Records RetentionRecords RetentionCACCRAO Workshop, May 1, 2007CACCRAO Workshop, May 1, 2007

Palm Springs HiltonPalm Springs Hilton

Kristie AndersonKristie AndersonDirector Admissions & Records, Mendocino CollegeDirector Admissions & Records, Mendocino College

kanderso@mendocino.edukanderso@mendocino.edu

Alicia TerryAlicia TerryRegistrar, MiraCosta CollegeRegistrar, MiraCosta College

aterry@miracosta.eduaterry@miracosta.edu

Pat FifieldPat Fifield

Associate Registrar, DeAnza CollegeAssociate Registrar, DeAnza College

fifieldpat@fhda.edufifieldpat@fhda.edu

Records RetentionRecords RetentionWhat is it?What is it?

Identification of recordsIdentification of records Classification of recordsClassification of records Storage/retention of recordsStorage/retention of records Destruction of recordsDestruction of records

What this is not!What this is not!

A FERPA discussionA FERPA discussionNot about who has access to recordsNot about who has access to records

Not a definition of directory informationNot a definition of directory information

Not about student’s rights regarding their recordsNot about student’s rights regarding their records

Examples of RegulationsExamples of Regulations

Title V 59020-41 Retention & Destruction of Title V 59020-41 Retention & Destruction of Records (all records…required to prepare or Records (all records…required to prepare or retain by law or official duty)retain by law or official duty)

Title V 54600 Student Records Title V 54600 Student Records Attendance Accounting Manual – audit Attendance Accounting Manual – audit

accountability accountability Education Code – 76200 Student RecordsEducation Code – 76200 Student Records

Title V 59020-41 Retention & Destruction of Title V 59020-41 Retention & Destruction of Records (all records…required to prepare or Records (all records…required to prepare or retain by law or official duty)retain by law or official duty)

Title V 54600 Student Records Title V 54600 Student Records Attendance Accounting Manual – audit Attendance Accounting Manual – audit

accountability accountability Education Code – 76200 Student RecordsEducation Code – 76200 Student Records

T5 59020-41 Retention and T5 59020-41 Retention and Destruction of RecordsDestruction of Records

Explains how to handle all records, maps, books, papers, Explains how to handle all records, maps, books, papers, data processing output, and electronic documents that a data processing output, and electronic documents that a district is required by law to prepare or retain by law or district is required by law to prepare or retain by law or official duty official duty

Student Records is just a part of thisStudent Records is just a part of this How to classifyHow to classify How long to retain records (copies must be “in an How long to retain records (copies must be “in an

accessible location and provision…made for preserving accessible location and provision…made for preserving permanently, examining and using same”)permanently, examining and using same”)

Procedures for destruction Procedures for destruction Destruction requires board action!Destruction requires board action!

T5 54600-62 Student RecordsT5 54600-62 Student Records

Student records relevant to admission, registration, Student records relevant to admission, registration, academic history, career, student benefits or services, academic history, career, student benefits or services, extracurricular activities, counseling and guidance, extracurricular activities, counseling and guidance, discipline, student conduct and anything else required by discipline, student conduct and anything else required by law law

Students must have access to all these records (except Students must have access to all these records (except parts of documents that have other students’ information) – parts of documents that have other students’ information) – this is where FERPA comes into playthis is where FERPA comes into play

A subpoena requesting student records might include any A subpoena requesting student records might include any or all of these recordsor all of these records

Students may challenge the content of these records – also Students may challenge the content of these records – also further defined in FERPAfurther defined in FERPA

Attendance Accounting ManualAttendance Accounting ManualChapter on Audit AccountabilityChapter on Audit Accountability

Reiterates the information in T5 and spells it Reiterates the information in T5 and spells it out as being subject to auditingout as being subject to auditing

Manual available on Statewide Chancellor’s Manual available on Statewide Chancellor’s Office website - Office website - http://www.cccco.edu/divisions/cffp/fiscal/allhttp://www.cccco.edu/divisions/cffp/fiscal/allocations/manuals.htmocations/manuals.htm

Education Code 76200-22Education Code 76200-22Student RecordsStudent Records

““any item of information directly related to an any item of information directly related to an identifiable student, other than directory identifiable student, other than directory information, which is maintained by a information, which is maintained by a community college…”community college…”

Not a physician’s recordNot a physician’s record Not a law enforcement record Not a law enforcement record

More Title V Regulations that More Title V Regulations that mention some type of recordmention some type of record 55006 course records55006 course records 55219 MIS & distance ed records55219 MIS & distance ed records 55256 work experience records55256 work experience records 55607 voc ed income and expenditure records55607 voc ed income and expenditure records 55728 flex calendar reporting55728 flex calendar reporting 55828 inventory of off-campus programs & 55828 inventory of off-campus programs &

facilitiesfacilities 56030 DSPS budget & fiscal reports56030 DSPS budget & fiscal reports 56678 instructional grants56678 instructional grants 57011 construction expenditures57011 construction expenditures

And more…..And more…..

Course enrollmentCourse enrollment AttendanceAttendance Employment qualificationsEmployment qualifications Budget reportsBudget reports Financial AidFinancial Aid Instructional materialsInstructional materials District PoliciesDistrict Policies ComplaintsComplaints

Who should have records Who should have records procedures in place?procedures in place?

Essentially all college offices that have Essentially all college offices that have anything to do with students, employment or anything to do with students, employment or $$

Admissions & RecordsAdmissions & Records Financial AidFinancial Aid Human Resources/PayrollHuman Resources/Payroll FiscalFiscal Anyone else?Anyone else?

Who else needs records Who else needs records procedures?procedures?

Almost everyoneAlmost everyone Special Programs, International, Nursing, Police Special Programs, International, Nursing, Police

Academy, Tech Prep, Apprenticeship, Honors, etc.Academy, Tech Prep, Apprenticeship, Honors, etc. Student Services such as: Student Activities, Student Services such as: Student Activities,

Leadership, Community Service, Commencement, Leadership, Community Service, Commencement, Exception Committee, Counseling, etc.Exception Committee, Counseling, etc.

Instructional ServicesInstructional Services Student Accounts/CashieringStudent Accounts/Cashiering

Issues Issues to consider when developing or reviewing your to consider when developing or reviewing your

college’s procedurescollege’s procedures

Student Access – how do you find all records that Student Access – how do you find all records that a student has a right to view?a student has a right to view?

Subpoenas – how do you locate all records Subpoenas – how do you locate all records pertaining to a student especially those maintained pertaining to a student especially those maintained by specialized programs or instructors?by specialized programs or instructors?

What areas need to develop classification, What areas need to develop classification, retention, destruction procedures?retention, destruction procedures?

How do you handle the documentation needed for How do you handle the documentation needed for board approval? board approval?

Proper Storage Proper Storage Duplicates in secondary locationDuplicates in secondary location

Your Records Retention ManualYour Records Retention ManualAt a minimum should include:At a minimum should include:

Area of content one department (A&R) or the whole collegeArea of content one department (A&R) or the whole college Include the regulationsInclude the regulations Define the records (application, roster, graduation list)Define the records (application, roster, graduation list) Classify the records (permanent, optional, disposable, non-Classify the records (permanent, optional, disposable, non-

classified)classified) Method of storage (paper, electronic, film, fiche) and Method of storage (paper, electronic, film, fiche) and

locationlocation Controls – who is responsible for whatControls – who is responsible for what Storage list Storage list Letter to Board for destruction approvalLetter to Board for destruction approval

Electronic StorageElectronic Storage

T5 59022 Class 1 doc (may be)…reproduced…T5 59022 Class 1 doc (may be)…reproduced…electronicallyelectronically

The reproduction was accurate in detailThe reproduction was accurate in detail The CEO has attached…a signed and dated The CEO has attached…a signed and dated

certification…that the copy is a correct copy of the certification…that the copy is a correct copy of the originaloriginal

The copy was placed in an accessible location and The copy was placed in an accessible location and provision was made for preserving permanently, provision was made for preserving permanently, examining and using sameexamining and using same

San Diego Community College District Example

Major & Transfer Studies Elective 12/99 NC Evaluation 01-Jul Student folder

Military Contract Education Program - Roster SS-Militarycert05 1 District SS Permanent District SS

Mandated Training Course Repetition SS-MAND-5/98 3 Admission 3 yrs Dist. SS

Minor’s Authorization Consent Form for Medical Treatment SS-Studwaiver02 3 Hlth Srvcs 3 yrs Student Chart

Official Grade and Attendance Roster OGAR-12/95R 1 InstructionAdmission

Permanent Dist. SS

Permanent Record/Cumulative Totals Correction SS-PR/CTC-8/86 NC Evaluation 01-Jul Student folder

Petition for Academic Renewal by Course Repetition SS-PAR-12/99 NC Evaluation 01-Jul Student folder

Petition for Academic Renewal without Course Repetition SS-PARWOCR-12/99R

NC Evaluation 01-Jul Student folder

Petition for Approval of Major Area Electives SS-MELC-11/92 NC Counseling 01-Jul Student folder

Petition for Change of Degree Declaration SS-DECGHG-4/97 NC Counseling 01-Jul Dist. SS

Petition for Certification of Completion SS-Certicomp01 NC Evaluations 01-Jul Student Folder

Petition for Credit/No Credit Option SS-CR/NC-8/99R 3 Admission 3 yrs Admission

Petition for Graduation SS-PGD-02/02 NC Evaluation 01-Jul Student folder

Petition for Modification of Major SS-MODMJ-8/99R NC Counseling 01-Jul Student folder

Petition for Schedule Adjustment after Deadline SS-SCHADJ-0801 3 Admission 3 yrs Admission

Questions?Questions?