Student Privacy, Information Security & Advising with Technologykeyboard_arrow_down

Toward the end of Spring 2019, the UW Online Advising Group rebooted, and in early conversations we learned that many advisers were rightly concerned about FERPA with relation to using technology in their advising practice. A small working group was created and since that time has worked with the UW Office of the University Registrar, UW Privacy Office, UW Records Management Services, and the Office of the UW Chief Information Security Officer to examine FERPA through the intersection of advising and technology. Very early we realized that discussions about advising with technology needed to be expanded to include the broader topics of privacy and information security. You can see a current version of our working document, which will eventually be finalized and added to this website.

Additional Resources

• UW Zoom Privacy FAQ
• Privacy Best Practices for Online Conferencing
• Privacy Best Practices for Livestreaming

In a Nutshell: Tips for Protecting Student Information & Privacy using Technologykeyboard_arrow_down

Whether working on-campus or remotely, you are likely using technology to communicate with and about your students. FERPA applies to student records that are created, stored, and maintained by University school officials; however, when we engage with students over the phone, email, or video conferences we need to be mindful of digital privacy in a broader sense. These tips are drawn from the Student Privacy, Information Security & Advising with Technology working document -- for more information and resources please visit the original document.

• Ground your work in UW’s Privacy Values and Principles and provide a privacy notice when appropriate. Privacy expectations vary based on cultural, generational, and geographic background. They also change over time. Set expectations at the start of individual and group meetings and around the tools you will use for communication. Ask yourself if you would be comfortable if your own information was handled in the same way as your students’ information.
• Create a secure work environment.
  • Make it difficult for malicious and accidental data breaches to occur. Follow these Top 5 Tips to Secure Data from the UW Office of the Chief Information Security Officer.
  • Keep your conversations as private as possible. If you do not have access to a private space to work, use headphones, avoid using the student’s full name, and be transparent about who else may hear your conversation and how you are managing the situation.
  • Lock your computer when you need to step away, even just for a moment.
  • If using a personal computer that is shared with others:
    • consider setting up a separate login for your work (but still don’t download records locally).
    • don’t save login/password information in your browser (not a good idea in general).
    • do not download student records and keep them where others can see them. The preference is to store files on a FERPA-compliant cloud option.
• Understand the technologies you are using. Limit the number of technologies you use to start with so that you can take time to understand how they work and how to keep student information secure. While UW Zoom, UW Google Suite and UW OneDrive are FERPA compliant, it is important to understand how recording and sharing work as well as how the privacy settings can be modified. Important questions to ask include: Who has access to this document/recording? Can this document be accessed by someone who shouldn’t have access? Where will this recording be saved and for how long?
• Communicate safely. Be intentional with the information shared over email; emails can easily be forwarded or accidentally sent to the wrong person.
  • Use UW email addresses for students, staff, and faculty when communicating about students.
  • Be brief and specific.Before sending, consider whether you would be comfortable with someone who was not the intended audience seeing the email.
  • Share student documents over UW OneDrive, UW Google Suite, or Canvas instead of over email. Learn more about UW OneDrive and UW G Suite here.
  • Do not email lists of multiple students (e.g. course rosters).
  • Review additional best practices in our working document.
• Record only if truly necessary, and make sure you have consent to record. Washington is a two party consent state, so, any recorded interaction must be consensual. If recording is needed, particularly for group appointments, be transparent with students about the recording and its purpose, who will have access to it, and for how long. Consider whether there is an alternative for sharing information from the recording. Recording one-on-one appointments is not advised. For more information, see the Adviser Education Program section below on recording.
• Remember that digital documents and emails may be subject to FERPA and record retention policies. Recordings of individual student meetings, emails about students, and other electronic documents should be maintained according to a retention schedule if they meet the definitions provided by the UW Record Management Office through their published Advisors' Record Retention Schedule. If you access and store work files on your personal devices, and there is a open records request, you may need to turn over your device(s). See our working document for additional details.

To Record or Not to Record: Considerationskeyboard_arrow_down

Some advising staff may utilize technologies to manage synchronous individual appointments or group meetings with students. At UW, Zoom is the main FERPA-approved video conferencing tool available to advisers. Often we are asked to record meetings, but it is important to pause and ask yourself whether recording is necessary. For more information, please watch this video.

To Record or Not to Record: Considerations

Additional Resources

Privacy Best Practices for Online Conferencing