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Compliance Certification Report
Comprehensive Standards 3.9.2


Last Updated Aug 13, 2004
(static edition)


Comprehensive Standards 3.9.2:

The institution protects the security, confidentiality, and integrity of its student records.

The Institution Certifies Compliance: Yes

Compliance report completed by: Audit Team 22

Statement of Rationale for Judgment of Compliance:

Student records are managed and maintained by various offices on campus (see Inventory of Student Education Records). [1]  A copy of this list is maintained in the Office of the Registrar for students who want to request access to these records. These records are maintained securely, and confidentiality is protected by adherence to the Family Educational Rights and Privacy Act (FERPA) requirements. [2] Employees are introduced to this policy both as they go through new employee orientation and when they request access to electronic student data. They are required to read the policy and sign an acknowledgement statement. Students are informed each semester of their rights to inspect records as part of a routine communication to students. [3] Directory information is not listed for those students who choose to request privacy of this information. [2] The Office of the Registrar manages the non-disclosure procedure. [4]

All student records are retained or destroyed according to the UofM Policy for Records Management Program. [5] General procedures for the major sets of “official” records are described below. For the other sets of records as described in the Inventory of Student Education Records, a fact sheet is provided in the supporting documentation for this standard. [6]

Admissions – Undergraduate, Graduate, and Law

Admissions records include applications, transcripts, test scores, residency information, and supporting documents. Access to these records is granted on a need-to-know basis for employees who work directly with the admission process. Employees are required to sign a statement of confidentiality. To ensure integrity, records are secured by restricted access; records are locked when personnel are not present. [7] The release of information to students is based on FERPA requirements and necessitates proof of identification by the student.

Medical Records

The director of Student Health Services at the University of Memphis maintains medical records of students, faculty, and staff dating from 1993. Current records are housed in locked filing cabinets in a locked building. Student records older than five years (pre-1998) are housed in file boxes stored in a locked room in a locked building. Records are shredded after ten years by a signed directive from the vice president for student affairs. All student workers in Student Health Services read and sign a confidentiality statement upon employment. A copy of the signed statement is kept in the student’s employment file. Medical records are not released without the written consent of the patient. [8]

Psychological Counseling and Career Counseling Records

The Psychological Counseling and Career Counseling units within the Center for Student Development maintain records of both active and inactive students who request counseling services. The information in the records, which may include therapist progress notes, psychological and career testing information, and reports from other agencies, are confidential in accordance with the state of Tennessee laws related to the practice of psychological counseling, [9] the American Psychological Association’s Ethical Principles of Psychologists and Code of Conduct 2002, [10] and the federal Health Information Portability and Accountability Act. [11]

The Psychological and Career Counseling units also maintain a secure database that contains partial student records (demographic information, number and type of counseling sessions attended, psychoeducational testing information, and termination information) for all students receiving psychological and career counseling services in these units. The server for this database is contained within Psychological Counseling and access to this information is password-protected and accessible only to full-time staff members of Psychological Counseling or Career Counseling.

Counseling students in training are able to access only the records of the students they counsel. Information is disclosed to other individuals or agencies only with written permission signed by the student and witnessed by another employee of the Psychological Counseling or Career Counseling units on the Release of Information Consent form. [12] Active and inactive student records are maintained in locked file cabinets within a locked room.

Professional and Continuing Education Records

Professional and continuing education student data are stored in a password-protected stand-alone database. Passwords are issued to professional and continuing education staff only. Online registrations are collected on a secure website authorized and maintained by the university’s Information Technology Division. New employees are made aware of Family Educational Rights and Privacy Act (FERPA) guidelines as part of their orientation and sign a FERPA statement. Periodic reiterations of the FERPA policy are issued to employees via e-mail from the Office of the Registrar.

The student database is backed up automatically every fifteen minutes and is copied to disk daily. One disk is stored on-site overnight; the other is taken home with the registration supervisor. Back-up disks for previous terms are stored off-site at a fireproof commercial facility. Paper records are retained for five years in compliance with Tennessee Board of Regents [13] and university policy; [5] paper records over five years old are shredded. Electronic data are stored indefinitely.

Student Discipline Records

The Office of Judicial and Ethical Programs maintains student discipline records according to FERPA guidelines. In addition, students who have graduated may petition to have their records expunged. Cases involving residence hall expulsion, university suspension, and expulsion cannot be expunged.

Residence (Housing) Records

Student housing applications, contracts, housing-related information, and rent payment history records are maintained by the Office of Residence Life and Dining Services. Each employee receives training and a staff manual to ensure appropriate use of data, consistent with university and FERPA guidelines. The electronic data system is backed up nightly on a separate server, and physical files are secured in locked cabinets. Retention and destruction are governed by the university’s records retention management program. [5]

Financial Aid and Student Employment

The Office of Student Financial Aid maintains records for financial aid award applications, awards, and supporting documents for all types of financial aid and scholarships. The office is also responsible for student employment records. Access is restricted to employees in the office who are required to sign a confidentiality statement pertaining to the release of information. Files are secured in locked file cabinets and offices are locked during times not supervised by employees. Retention and destruction are governed by the university’s records retention management program. [5]


Relevant Organizational Unit(s):

Registrar; Vice President for Student Affairs


Supporting Documentation and Evidence:

[1] Inventory of Student Education Records
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[2] UofM Policy UM1248 Privacy of Education Records (Compliance with FERPA)
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[3] Student Right to Know Information, Records Access and Security
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[4] Restriction/ Release of Directory Information 1.3.4.28
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[5] UofM Policy UM1365 University Records Management Program
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[6] Inventory of Student Education Records
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[7] UofM Response to Comprehensive Standard 3.4.11
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[8] UofM Policy UM1384 Health Services
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[9] Tennessee Laws Governing Patient Records
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[10] American Psychological Association’s Ethical Principles of Psychologists and Code of Conduct 2002
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[11] United States Department of Health and Human Services
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[12] Release of Information Consent Form
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[13] TBR Guideline G-070 Disposal of Records
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