

LA Statutes: Database

QC Control Reports

Sample Change of Grade

Updating Equivalents for Students