has a written procedure for protecting the privacy of students enrolled in distance and correspondence education courses or programs.

Compliance Certification Rationale for Judgment of Compliance

Southwest Texas Junior College protects the privacy of all its students and the security and integrity of student records. SWTJC’s Information Technology Department maintains numerous precautionary measures to ensure the security of electronic records.  Various controls assure that system security is current and operating effectively.  Some examples are firewalls, virus protection, intrusion detection, and spy-ware blockers.  The integrity of computerized SWTJC student records is validated through daily backups of the student information system (Colleague) and our document management systems, Docuware and Fortis.  System audit trails record transactions in Colleague from processed data to the source of input. These audit trails allow SWTJC personnel to track changes or modifications to student records and to identify those making changes/modifications.

The confidentiality of student records at Southwest Texas Junior College is maintained according to the guidelines of the Family Educational Rights and Privacy Act (FERPA).  College policy concerning disclosure of student records and directory information is available in our College catalog, on the SWTJC website, and in the Student Handbook.   Student directory information is available upon formal written request unless a student has restricted the release of such information in writing to the Admissions and Registrar’s office.  Student records are released only to the individual students to whom they belong.  Students may sign a release form granting authorization to release records to designated individuals or educational entities.  The issuance of a student’s academic records (transcripts) is protected by the use of security transcript paper and/or the delivery of electronic records to institutions capable of receiving electronic records via EDI, using Secure File Transport Protocol (SFTP).  Files that are sent using SFTP are encrypted and decrypted on the receiving side, creating a secure pathway.

To safeguard students’ privacy and to avoid identity theft, SWTJC assigns each student a unique identification number that can be used in place of the Social Security Number on any documents that identify the student.  Students have access to their records via the web through the security of a user ID and password.

An additional protection in place for students enrolled in distance education is the Distance Learning Department Confidentiality Agreement . This document is required of students and staff charged with monitoring duties for video-conferencing or online courses. It is also required of students and staff who assist the proctoring of in-person mid-term and final exams for online students.

Off-Site Committee Judgment and Commentary: Non-Compliance

The institution outlines its policies for protecting privacy of online students and indicates they are in accordance with FERPA. Processes to maintain privacy are outlined. In addition, the institution requires staff monitoring online students to sign a distance learning department confidentiality agreement. However, the committee could not find a written procedure protecting online students’ privacy.

Institutional Response

The following “Procedures for Protecting the Privacy of Online Students” was added to the SWTJC Faculty Handbook sub-section (page 32) entitled, “Distance Learning Instructor.” The procedures were disseminated to all SWTJC instructors teaching online and to staff associated with providing or maintaining online courses.

‘Southwest Texas Junior College protects the privacy of all its students, adhering to the same privacy standards for online students as it does for “face-to-face” students. Guidelines provided by the Family Educational Rights and Privacy Act (FERPA) govern all college efforts to maintain privacy and control of student information.

To further protect student privacy in online or hybrid courses, these procedures shall be followed:

• The arbitrary SWTJC student Identification Number, assigned through Colleague, the institutional management system, will always be used to identify students, in lieu of Social Security Numbers.
• Students will access online learning materials via an approved Learning Managements System (LMS) all of which requires unique user names and passwords for access, and which students may select and change.
• Online faculty will instruct students never to reveal their log-in names or passwords to anyone.
• Student postings to course discussion boards, chat rooms, and class forums shall be accessible only to members of the class, the instructor, and SWTJC staff specifically authorized and responsible for student learning assessment or oversight of the academic quality and integrity of the course.
• Instructors will communicate grades to online students via the secure gradebook communication capabilities of the LMS.
• Instructors or staff will not communicate grade information or other protected information via emails, which can be intercepted or viewed by someone other than the student.
• Instructional support staff, such as monitors assigned to assist Dual Credit students, shall adhere to all procedures outlined above. In addition, such staff shall complete and submit to the Distance Learning Office at the Uvalde Campus the ‘Southwest Texas Junior College Distance Learning Department Confidentiality Agreement’ at the beginning of his/her first semester of employment/assignment. This Agreement will remain in force until the staff member no longer holds the support position. Revision of the Agreement will require staff to re-submit the document.’