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Protecting the Privacy of Student Records, Section 4 summary
Section 4:
Securing the Privacy of Data Maintained
and Used within an Agency 

Section Summary:

A. Management Responsibilities

  • An official designated as the records manager should be responsible for keeping individual records safe and intact from accidents, unauthorized access, theft, changes, or unintentional release.
B. Defining "Legitimate Educational Interests"
  • It is more practical to establish criteria for determining broad categories of positions than to list exactly who or what individual positions are considered "school officials."
  • While agencies or schools may establish a policy to determine what constitutes "legitimate educational interest," the decision also may be made case-by-case.
  • If you have any questions about whether a requestor has a legitimate educational interest, ask the records manager not to disclose the information without prior approval from the parents or other appropriate officials.
C. Training Agency Staff
  • All staff should be trained in information security as soon as they are hired. You should inform staff of what is considered appropriate and inappropriate access to data and use of the information within the records.
D. Professional Ethical Standards
  • Existing professional standards are invaluable resources to support policymaking and training.
E. Research Use within an Agency
  • It is important to determine each time whether the staff assigned to conduct the research are trained and authorized to access the data. An alternative approach is to sidestep the question of security by creating a research file deleting the students' identifying information.
[Section 4 full text]

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National Center for Education Statistics - http://nces.ed.gov
U.S. Department of Education