Transcript FERPA and Reverse Transfer

FERPA and Reverse Transfer
Oklahoma Reverse Transfer Workshop
University of Central Oklahoma
Edmond, Oklahoma
July 30, 2015
Michael Hawes
Statistical Privacy Advisor
U.S. Department of Education
Family Educational Rights and
Privacy Act (FERPA)
 Gives parents (and eligible students) the right to access
and seek to amend their children’s education records
 Protects personally identifiable information (PII) from
education records from unauthorized disclosure
 Requirement for written consent before sharing PII –
unless an exception applies
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Personally Identifiable
Information (PII)
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Name
Name of parents or other family members
Address
Personal identifier (e.g., SSN, Student ID#)
Other indirect identifiers (e.g., date or place of birth)
“Other information that, alone or in combination, is
linked or linkable to a specific student that would allow a
reasonable person in the school community, who does
not have personal knowledge of the relevant
circumstances, to identify the student with reasonable
certainty.” (§ 99.3)
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Exceptions to the Consent
Requirement
Two of FERPA’s exceptions to the parental consent
requirement are most relevant when discussing
Reverse Transfer.
– School Official exception
– Audit and Evaluation exception
There are a number of other FERPA exceptions
(e.g., health and safety emergencies, directory information, etc).
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FERPA and Reverse Transfer
Under FERPA, it is easy for a student’s record to follow
them forward in their academic journey, but much more
difficult for it to go backwards to institutions they previously
attended.
With Student
Community College
University
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Consent (Best Practice)
Incorporate consent into the initial application
process.
Consent (alternative)
If consent was not obtained at admission, the University
can request consent for students likely to qualify for
Reverse Transfer.
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Redacted/Anonymized
Transcripts
The University redacts all direct and indirect identifiers from
the transcripts of potential Reverse Transfer candidates,
and replaces them with a unique identifier.
The University then sends the redacted transcripts to the
Community College for the degree audit (who commits to
not attempt to re-identify any of the students).
The Community College sends a list of the unique
identifiers for those students eligible for a degree.
The University contacts the eligible students, and obtains
consent to send their information to the Community College
to award the degree.
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University Staff Perform the
Degree Audit
The Community College provides the
University with their degree requirements.
The University conducts the degree
audits, and contacts those students
eligible for a degree.
Once student consents, the transcript is
sent to the Community College to award
the degree.
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University Volunteers Perform
the Degree Audit
Approved
for Use in
Oklahoma
Using FERPA’s “School
Official” Exception, the
University has Community
College staff perform the
degree audits as University
volunteers.
University must have appropriate
language in their annual FERPA notice.
Must exercise “direct control” over the
volunteers’ use and maintenance of PII.
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OK State Regents Perform the
Degree Audit
State Regents:
• Conduct the degree audit.
• Contact eligible students.
• Send transcript once consent
is received
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State Regents Authorize the
Community College to Perform the
Degree Audit
MOU
State Regents:
• Designate Community Colleges as
their “Authorized Representatives” to
conduct degree audits.
• Send Transcripts
Community Colleges:
• Conduct the degree audits.
• Contact eligible students (on behalf of
the Regents)
• Award degrees
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Questions and Discussion
Michael Hawes
Statistical Privacy Advisor
U.S. Department of Education
[email protected]
(202) 453-7017
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