Virtual Graduation Events and Privacy

This page provides guidance for privacy and information security considerations if you are planning virtual graduation events. These were reviewed by University Registrar and FERPA Officer Helen Garrett.

With respect to FERPA, there are two considerations we attempt to address in our recommendations for hosting virtual events: whether a record is created and what kind of information will be shared. We also consider FERPA-compliance of technologies.

Main Points:

1. Students should be notified ahead of the event whether the event will be recorded, livestreamed, the information that will be shared, where the event will be hosted, who will have access to the event and/or recording, and for how long.

2. Students should have the ability to voluntarily “opt in” to the graduation event. Releases to share information should be maintained until the event is over or if there is a recording, until the recording is removed from UW websites and deleted.

3. “Opting in” should include a written process or completion of a form where students are notified that with their affirmative response they are consenting to x,y,z.

Platform

• Be mindful of the platform being used.

  • Marching Order, Grad Images, and Zoom are FERPA-compliant and/or have contracts with the University of Washington.

  • If you are integrating other non-FERPA compliant platforms - YouTube, Vimeo, Facebook or others, be explicit ahead of the event about how the technologies will be used.

Recording

• Graduation event recordings maintained and posted on UW websites will be considered a student record.

• All parties must consent to being recorded.

• Participants must be told where the recording will be kept, who will have access, and for how long.

• Review best practices from the UW Privacy Office (the source of most current guidance for UW on this topic) and our section on Privacy & Information Security.

• Review best practices from the Records Management Office. (See the last bullet item in particular.)

  • Per Barbara Benson from the Records Management Office, graduation event recordings fall under the retention schedule for Photos, Slides, Videotapes, Audiotapes. Any recordings or files for the graduation event sent by students do not need to be saved in their student file.

  • If you would like to have a graduation event recording hosted by the University Archives, please contact John Bolcer at (206) 685-2352 or jdbolcer@uw.edu.

Livestreaming

• Review information from the UW Privacy Office about livestreaming events, which is the source of most current guidance for UW on this topic.

• Because a livestreamed event does not create a record, FERPA does not apply in that regard.

• However, FERPA-protected directory information is likely going to be shared at the event -- name, degree, awards, etc., from education records. Note that student photographs are not included as part of UW’s directory information.

• Students must be made aware of the event details and the information that will be shared, and must voluntarily opt-in.

Event Programs and Webpages

• If a student has not opted out of the directory information release (“Yes” for the FERPA release), the University may share items included in the directory without written student consent.

• If the student has opted out of the directory information release (“No” for the FERPA release), then students must provide permission to print their name or any other directory information on graduation programs or webpages.