11 - FERPA

FERPA - DGSOM Access to Student Records Policy

The Family Educational Rights and Privacy Act (FERPA) of 1974 sets forth requirements regarding the privacy of student education records. FERPA governs the release of these records maintained by an educational institution and access to these records.

Students have three primary rights under FERPA:

UCLA sets clear guidelines regarding disclosure of information from student records. For detailed information, please check here: UCLA Policy 220

The Liaison Committee on Medical Education (LCME) also addresses access to and disclosure of student records in Standards 11.5 and 11.6 which can be viewed here: http://lcme.org/publications/

David Geffen School of Medicine Family Educational Rights and Privacy Act (FERPA) Policy

It is the purpose of this policy to provide reasonable interpretations of the Federal Family Educational Rights and Privacy Act and to protect the student's right to privacy as guaranteed therein. This DGSOM policy is designed to ensure that student educational records are available only to faculty and administration who are permitted to review them in accordance with FERPA, and accessible to DGSOM students and their designees as stipulated below.

1.  Students may request in writing for themselves or any other individual(s) to be granted access to their student records. Access is provided by extracting and securely transmitting the requested records. Access is not granted directly to the system of record.

1. Student enrollment status and course schedules
2. Grades
3. Academic/Professional Standing
4. Summative Student Performance Evaluations  
   1. Individual evaluations are collected solely for the purpose of informing the creation of the final, composite evaluation for each clerkship. The final composite evaluation is the basis for final grades on the clerkship, and it is the evaluation that is considered part of the educational record under the Family Educational Rights and Privacy Act (FERPA). Access to individual evaluations for clinical rotations is not provided.

2.  Educational Data Staff within the Education Technology Services unit of DGIT have access to medical student records for the purpose of building and maintaining data systems and reporting.

3.  Access to student data within digital systems is role-based and assigned based upon the specific educational role of the faculty or staff on a “need to know” basis.

4.  Faculty and Administrative Access to DGSOM’s Student Information System (SIS):

1. Only medical school leaders (i.e. deans) and medical education administration with legitimate educational interest in the student record are granted access to DGSOM’s SIS.
2. Medical education staff are granted access to SIS on a case-by-case basis. The Director of Student Affairs must sign-off on all access.
3. All system users must complete FERPA training prior to be granted access.
4. Students do not have direct access to the student information system but per FERPA, may request access to their student records at any time from the DGSOM Registrar.

5.  Faculty and Administrative Access to Evaluations of Student Performance:

1. Medical education leaders and staff, including deans, medical education staff, course directors and course coordinators with legitimate educational interest in the student assessment data are granted access to the School of Medicine’s online evaluation systems.
2. Additional faculty leaders, i.e. co-directors, site directors, with legitimate educational interest in student assessment data are granted access to the online evaluation system by the course director.
3. Access to assessment data specific to a course or clerkship is reviewed and renewed annually by the course directors.
4. Teaching evaluators have access to records of the student assessment data submitted by them until they no longer have access to the evaluation systems based on the end of their specific teaching responsibilities. 

6.  Access to student clinical skills and simulation assessment data is determined by the Faculty of record and/or course coordinator for a given assessment activity and is provided for a limited time for student review. Faculty of record and/or course coordinator accounts are managed by the Curricular Affairs and Simulation Center staff and access is limited to data for a given assessment activity.

7.  “Legitimate Educational Interest" means: (1) the information or record is relevant and necessary to the accomplishment of some task or determination; and (2) the task or determination is an employment responsibility for the inquirer or is a properly assigned subject matter for the inquirer. University officials with a "legitimate educational interest" may include:

1. A person employed by the University or an affiliated site in an administrative, supervisory, academic research, teaching, or support staff position;
2. A person serving on a University governing body;
3. A contractor, consultant, volunteer or other party to whom the University has outsourced institutional services or functions provided that the outside party performs an institutional service or function for which the University would otherwise use employees; the outside party is under the direct control of the University with respect to the use and maintenance of Student Records; and the outside party may not disclose the information to any other party without the Student’s consent, and may not use the information for any purpose other than the purpose for which the Disclosure was made;
4. A student serving on an official committee, such as disciplinary or grievance committee, or assisting another University Official in performing his or her tasks.

Approved by Clarence H. Braddock, III, M.D., MPH, MACP, Vice Dean for Education, July 2019

DGSOM Registrar