ADMINISTRATIVE PROCEDURE No. 3231
Type of Records
Student records shall be divided into two categories: the cumulative folder and supplementary records.
The cumulative folder may contain all information about a student which is collected and maintained on a routine basis, such as identifying information (name, birth date, sex, year in school, address, telephone number, parent's name, ethnic classification, emergency information, parent's place of employment, family doctor, babysitter, siblings); attendance records including date of entry and withdrawal; grades and other student progress reports; results of tests of school achievement, aptitude, interests, hearing and vision; health and immunization status reports; records of school accomplishments and participation in school activities; verified reports of misconduct, including a record of disciplinary action taken; and such other information as shall enable staff to counsel with students and plan appropriate activities. Identifying information may be limited if the student is a participant in the state Address Confidentiality Program.
Supplementary records about a student may be collected and maintained in connection with special school concerns about the student, such as confidential health information or reports connected with assessment and placement of a student who is formally identified as a “focus of concern;” reports from nonschool persons and organizations such as physicians, psychologists and clinics, except for general screening purposes; reports pertaining to specific problems associated with the student; and current reports of psychological tests and progress reports related to a student's disabling condition. All such reports included in records shall be dated and signed.
For the purpose of this procedure, working notes of staff are defined as those records about students which are maintained in the sole possession of the writer and are not accessible or revealed to any other person except a substitute for that staff member. Working notes are not considered student records within the purview of this procedure.
Annual FERPA Notification
The Walla Walla Public Schools, to meet requirements of the Family Education Rights and Privacy Act (FERPA), will provide parents/guardians annual notification of their FERPA rights to inspect and review the records of their children by publication in their child’s student handbook.
Access to Student Records
A. Custodial Parents/Guardians and Students:
Parents/guardians of students or eligible students may inspect and review the student’s cumulative folder and/orsupplementary records upon request. Parents/guardians or eligible students should submit to the student’s school principal a written request which identifies as precisely as possible the record or records he or she wishes to inspect. The principal will make the needed arrangements for access as promptly as possible and notify the parent/guardian or eligible student of the time and place where the records may be inspected. Access must be given in 45 days or less from the receipt of the request. The parent/guardian shall be provided analysis and interpretation by qualified school personnel of all information in the cumulative folder and supplementary records. When a record contains information about students other than the parent’s/guardian’s child or the eligible student, the parent/guardian or eligible student may not inspect and review the portion of the record which pertains to other students.
B. Non-Custodial Parents/Guardians:
A non-custodial parent/guardian has the same rights of access to school records as custodial parents/guardians, unless the divorce decree contains a specific court order to the contrary. In the absence of a prohibiting court order, principals will provide copies of report cards, an official school district calendar, and notices of regularly scheduled conferences to non-custodial parents/guardians making such request at no charge. Principals will inform the custodial parent/guardian of the receipt of a request from the non-custodial parent/guardian.
Copies of Records
The Walla Walla Public Schools will not provide a parent/guardian or eligible student a copy of the student's record unless failure to do so would effectively prevent the parent/guardian or eligible student the right to inspect and review the records. If the record involves answers to a standardized test, the district will not provide a parent/guardian a copy of standardized test questions.
Disclosure of Student Records
The Walla Walla Public Schools will disclose information from a student’s records only with the written consent of the parent/guardian or eligible student, except:
A. To school officials who have a legitimate educational interest in the records.
A school official is:
1. A person employed by the district as an administrator, supervisor, instructor, or support staff member.
2. A person elected to the school board.
3. A person employed by or under contract to the district to perform a special task, such as an attorney, an auditor, medical consultant or therapist.
A school official has a legitimate educational interest if the official is:
1. Performing a task that is specified in his or her position description or by a contract agreement.
2. Performing a task related to a student’s education.
3. Performing a task related to the discipline of a student.
4. Providing a service or benefit relating to the student or student’s family, such as health care, counseling, or job placement.
B. To other districts upon official request from the district, unless the student has an outstanding fee or fine. (see Policy 3231)
C. To authorized representatives of the comptroller general of the United States, the commissioner of education, and/or an administrative head of an education agency or state education authorities in connection with the audit and evaluation of federally supported education programs or in connection with the enforcement of the federal legal requirements for such programs.
D. To state and local officials to whom such information is specifically required to be reported or disclosed pursuant to Washington state statute (examples: reporting child abuse or referrals to juvenile court for truancy).
E. To organizations conducting certain studies for or on behalf of the district.
F. To comply with a judicial order or lawfully issued subpoena, upon condition that the parents/guardians or adult student shall be notified by school officials in advance of such compliance. The school district may participate in an exchange of information with law enforcement and juvenile court officials to the extent permitted by FERPA.
G. To appropriate persons and agencies in connection with an emergency to protect the health or safety of the student or other persons.
H. To parents/guardians of an eligible student who claim the student as a dependent for income tax purposes.
I. Federal law allows the school district to release certain student directory information for legitimate education purposes. Directory information is defined as the student’s name, address, age, birthplace, participation in officially recognized school events and programs, weight of athletic team members, awards, diplomas, and photographs. Directory information shall not be released for commercial reasons or purposes. The actual residential addresses of participants in the state Address Confidentiality Program will not be available for release as directory information. (Procedure 3233)
J. A high school student may grant authority in writing to the district permitting prospective employers to review the student's transcript.
Record of Requests for Disclosure
The Walla Walla Public Schools will maintain a record of all requests for and/or disclosure of information from a student's records, excluding requests of school officials and requests for directory information. The record will indicate the name of the party making the request, any additional parties to whom it may be disclosed, and the legitimate interest the party had in requesting or obtaining the information. The record may be reviewed by the parent/guardians or eligible student. (See Access to Student Records section, p. 2)
Confidential Health Records
Confidential health records should be stored in a secure area accessible only to authorized staff, unless an appropriately executed release under Ch. 70.02 has been obtained. Such records are also covered by the Family Education Rights and Privacy Act, permitting parent access to review and otherwise exercise FERPA rights regarding the records. There is a higher standard of confidentiality and minor student’s rights of privacy for records pertaining to HIV, sexually transmitted diseases, drug or alcohol treatment, mental health treatment, family planning, or abortion. The releases for information regarding sexually transmitted diseases, HIV, and drug or alcohol treatment are more restrictive than ordinary medical releases. (Procedure 3414)
Correction of Student Records
Parents/guardians or eligible students have the right to ask to have records corrected that they believe are inaccurate, misleading, or in violation of their privacy rights. Following are the procedures for the correction of records:
A. Parents/guardians or the eligible student must ask the Walla Walla Public Schools to amend the record. In so doing, they should identify the part of the record they want changed and specify why they believe it is inaccurate, misleading, or in violation of the student's privacy or other rights.
B. The Walla Walla Public Schools may honor such requests or it may decide not to comply. If it decides not to comply, the district will notify the parents/guardians or eligible student of the decision and advise them of their right to a hearing to challenge the information believed to be inaccurate, misleading, or in violation of the student's rights.
C. Upon written request, the Walla Walla Public Schools will arrange for a hearing and notify the parents/guardians or eligible student, reasonably in advance, of the date, place, and time of the hearing. The hearing will be conducted by a hearing officer who is a disinterested party; however, the hearing officer may be an official of the district. The parents/guardians or eligible student will be afforded a full and fair opportunity to present evidence relevant to the issues raised in the original request to amend the student's records. The parents/guardians or student may be assisted by one or more individuals, including an attorney.
D. The Walla Walla Public Schools will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence presented and the reason for the decision.
E. If Walla Walla Public Schools decides that the challenged information is not inaccurate, misleading, or in violation of the student's right of privacy, it will notify the parents/ guardians or eligible student that they have a right to place in the record a statement commenting on the challenged information and/or a statement setting forth reasons for disagreeing with the decision.
F. The statement will be maintained as part of the student's records as long as the contested portion is maintained. If Walla Walla Public Schools discloses the contested portion of the record, it will also disclose the statement.
G. If based on the hearing the Walla Walla Public Schools decides that the information is inaccurate, misleading, or in violation of the student's right of privacy, it will amend the record and notify the parents/guardians or eligible student, in writing, that the record has been amended.
Maintenance of Student Records
The student's building principal, counselor, or teacher shall be the custodian of the cumulative folder. Authorized staff in the Special Programs Department shall be the custodians of the supplemental records. Principals and/or Special Program Department staff shall:
A. Maintain only those records authorized by these procedures.
B. Safeguard student records from unauthorized use and disposition.
C. Maintain access records.
D. Honor access requests for the parent/guardian or eligible student.
Disposition of Student Records
The permanent student record shall serve as the record of the student's school history and academic achievement. Permanent records filed in the student's cumulative folder are to be extracted and retained before disposition of the folder.
When a student transfers to another school in the district, all records including the permanent student record shall be transmitted to the other school. When a student transfers to a school outside of the district, the building principal, associate principal, assistant principal, dean of students, or designee shall purge the cumulative folder of all nonofficial, extraneous information. A copy of all records will be sent to the requesting school, unless the student has an outstanding fee or fine. In those instances the enrolling school shall be provided with information regarding the student’s academic performance, special placement, immunization history, attendance, history of violent behavior, violent offenses, sex offenses, inhaling toxic fumes, drug offenses, liquor violations, assault, kidnapping, harassment, stalking, arson, and discipline actions within two school days, and the records shall be sent as soon as possible. The official transcript shall be withheld until the fee or fine is discharged. The enrolling school district shall be notified that the transcript is being withheld due to an outstanding fee or fine.
The district will follow the current Secretary of State’s Records Management Manual and General Records Retention Schedules for School Districts for retention of student records.
At the time a student graduates from school or ceases to need special educational services, the parent/guardian or adult student shall be informed that record information regarding the disabling condition is no longer needed. When informing the parent/guardian or adult student about his/her rights regarding such records, the district shall advise the parent/guardian or adult student that the information may be needed by the student or the parent/guardian to establish eligibility for certain adult benefits, e.g., social security. At the parent's/guardian’s or adult student's request, the record information relating to the disabling condition shall be destroyed.
A parent/guardian or adult student, at his/her expense, may receive a copy of all records to be transmitted to another district.
Issued: September 2003