Cofidentiality of Student Records

Purpose

Policy for disclosure of student records to a member of the faculty or administration who have legitimate educational interest.

Overview

It is the purpose of this policy to provide reasonable interpretations of the Federal Family Educational Rights and Privacy Act and to protect the student's right of privacy as guaranteed therein. The policy is designed to ensure that student educational records are available only to faculty and administration who are permitted to review them in accordance with FERPA.

Related LCME Standards

11.5: Confidentiality of Student Educational Records

Principles

  1. In accordance with UC Policy PACAOS 130.231 "Student records" are those records that contain information directly related to a student and that are maintained by a University of California campus, the University of California Office of the President, or by any organization authorized to act on behalf of the University.
  2. In accordance with UC Policy PACAOS 130.232 student records include, but are not limited to, academic evaluations, including student examination papers, transcripts, test scores and other academic records; general counseling and advising records; disciplinary records; and financial aid records, including student loan collection records.
  3. In accordance with UC Policy PACAOS 130.234 the term "student records" does not include campus police records, employment records, health records, or instructional records created by an individual for the sole purpose of their instructional activities.
  4. Aspects of the student record are maintained by the UCSF Office of the Registrar or the School of Medicine Office of Medical Education.
  5. Right of access to these records is protected under the Federal Family Educational Rights and Privacy Act (FERPA) of 1974 and follows campus policy: http://studentlife.ucsf.edu/13000-policies-applying-disclosure-information-student-records(link is external)
  6. The School of Medicine Office of Medical Education maintains student records in the following formats:
    • School of Medicine’s Student Information System: A secure system that allows approved medical education faculty members and staff to access student contact information, program information, grades, course schedules, extra-curricular events, admissions data, and photographs.
    • Student Assessment Dashboard: The secure digital dashboards provide medical students and approved faculty and staff with access to student assessment data for the purpose of evaluating progression in the MD program’s competency-based curriculum.
    • Evaluations of Student Performance: The School of Medicine captures and stores secure written evaluations or video recordings of performance on for formative and summative assessment.  
  7. Access to student data within digital systems is role-based and assigned based upon the specific educational role of the faculty or staff on a “need to know” basis.
  8. In accordance with UC Policy PACAOS 130.260 The term "disclosure" means to permit access to or the release, transfer, or other communication of personally identifiable information contained in a student record by any means, including, but not limited to, oral, written, or electronic means. Disclosure to the party identified as the party that provided or created the record does not constitute a “disclosure” for purposes of FERPA.
  9. "Legitimate Educational Interest" means: (1) the information or record is relevant and necessary to the accomplishment of some task or determination; and (2) the task or determination is an employment responsibility for the inquirer or is a properly assigned subject matter for the inquirer.

Policy

  1. Students may request in writing for any individual to be granted access to their student records. Access is provided by extracting and securely transmitting the requested records. Access is not granted directly to the system of record.
  2. Educational Data Staff within the Technology Enhanced Education unit have access to medical students records for the purpose of building and maintaining data systems and reporting.
  3. Faculty and Administrative Access to Student Information System
    • Only medical school leaders (i.e. deans) and medical education administration with legitimate educational interest in the student record are granted access to the School of Medicine’s student information system.
    • Medical education staff are granted access to the School of Medicine student information system on a case-by-case basis. The Director of the Student Experience must sign-off on all access.
    • All system users must complete in-person training and read and sign the School of Medicine student information access release form prior to be granted access. This form describes the student records privacy guidelines and student rights to access provided by FERPA. All accounts are reviewed and renewed annually. During the annual review, all users are required to attest to continuing to require access as well as having reviewed and understood FERPA policy.
    • Students do not have direct access to the student information system but per FERPA, may request access to their student records at any time from the UCSF Office of the Registrar.
  4. Faculty and Administrative Access to Assessment Dashboards
    • Only the Associate Dean for Assessment can access all medical student dashboards.
    • Faculty coaches can access their assigned students’ dashboards.
    • Students have access to student assessment records as housed in the dashboard at all times.
  5. Faculty and Administrative Access to Evaluations of Student Performance:
    • Medical education leaders and staff, including deans, medical education staff, course directors and course coordinators with legitimate educational interest in the student assessment data are granted access to the School of Medicine’s online evaluation system.
    • Additional faculty leaders, i.e. co-directors, site directors, with legitimate educational interest in student assessment data are granted access to the online evaluation system by the course director.
    • Access to assessment data specific to a course or clerkship is reviewed and renewed annually by the course directors.
    • Provided evaluation reciprocity is met, students have direct access to their assessment data in E*Value at all times and per FERPA may request access to the additional records at any time.
    • Teaching evaluators have access to records of the student assessment data submitted by them until they no longer have access to the E*Value system.
  6. Access to student clinical skills and simulation assessment data contained within the B-line system is determined by the Faculty of record and/or course coordinator for a given assessment activity and is provided for a limited time for student review. Faculty of record and/or course coordinator accounts are managed by the Clinical Skills and Simulation staff and access is limited to data for a given assessment activity.

Procedure

HOW STUDENTS CAN REQUEST ACCESS TO THEIR STUDENT RECORD FOR THEMSELVES OR FOR A THIRD PARTY:

  1. Students submit their request via email or in person to the UCSF Office of the Registrar.
  2. In accordance with UC Policy PACAOS-130.411 the Office of the Registrar will coordinate with the School of Medicine to package and deliver the relevant student records within 45 days of the request.

HOW MEDICAL EDUCATION STAFF CAN OBTAIN ACCESS TO STUDENT RECORDS IN MedSIS:

  1. This MedSIS access request form must be completed by the employee's supervisor, or the Director of Medical Student Experience.
  2. Their supervisor must verify that the staff member has valid educational interest. 
  3. Access to sensitive student data must be approved by the Director of Student Experience. 

Accountable Dean or Director(s)

Kevin Souza, MS, Associate Dean for Medical Education

Chandler Mayfield, Executive Director, Technology Enhanced Education

DQ Tran Taylor, Director, Student Experience Team

Approval Date and Governing Body: April 17, 2018, CCEP