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FERPA Considerations for Faculty


Posting of Grades

Posting of grades after an examination or at the end of a semester is a very efficient and effective way of transmitting information to students about their academic progress. Under the FERPA regulations, you may not post grades by a full or partial Social Security Number under any circumstances. Contrary to popular belief, having students sign a waiver at the beginning of the semester is not sufficient to avoid a FERPA violation.

The Student ID number should not be used either to post grades. A compliant alternative is to assign students random examination identification numbers, and to post grades in random order by these numbers. (Note that posting in alphabetical order is also problematic, as the identity of students could be ascertained.) Such random numbers could be assigned at the beginning of a course and used throughout the semester. Students should be urged to keep the numbers confidential, and a statement to this effect should be included in the course syllabus. The best solution, however, is to post grades in UD’s learning management system (Canvas).

Calls from Parents (or others)

Parents often call faculty to inquire about their student's academic progress, as well as to find out about admission to majors and programs, among other reasons. Remember, you cannot share any information about the student's academic record, progress, or eligibility with a parent. The safest way to handle student specific inquiries and avoid violating FERPA is not to discuss any student-specific issues with parents or any one else other than the student.

This may be challenging, but releasing such personally identifiable information usually violates the FERPA statute and could place you at risk legally. The best thing to do is to urge the parent (or other caller) to speak with the student, and have the student stop by, if possible, to make the inquiry in person. Alternatively, you could refer the caller to the college advising office, the undergraduate or graduate admissions office, or other appropriate academic administrative office, where the procedures can be explained in more detail.

Note: It IS okay to provide general information. Think of this as information published on a website, like important dates and deadlines, information from the academic catalog, and, of course, the link to the Parent/Guardian Secure Services web application where a student can authorize a parent to see specific information from their academic record.

Personal, Non-public Information (PNPI)

State and Federal laws and regulations govern the safeguarding of personal, non-public information (PNPI), such as Social Security Numbers (SSNs) and grades associated with names. Faculty and Staff are cautioned to properly protect this information by encrypting electronic files and locking stored hardcopy files.

FERPA Responsibilities for UD Employees

The webpage FERPA Responsibilities for UD Employees provides a complete list of FERPA-related information, definitions, procedures for the disclosure of education records to third parties, general rules and actions allowed and not allowed under FERPA.

Canvas and other learning management tools

Canvas allows site participants to interact with each other within a site. Depending on which tools an instructor uses in their course site, students may have access to the name(s) of other students who are enrolled in the course. For this reason, only classes that meet together (for example, a dual-listed 400/600-level class or two cross-listed classes offered under different course rubrics) are combined in Canvas.

The safest way to ensure compliance with FERPA is to only combine class sections in Canvas that meet together at the same time/location and copy content to other course sections when applicable. In rare cases, a faculty member may request to merge separate class sections into a single Canvas course. If approved, it is the INSTRUCTOR’S RESPONSIBILITY to take the necessary steps to ensure student privacy and compliance with FERPA Information for UD Employees. Specifically, the instructor will need to make changes in the settings for a merged Canvas course that prevents students from seeing or interacting with students in sections other than their own unless the sections meet at the same time and in the same location. They will also be required to change settings on each individual registered for the sections that are merged. In Canvas, the settings that the instructor will need to check/update to ensure student privacy can be found in the online information sheet: "Ensuring Student Data Privacy Within Combined Course Sections in Canvas".

If an instructor does not make the appropriate adjustments in the Canvas setting to comply with FERPA, future course combination requests in Canvas will not be approved. As a reminder, FERPA is enforced by the United States Department of Education, which has the authority to audit institutions of higher education for FERPA compliance. FERPA violations may result in the loss of federal funding for the University. Any breach of confidentiality that results in a violation of FERPA could lead to the imposition of disciplinary sanctions under University human resource policies.

Further questions?

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