FERPA Compliance: Using Student Data in the AEFIS Solution Platform

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Academic Evaluation, Feedback and Intervention System

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“FERPA Compliance: Using Student Data in the AEFIS Solution Platform”

Untra Academic Management Solutions, LLC recognizes the necessary security measures for the handling of student data. As such, data is used only in the best interest of improved personalized learning and instructional support as part of the AEFIS Solution Platform.

Published July 20, 2010 For more information about the Academic Evaluation, Feedback and Intervention System—AEFIS, visit

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AEFIS | 234 Market Street, 2nd_{Floor West | Philadelphia, Pennsylvania 19106 | +1-215-873-0800 |}_{www.goAEFIS.com}

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“FERPA Compliance: Using Student Data in the AEFIS Solution Platform”

TERMS

OF

USE

Access to and use of AEFIS web and print materials is subject to the terms and conditions of this User Agreement and Copyright Notice and all applicable laws and regulations, including laws and regulations governing copyright and trademark. BY ACCESSING THE SERVICE AND THE DOCUMENTATION, YOU ACCEPT, WITHOUT LIMITATION OR QUALIFICATION, ALL OF THE TERMS AND CONDITIONS IN THIS USER AGREEMENT. Untra Corporation reserves the right to change these terms and conditions at any time. The materials used and displayed in AEFIS web and print materials, including but not limited to text, software, photographs, graphics, illustrations and artwork, video, music and sound, and names, logos, trademarks and service marks, are the property of Untra Corporation. Any such content may be displayed solely for your institutional, non-commercial use. You agree not to modify, reproduce, retransmit, distribute, disseminate, sell, publish, broadcast or circulate any such material without the written permission of Untra Corporation.

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AEFIS

O

VERVIEW

What is AEFIS?

AEFIS is the web-based assessment management solution and Instructional Decision Support System (IDSS) that promotes personalized learning by delivering real-time information to administrators, faculty, students, and alumni & industry to enhance curriculum development and streamline accreditation processes.

What does AEFIS do?

 Manages Student Learning Outcomes  Organizes Program Design & Alignment  Facilitates Direct & Indirect Assessments  Provides Centralized Syllabus Management  Delivers Instructional Decision Support (IDSS)  Fosters Personalized Learning

 Streamlines Accreditation Processes

 Connects Assessment to Teaching and Learning  Handles Surveys and Data Collection

AEFIS

IS

FERPA

C

OMPLIANT

The Family Educational Rights and Privacy Act is a Federal law that protects the privacy of student education records. It seeks to preserve such sensitive information for use by agencies, mainly educational institutions and agencies, with legitimate educational interests. According to the law (34 CFR §99.31), the institution can disclose student information to external organizations, such as AEFIS, with the following qualifications:

― The organization performs an institution service or function for which the institution would otherwise use employees.

― The organization is under the direct control of the institution with respect to use and maintenance of education records.

― The organization complies with FERPA policies for re-disclosure of information from education records.

AEFIS accounts for all of the above, by minimizing the work of institutional employees and implementing scalable processes to be administered by a web-based tool. The tool engages all stakeholders, who are granted access to information only by customizable user levels.

To learn more about the Family Education Rights and Privacy Acts (FERPA), visit

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HAT STUDENT DATA IS IMPORTED INTO

AEFIS?

Student data is imported from the Academic Management System (AMS), i.e. Banner, PeopleSoft, etc., during the implementation processes and regular data updates throughout the course of the AEFIS system lifecycle—all data fields are compliant with FERPA, however many are optional to comply with any institutional policies that object to the accessibility and retention of such data. AEFIS is a highly customizable solution that can be adjusted to further comply with institutional and other pertinent regulations and policies. The following is the standard student information data specification for the AEFIS data import process:

Field Optional/Required Field Description

STUUnivID Required Student University ID Usually ID assigned to any Identification STULastName Required Student Last Name

STUFirstName Required Student First Name STUMIName Optional Student Middle Initial STUEmailAddress Required Student Email Address STUCollCode Required Student College Code STUCollDesc Required Student College Description STUMajorCode Required Student Major Code STUMajorDesc Required Student Major Description

STUProg1 Optional Program/Track/Concentration the Student is enrolled. STULevel Required Student level, UG=Undergrad

STUBirthdate Optional Student Birthdate STUEthn Optional Student Ethnicity STUGender Optional Student Gender STUCitz Optional Student Citizenship LevlGpa Optional Student GPA

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HAT IS STUDENT DATA USED FOR IN

AEFIS?

AEFIS serves to aggregate assessment data that can be applied to both improved instructional support and accreditation documentation. Instructors and administrators play various roles in these improvement processes throughout the data assimilation.

Faculty is expected to enter Student Assessment data, including:

― Perceived student performance level measured against Student Learning Outcome Performance Criteria rubrics.

― Student performance percentile on specific assessment (i.e. grade on multiple choice test, oral presentation, essay, etc.).

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previous instructors’ recommendations for teaching the course effectively. To maintain the effectiveness of the IDSS, AEFIS recommends the inclusion of student information. However, to comply with institutional policies, particular data types can be removed.

Student data in the Course Syllabus module most commonly includes: ― Student Department/Degree Program

― Student overall GPA

― Student survey results as deployed by institution (i.e. Personality Inventory, Learning Styles Survey, etc.)

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HO HAS ACCESS TO STUDENT DATA IN THE SYSTEM

?

Access to any data in AEFIS is determined by User Level to protect both student and faculty’s information and intellectual property. These roles are assigned institutionally in order to comply with institutional policies. Such policies should be presented to UntraAMS, LLC prior to any contractual agreements being settled. The institution should be aware that for data processing and support purposes, UntraAMS Administrators have access to student and faculty information. This access is limited to only the most necessary instances.

User Levels

UntraAMS, Institutional, and General Administrators have access to create User Accounts and assign User Levels in AEFIS. These User Levels, defined below, limit system access and information visibility across the system to ensure data security.

1. UntraAMS Administrators – System Administrators can access all parts of the AEFIS system. The only limitation to this group will be the anonymity measure of user survey data for IRB compliant surveys thereby creating the inability to conveniently associate users with survey data.

2. Institutional Administrators – Institutional Administrator are able to access to all data and manage and control all functionality in the overall Institutional AEFIS System Instance (IASI), and be able to set the root level of inherited settings and information such as Institutional Student Learning Outcomes (SLOs), Institutional Mission, Institutional Course Evaluations, number of levels of performance criteria rubrics, etc. This is typically going to be one or more individuals in the Provost’s Office, or from Academic IS reporting to Provost’s office in a typical university setting.

3. General (or Unit/College/School) Administrators – General (or Unit/College/School) Administrators of the system are able to access all data and manage and control all functionality in their assigned Unit/College/School. These users will be able to set the inherited settings and information from College/Unit level such as Unit/College Student Learning Outcomes (SLOs), Unit/College Level Mission, Faculty Course Evaluations, Mid term Evaluations, Alumni Evaluations, Embedded Direct Assessments etc. This is typically Associate Dean(s), Assessment Coordinator(s), etc.

4. Deans – Deans will be able to view all data in their assigned Unit/College/School. These users will be able to view reports on all assessment/evaluation activities but will not be able to take administrative actions, such as modify ongoing Student Course Evaluation

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Surveys. This is typically a Dean or Director of an academic unit such as a College or a School.

5. Assessment (or Department) Administrators – Assessment (or Department) Administrators of the system are able to access all data and manage and control all functionality in their assigned department under a given Unit/College/School. These users will be able to manage academic programs, approve and manage syllabi, view all evaluation and assessment results, create recommendations on assessment and evaluations, manage Embedded Direct Assessments, manage meeting minutes and other assessment related documentation, etc. These users will also be able to create proxies that can access a given entity or a function within the system to help aid the workload of this type of user through 3rd_{party assignments such as an administrative assistant or work-study. This is}

typically Academic Program Managers, Faculty that are members of Curriculum Committee, etc.

6. Department Heads (Department Chairs) – Similar to “Deans”, Department Heads (Department Chairs) will be able to view all data in their assigned department under a given Unit/College/School. These users will be able to view reports on all

assessment/evaluation activities but will not be able to take administrative actions, such as approve pending course syllabi, etc.

7. Faculty (or Instructors) – Faculty (or Instructors) are able to access all data, manage and control all functionality in their assigned courses. These users will be able to view student evaluation and SLO assessment results for their own courses, view faculty course

evaluation and course based assessment results for their department (and departments they teach in), manage their own syllabi, design and manage their own custom Student Learning Outcomes (SLOs) and associated Performance Criteria (PCs) and rubrics for their own courses inside their syllabi, design and manage their own Embedded Direct Assessments for their own courses to assess their own custom SLOs and PCs in their syllabi, etc. These users will also be able to create proxies that can access a given entity or a function within the system to help aid the workload of this type of user thorough 3rd_party

assignments such a teaching assistant or a work-study. This is typically Full Time Faculty (such as core or Tenure/Tenure Track faculty), Adjunct Faculty, TA’s, etc.

8. Accreditation Reviewers – Accreditation Reviewers will be able to view all data in a temporarily designated Unit/College/School/Department. These users will be able to view reports on all activities and make recommendations and comments for a general Reviewer Report, but will not be able to take administrative actions, such as adjust Course Evaluation Surveys.

9. Students – Students are one of the key users of the AEFIS system who will be able to create and maintain personal user profiles, complete assigned surveys, access assigned course syllabi and be able to track all their own activity and generated messaging within AEFIS.

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HAT STUDENT DATA IS RETAINED IN THE SYSTEM

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S DATABASE

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FERPA does not regulate the retention of student information; however, retention of this sensitive information in AEFIS is dictated by institutional policies. The student data retained in the AEFIS database is rooted in the information discussed earlier in this essay. As such, appropriate user levels are necessary to view any of this sensitive data. AEFIS supports the retention of student data for application to institutional improvement. This improvement can be fueled by effective assessment documentation.

Student data is retained in the Instructional Decision Support System (IDSS), a module within the Course Syllabi platform. AEFIS developers are working to make amendments to the IDSS and strengthen its usability for tracing trends and learning more about course enrollments. Personal student data, often considered the most sensitive, will be optionally applicable to the module. Discovering trends in assessment data promotes the application of best practices to address those consistencies and also allow for more comprehensive assessment documentation and, thereby, success in accreditation reviews. AEFIS, of course, does not lay claims to any student information nor seeks to interfere with institutional decision making and thus, data is maintained in accordance with institutions’ data retention policies and destroyed thereafter.

AEFIS

FERPA

C

OMPLIANCE

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TATEMENT

The AEFIS system complies with the Family Educational Rights and Privacy Act, 11 U.S.C. § 1232g (“FERPA”) and the regulations promulgated thereunder. FERPA permits an educational institution to disclose personally identifiable information from the education records of a student without consent under certain circumstances and the disclosure of student information to Untra Academic Management Sources, LLC (“UntraAMS”) and its use in the AEFIS system complies with all FERPA requirements. UntraAMS is contracted to perform institutional services for which the institution may otherwise use its employees and disclosures are made solely to school officials within the institution whom the institution has determined have legitimate educational interests. UntraAMS remains under the direct control of the institution with respect to the use and maintenance of the education records and UntraAMS understands its obligation to comply with FERPA regarding the use and redisclosure of personally identifiable information from education records.