FERPA & Remote Instruction

Communication

Please only communicate via email with students using their allegheny.edu email address rather than through another personal email.  This email is protected by FERPA and helps us verify the student’s identity. It is imperative that we are using the student’s college account when having conversations surrounding not just registration or advising related items but also when engaging in any discussion about their educational record, including their distance learning.  Additionally, staff and faculty should only be using their Allegheny email accounts when working with students. Remember, if you are using your personal computer, tablet, or phone, your Allegheny email account may not be set as the default.

Education Record Clarification

We are all making the best of an unprecedented situation and it is helpful to remember what constitutes an education record.  Education records are those that are directly related to the student and that are maintained by the institution. Everything in Colleague, Sakai, Google Classroom, assignments, grades and any communication to the student, is a part of the student’s education record.  If you are conducting a class synchronously and making a recording of the class, that becomes a part of the student’s education record. Any information that is Personally Identifiable Information (PII) is protected by FERPA. See our FERPA faculty and staff FAQ for more information.

What Needs to be Documented and Maintained

(this is true in any teaching/learning environment)

  • Advising records

    • You may now store your advising notes in Self-Service, if you wish, although they will be visible to anyone who has access to that student’s record. If your advising is conducted via email or some other electronic mode, it is considered a part of the education record and needs to be saved.

    • If a student is requesting an action that was on paper a few weeks ago, please have them use the new online forms on the Registrar’s Office website for documentation.

  • Academic records

    • Grades or scores

    • Discussions, chats, blogs and all assignments in Sakai or Google Classroom

    • Exams, tests, quizzes in Sakai or Google Classroom

    • Email communications to and from students

    • Any other course materials that will be used for grade assessment/evaluation in other places or modalities

  • Declaration or change of major/minor (please instruct students to use the new on-line form)

Communication of Grades

As we migrate to distance learning, faculty are encouraged to use Sakai for posting and communicating grading information to students. This is the platform that the college is prepared to support for your grading needs. While FERPA does not explicitly prohibit the emailing of grades, you should be careful in doing so.

However, we understand that Sakai may not work for every faculty member under the current circumstances. In light of that, we want to discourage emailing grades, but understand that flexibility in this area is needed.  If you must use email to communicate grades, here are some hints:

  • Do not provide grading information to groups of students, unless a grade for a group project or assignment is appropriate.

  • If you are emailing attachments, double-check you are including ONLY documents that contain information for the student with whom you are communicating.

  • If you do accidentally release PII to a third party (e.g., sharing a grade with others) we need to document that. Please e-mail registrar@allegheny.edu

Recordings, Video, and Online Presence

Any distance learning environment should be treated just as a face-to-face instruction would be handled. Students are expected to actively “participate” as outlined by the syllabus and students cannot expect anonymity through distance instruction. Faculty are encouraged to record sessions and make them available to students in their class at a later time. Faculty who do record, however, are encouraged to inform students at the start of any session that it is being recorded. If a student raises a concern, consider whether it is possible to address their concerns. Given the challenges we know students are having with synchronous remote instruction, we should avoid turning off the recording function if a student has expressed a desire not to be recorded, although that is an option. Another possibility is to ask a student who does not wish to be recorded to turn off their camera, mute their microphone, and participate in the class silently. They could send the instructor their opinions and questions in a seperate, private Chat window not shared with the rest of the class. With some exceptions for public presentations or engagement, whenever possible, access to the recordings should be limited to those enrolled in the section.

This is not an exhaustive list of privacy issues and concerns you may have, but is an example of the kinds of records we need to maintain.  Please contact registrar@allegheny.edu if you have questions.

Please slso see here for additional information from LITS about FERPA and Protecting Video Recordings from Unauthorized Use.

 

Below is the suggested language we encourage you to put the statement below in your syllabus and tweak as appropriate for your courses:

FERPA, Privacy, and Remote Instruction Syllabus Statement

In a distance learning environment, the federal law (FERPA) continues to remain in effect, but students should think about their role in supporting the privacy of fellow students. As this course transitions to increased remote interactions, be cognizant that shared pictures, written assignments, videos, emails, blog posts, discussion boards, etc. remain part of the content of the course, just as it would if it were shared in the face-to-face classroom setting.  While the privacy of those posts cannot be guaranteed , the expectation is that each member of the class treat those materials with care and not reshare or post beyond the class.

 

 

This is adapted, with permission, from Augustana College. Last updated 03.27.2020.