Comprehensive Standard 3.9.2

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

Judgement: Compliant

Narrative:

With respect to the security, confidentiality and integrity of student records, the University of South Carolina Upstate (USC Upstate) operates in accordance with the Family Educational Rights and Privacy Act (FERPA) (available online only), the South Carolina Family Privacy Protection Act of 2002, and the University of South Carolina (USC) System policies (ACAF 3.03) as they relate to handling of and access to records.

By USC System policy, all computerized student academic records are maintained on a USC system-wide mainframe. The mainframe houses the databases for academic records, admissions, financial aid, financial transactions, advisement, and other similar student records. The Computer Services Division at USC Columbia uses an IBM 9672-R53 enterprise server running OS390. Every Tuesday night, the data is backed up with tapes on an off-site rotation. The Production Control area of Computer Services is staffed 24 hours a day, seven days a week. USC Upstate users access the mainframe with a router using a T1 line. The University is currently in the process of replacing this legacy system with a new Banner-based software system. The project, called OneCarolina, not only will replace the mainframe system but also will encompass many of the miscellaneous home-grown databases that offices have created.

USC Upstate offices that handle student records in electronic and hard-copy forms adhere to specific procedures designed to ensure the security, confidentiality and integrity of the documentation. USC Upstate’s Information Technology and Services provides Monday-Friday scheduled backups of locally maintained public and secured servers.  Success/failure reports are run daily on the backups.  Every Monday, Iron Mountain Company collects the backup tapes which are then stored offsite creating a secure redundant repository.

Most student records are stored on the mainframe through the Information Management System (IMS) or Visual Information Processing (VIP). Batch processing of information is occasionally accomplished through the Time Sharing Option (TSO). Security measures associated with each are discussed below.

Registrar’s Office
The Registrar is responsible for granting initial IMS access to University employees. An employee who requires access must submit a request to the Registrar through the immediate supervisor and list the reason(s) the access is needed. Requests for access to specific modules within IMS are discussed with appropriate personnel with oversight for those areas. For example, if an employee seeks access to financial aid information, the Registrar discusses the appropriate level of access with the requesting party and the Director of Financial Aid. In some special situations, key student employees are also given IMS access to enable them to complete their tasks in their respective areas (usually Records, Admissions, and Financial Aid). Once the need for such access has been determined, the Registrar notifies Information Technology and Services to request a user id through USC Columbia. Once the user id has been assigned, USC Columbia notifies Information Technology and Services.  The Registrar instructs University personnel about the responsibilities associated with IMS access as well as the implications related to the Family Education Rights and Privacy Act of 1974 (FERPA).  As a means to lessen the chances of a security breach, IMS passwords expire monthly.

While many entries into IMS such as registration transactions and grades are made locally through the Registrar’s office, there are some transactions such as grade changes or name changes that are routed to USC Columbia to be entered. Hard copies of such changes are securely maintained. Several weeks after a batch is sent for entry, IMS is reviewed to make sure the changes have been accurately entered. After this verification, local hard copies of the documents are shredded. The actual change request form that was sent to Columbia is microfilmed and securely archived. Scanned copies of forms can be viewed locally by records personnel if necessary.

Students and faculty typically access student records through VIP. To gain access to VIP, faculty are asked to complete online FERPA training. Student access to VIP is through a PIN that is automatically emailed to the student.  The Registrar reminds faculty and staff annually of the provisions of FERPA and their responsibilities to adhere to the law.

Admissions
Admissions trains new staff members on the need to protect the security of students’ documents and records. FERPA requirements are periodically reviewed as part of staff meetings or office retreats. Student workers receive FERPA training from the Career Services Office (via the Work Study Coordinator) and are required to sign a confidentiality agreement showing their understanding of the requirements.

In an attempt to protect personal data from visitors to the Admissions Office, privacy screens have been installed over the PC monitors in the reception area and partitions separate computers for student use in the lobby area. Students inquiring about their status from a staff member at one of these three stations are asked to write their name and last four digits of their social security number on a visitor card. Number key pads are used at the front service area so student privacy is protected.

Access to Admissions records – both hard copy and electronic – is limited to individuals with a legitimate need for such access. Hard copy files (applications, transcripts, etc.) are kept in the secure file cabinets in the processing office to which approximately 15 people (professional Admissions/Enrollment Services staff, Admissions student workers) have “walk in” access. Access to the University’s mainframe database (IMS) in which admissions data is stored is provided and monitored by the Registrar and is assigned via individual user accounts with role-based access. Faculty/staff outside Admissions have access to a very basic “view only” screen.
Currently document imaging is used for all documents related to the admissions process.  Hard copies of documents are kept in secured cabinets and shredded after 90 days on file. The electronic file for all enrolled students is sent to the USC Columbia Office of the Registrar for permanent storage.

Admissions began using the EMAS constituent relationship management software package in 2010 to facilitate communication with prospective students. Data are downloaded daily from the mainframe into EMAS, but the mainframe is the dominant “system of record.” Changes to information in EMAS in no way affects data stored on the mainframe. Access within EMAS is role-based, with only the Admissions Director and two system administrators having edit access to the entire package.

Financial Aid Office
To ensure the security of its records, the Financial Aid Office maintains hard copies of financial aid records. These records are filed in locked cabinets in a secured room with restricted employee-only entry. Electronic records are protected by a series of login steps and passwords accessible to Financial Aid staff only.

Only the last four digits of the social security numbers are printed on documents. Students who come to the office for assistance are asked to write down their identifying information so that it is not overheard. The identifying information is subsequently shredded.

Up-to-date training of staff takes place so that they are aware of FERPA and other privacy laws to ensure the integrity of records. Access to records/code sets, inquiries, and updates varies by staff roles and responsibilities. Staff have access only to data needed to perform their jobs.

The principal financial aid records are maintained on the mainframe and are accessed via IMS. Working copies are kept within a secured electronic database that meets Title 4 requirements and in secured paper files.

All records are maintained and kept secure for the required time period outlined by the U. S. Department of Education, NCAA, CHE and USC Upstate. Records that are no longer required to be maintained are shredded.

Health Services, Counseling Center, and Disability Services
Student records in the Counseling Center are primarily in hard copy hand-written format. At the conclusion of the work day, student files are secured in file cabinets inside a locked office. Only counselors and the administrative assistant are allowed access to the files and ensure that cabinets are secured.

Within the Health Services center, there is a database for all clients. All members of Health Services (nursing professionals, director, and administrative assistant) have access to the records. The database is password protected and can only be accessed with Health Services staff log-on. All files are kept locked inside the administrative assistant’s office.

All hard copies of files of students who request disability services are maintained in the Disability Services suite in a locked cabinet. Only authorized personnel (Director, Assistant Director, and administrative assistant for Disability Services) have direct access to these records. Electronic files are maintained with a password protected system and only the Director, Assistant Director, and administrative assistant of Disability Services have direct access to the system.

Professional opinions and private case notes regarding conversations and student issues are maintained in a confidential electronic system that is only accessible to Disability Services staff. These notes are not a part of the student’s official file.

For all areas, professional staff are bound by confidentiality requirements of their profession. All staff are required to sign a confidentiality agreement. Any requests for copies of student records must be accompanied by a written authorization from the student. Photo identification is required when an individual walks in requesting a copy of his or her own records. In all instances when information is released, a record is maintained of what records were released, to whom they were released, and the date they were released.

To ensure student health records will not be lost, both paper and electronic documentation are maintained.  The database and back-up services are recoverable within a 30-day period. The Disability Services server is also backed-up on a regular basis with the University server system.

Center for International Studies
Paper copies of international student files are stored in a locked file cabinet in the Center for International Studies. Electronic student records are all password protected and stored on a password protected server and in the Federal Immigration Database (SEVIS). Only four authorized users are allowed to access the database and make changes to student records – the Associate Vice Chancellor for Enrollment Services, Director of Admissions, and Director and Associate Director of International Studies. The time and date of access by all authorized users of SEVIS is itself recorded in the database.

Immigration requires that a copy of international student advising files is kept for one year after students graduate or separate from the University. After that time, paper copies of the files are shredded. SEVIS electronic records remain available for access/viewing in the SEVIS Database.

Student Life
Student records pertaining to student activities and membership in organizations are password protected and maintained on a secure server. Only professional staff (Director, Assistant Directors, and Office Manager) can access these records. Some organizations such as Greek organizations require the institution to submit academic records of student members to national offices. Before such information is submitted, students must sign an authorization to release the records. Under no circumstances are social security numbers or other personally sensitive information released through the Office of Student Life.

Athletics & NCAA Compliance
To ensure the security of student athlete records, hard copies are secured in locked file cabinets. Electronic copies of student athlete information are maintained on the NCAA Compliance Assistant, a secure Internet-based NCAA database and within other NCAA or Atlantic Sun
Conference reports completed on secure sites. Prospective student athlete information is housed on a secure internal server.  The integrity of this information is password protected.

Career Services
Career Services maintains files that contain hiring forms related to student employment, password protected databases (Spartan Careerlink, SIGI3) with student and alumni contact information, student resumes, student personality assessment results, and experiential education application forms with contact information. Employment and career interest inventories are only entered into secured databases on a server and no hard copies are stored.  Only Career Services staff have access to the information on the databases.

Housing and Residential Life
Hard copies of student housing records are secured in a locked file room. Only selected Office of Housing and Residential Life staff have direct access to the file room. Electronic records are kept in secured areas on the network and are backed up daily. The shared (P) drive that houses the electronic records is accessible only through ACCESS by staff with varying levels of access. The housing data management software, Odyssey HMS, is maintained on its own server located at USC Columbia and backed up nightly. Access to HMS is granted through the system administrators depending on job responsibilities.

Confidentiality is addressed through the security of records, limited access to records, confidentiality agreements, and training sessions. The Office of Housing and Residential Life has procedures in place to minimize errors and prevent unauthorized access or changes to records. In HMS, all transactions are recorded in the software’s Admin Module, including the identity of the user and action performed. Paper documents are logged electronically in HMS system before they are filed.

Administrative records are kept in the office for one fiscal year and then moved to secure storage for five years before being shredded. Student housing records are kept in active files as long as the student is housed and then retained for five years after termination of contract.

Dean of Students, Discipline & Policies
Academic Integrity and Student Behavior discipline records are maintained in the Dean of Students office. Records are maintained through an electronic database and backed up through an offsite server. Certain paper copies are secured in locked file cabinets and are only assessable by the Dean of Students, Director of Housing, and the administrative assistants in those areas. Persons not directly involved with a discipline case, an appellate review of a decision, or the enforcement of a sanction do not have access to the record or results of a hearing or sanctioning meeting without a legitimate educational need to know or the authorization from the charged party. Records of major violation cases which have been resolved with a sanction less than suspension are maintained for a period of at least 7 years from the date of the last offense. Records may be retained by the University beyond the normal 7-year period in special circumstances, including, but not limited to, situations when legal action is taken by any party involved. When a date for purging records has been reached, records in all formats are destroyed. Records where the discipline sanction was suspension or expulsion will be maintained indefinitely.

Department of Public Safety
Criminal reports processed through the Department of Public Safety are generally considered public information and are available through Freedom of Information Act (FOIA) requests. However, information related to victims of sexual assault and/or juvenile cases is excluded from public disclosure. 

Electronic records are maintained in the Department’s Report Management System while paper copies are secured in a locked file cabinet within the Department. Reportable offenses are electronically transmitted monthly through the South Carolina Incident Based Reporting System (SCIBRS) to the South Carolina Law Enforcement Division (SLED). Non-reportable incidents are also maintained in a secured file cabinet within the Department. 

All employees of the Department of Public Safety are required to sign a Confidentiality Agreement upon commencement of employment. To ensure the integrity of student records, a supervisor is required to review, approve, and sign all reports. Once a report is approved by a supervisor, it may only be changed or amended with the approval of the supervisor. No official record is ever destroyed with the exception of misdemeanor cases pursuant to an order of expunction received by a court of competent jurisdiction.

Data Warehouse, OnDemand, CMS, and other Reporting Systems
Access to the DataWarehouse, OnDemand, and Conversational Monitoring System is heavily secured and given to a limited number of individuals with operational support job responsibilities (e.g., Information Technology and Services; Office of Institutional Research, Assessment and Planning). These tools allow for both designed and ad-hoc queries and reports. In accord with system-wide data access policy (UNIV 1.50), the University of South Carolina system-wide Data Stewards, who are managers of functional areas (typically at the level of Comptroller, Registrar, or Director of Admissions) must approve access to the data under their charge through these tools.

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