Connected Campus

3.9.2 Student Records

 

The institution protects the security, confidentiality, and integrity of its student records and maintains security measures to protect and back up data.

 

_X_  Compliance           ___  Partial Compliance          ___  Non-Compliance

 

Narrative

 

Mid-America Baptist Theological Seminary (MABTS) stores academic records and ensures that policies and procedures that govern their security, confidentiality, and integrity are maintained. Record types include student applications, student academic transcripts, academic records, personal information and files, and health records, both digital and hard copy. The following policies and procedures demonstrate that MABTS safeguards the security, confidentiality, and integrity of its student records and has a specific disaster plan for record retrieval. The institution’s policy on confidentiality, integrity, and security of student academic records is publicized and is agreed upon annually by faculty and staff.

 

Academic Records

 

All electronic and physical academic records at MABTS are stored securely and the policies and procedures governing academic records are publicized and agreed upon by faculty and staff.

 

Storage. Physical and electronic access to student academic information is restricted to those authorized by seminary policy [1]. Though the seminary does not receive government funding and therefore is not subject to the policies and procedures outlined in the Family Education Rights and Privacy Act [2], adherence to those policies is deemed best practice in regard to protection of student records.
                 

Student academic records are maintained in SONISWEB [4], an information management system provided and maintained by RJM Systems, Inc. headquartered at Reservoir Office Park, 1449 Old Waterbury Road, Suite 204, Southbury, CT 06488. The system includes integrated modules for student admissions, student records, registration, financial aid, student billing, student accounts receivable, alumni and transcript records. SONISWEB provides extensive edits to ensure completeness and accuracy of data entered both online and through batch transactions.

 

Student academic records are stored in three places: (1) electronically on the administrative server of the seminary in the Cordova, TN campus (2) in hard-copy student files of the Office of Registrar (kept in a room without windows behind two locked doors), (3) and on external hard drives in the seminary’s safety deposit box at Trustmark Bank located at 6767 Summer Ave., Bartlett, TN 38134.

 

Recovery. To further secure digital student records, the seminary network servers are automatically backed up nightly. Seminary employees are encouraged to save their work to the server, making their files recoverable in the event that they are lost. Incremental backups by RJM Systems, Inc. via SONISWEB are performed every 4 hours using 256-bit encryption, which are retained for 90 days in case of data loss or disaster. These backups are maintained onsite at SONISWEB headquarters and are uploaded offsite to a cloud-based service.

 

Security. By assigning special privileges to administrators, SONISWEB allows select individuals to set and/or override restrictions on credits, pre-requisites, co-requisites, programs, and levels [3]. Individuals requiring access to student information must login through a single secure login process [4]. The user is authenticated and then granted access to the data using industry-standard security protocols (unique identifiers and passwords). Access by students to these services is controlled via the secure login profile established by each eligible user. The profiles and unique identifiers are maintained in a secured database or server that follow the industry standard with regard to the creation of a username and password. When appropriate or necessary, data passed over the Internet through the web applications for facility, staff, or students are encrypted. MABTS follows the American Association of Collegiate Registrars and Admissions Officers (AACRAO) publication entitled Student Records Management: Retention, Disposal, and Archive of Student Records [5]. All student data is stored electronically on secured databases and servers, or physically in secure, fireproof filing cabinets. The Registrar and Registrar’s assistant oversee the security and access authorization process, and as part of the process, administrators are granted broad to limited access which allows them to view only and/or update student information depending upon their job/role function. As part of the information management account creation process, the Registrar determines the proper level of access and the appropriate data sets for which the individual will be authorized. The Registrar is responsible for the safety and preservation of the academic records of the seminary and makes certain that only authorized persons use academic records [6].

 

The Registrar is the designated data steward for each student’s academic records. The release of information to external requestors is approved by the Registrar, in accordance with established policy requiring written consent of the student [7]. Administrative users in the Registrar’s office are required to sign a data confidentiality statement [8] as part of their job acceptance.

 

Release of Records. Student academic records are available for inspection by the student and authorized seminary personnel, but these records are regarded as confidential and are not released to unauthorized persons. Student academic records are released to other persons or institutions only with the written consent of the student. No official transcript of a student record is furnished until all financial obligations to the seminary have been satisfied. A fee of $5 is charged for each transcript [9]. Students are free to print their unofficial transcripts at any time.

 

MABTS is subject to the Family Educational Rights and Privacy Act (FERPA) of 1974, establishing rights and duties with respect to the education records of students attending MABTS. It is the institution’s intention to fully comply with this legislation and to protect the rights of the students. MABTS has in place the use of Consent for Student Release of Information form [7] to assist with the protection of student rights. Educational records include financial aid, student account records, and academic records, which are considered confidential and will not be released without written consent from the student, except to the extent that FERPA authorized disclosure without consent. For this reason, it is necessary for the Campus Life office at MABTS to obtain permission from a student in order to release financial and academic information not excluded by FERPA laws. Copies of FERPA are available in the Campus Life office, Admissions office, Registrar’s office, and the Dean of Men/Dean of Women’s Office. Students may complete the Consent for Student Release of Information form in the Campus Life office with the name and relationship or any individuals they wish to be able to access their information. Authorization for an individual can also be revoked at any time by completing the same form in the Campus Life office.

 

International Student Records

 

The Registrar is the school’s Designated School Official (DSO) for the Student and Exchange Visitor Program (SEVIS) administered by the United States Immigration and Customs Enforcement office which is part of the Department of Homeland Security (DHS). Mrs. Maria Wooten, the Director of International Student Records, serves as the Primary Designated School Official, (PDSO). She maintains confidential immigration files on each F-VISA status international student, per federal immigration regulations and DHS via SEVIS. Student files are accessible only to the DSO and PDSO. Physical files are secured at the end of each business day [10].

 

Students with Disabilities. In accordance with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, the Registrar is responsible for maintaining the medical documentation, letters of accommodation and request for individualized testing. Accommodations for students with disabilities are deemed confidential [11]. Confidentiality of student records and information is a high priority; therefore, in an effort to maintain appropriate confidentiality, all student records are maintained in locked file cabinets with limited staff key access.

 

Student Disciplinary Records. Student disciplinary records are maintained in the offices of the Dean of Men and Dean of Women. These records are kept in locked filing cabinets with access restricted to the Dean of Men and Women.

 

Student Health Records. Student health forms [12] are maintained by the Registrar in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPPA) [13]. Student health forms are kept in a secure locked filing cabinet, and students who request a copy of their health form must complete the Consent for Student Release of Information form [7].

 

Scholarship Records. Scholarship information and forms [14] are collected by the Campus Life Office and stored in the Business Office. Access to this information is restricted to the Scholarship Committee and Campus Life Office personnel.

 

Veterans’ Education Benefits and Records. The seminary maintains confidential educational benefit records of veteran students and does not release records to unauthorized personnel without written consent of the student. Personnel authorized access to Veterans Administration (VA) records include a VA education representative who annually reviews the files, and a Tennessee Higher Education Commission (THEC) representative who views all files of students receiving VA educational benefits. United States military service members, veterans, and dependents of veterans who are eligible for veterans’ education benefits may apply to defer payment of tuition for the current semester. Application must be received on or before the final registration day of the current semester. If approved, tuition must then be paid to the Business Office no later than the last day of the current academic semester. This is in conjunction with THEC policies [15].
 

Documentation

 

1. 2014-15 Employee Handbook, p. 6

2. 2014-15 Student Supplement and Housing Handbook p. 22-23

3. SONISWEB Registrar and Records

4. SONISWEB Login Page

5. AACRAO Student Records Management

6. 2014-15 Employee Handbook, p. 32-33

7. Consent for Student Release of Information Form

8. MABTS Confidential Records Employee Agreement

9. 2014-15 MABTS Catalog, p. 82

10. 2014-15 Employee Handbook, p. 31 and 33

11. Americans with Disabilities Act

12. Health Record Form

13. HIPPA

14. Scholarship Application

15. 2014-15 Student Supplement and Housing Handbook, p. 32

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