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Big Sandy Community and Technical College

Institutional Assessment of Compliance

Self-Audit

COMPREHENSIVE STANDARD

3.9.2 The institution protects the security, confidentiality, and integrity of student records and maintains special security measures to protect and back up data. (Student records)

X Compliance   Partial Compliance   Non-Compliance

Narrative:

Big Sandy Community and Technical College (BSCTC) maintains the security, confidentiality and integrity of student records consistent with the guidelines set forth in the Kentucky Community and Technical College System (KCTCS) Administrative Policies and Procedures, Section 6.2, Educational Rights and Privacy Act [1] and with the Kentucky Council on Postsecondary Education (CPE) Comprehensive Database Guidelines [2]. As noted in Article 1.4.1 of the KCTCS Code of Student Conduct [3], "...records maintained by the college are available only to the student, to college personnel with legitimate educational interests, to other institutions where the student is seeking financial aid, and to authorized representatives of the Comptroller General of the U.S., the Secretary of HEW, or an administrative head of an education agency, in connection with an audit or evaluation of federally supported programs, and as provided by Section 164.283 of the Kentucky Revised Statute" [4].

The electronic information system used to provide controlled access to student records, PeopleSoft, is secure and complies with Business Procedure 1.5 described in the online KCTCS Business Procedures Manual [5]. As noted in Section 1.5.3.B [6] of this Manual, "The PeopleSoft database has a value-based user identification security feature that allows a user's access to be limited to only those functions that are necessary to perform a job for which access is required." The employee's job classification determines the level of security. Passwords are changed every ninety (90) days. An employee's access to PeopleSoft student records ends when employment ceases. Students may access their PeopleSoft records at any time, and their passwords must also be changed every ninety (90) days.

Servers for the PeopleSoft system are located in a secure off-site location managed by a third party professional database management service, Cedar Crestone Managed Services, Inc. Back-ups are completed nightly; each morning back-up logs are checked and any errors are documented and resolved. In addition, monthly back-ups are conducted when the system is offline. Random samplings of back-up tapes are tested semi-annually to ensure tape media is good and the restore process works as documented. A disaster recovery plan has been established and documented, in the Crestone Report on Controls in Operation and Test of Operating Effectiveness[7], that defines the roles, responsibilities, hardware, software, and time frames needed to ensure high availability and system redundancy. The disaster recovery procedure is tested at least annually, and actual results are compared with the expected outcome based on the procedures. Procedures are updated as needed after test results are analyzed. Procedures are audited periodically. The most recent audit covering January 21, 2006 through August 31, 2006, is provided as evidence of compliance that special security measures are in place to protect and back up data.

The security of student records is the responsibility of the registrar at BSCTC. Non-electronic records are secured in locked, fireproof filing cabinets in locked rooms in the Admissions area of the Prestonsburg, Pikeville, and Mayo campuses. Physical access to student records maintained on BSCTC campuses is granted to members of the student affairs unit.

BSCTC is compliant with the Federal Education Right to Privacy Act (FERPA) [8] in protecting the confidentiality of student information and records as defined by law. During new student orientation, all students are provided copies of FERPA documentation. Additionally, FERPA information is made available in the BSCTC Student Handbook [9], in both the BSCTC eCatalog (page 43) [10] and in the KCTCS 2006-2007 catalog (pages 54-56) [11], as well as on the BSCTC website [12].

Supporting Documentation:

Source

Location/Special Instructions

1

KCTCS Administrative Policies and Procedures, Section 6.2, Educational Rights and Privacy Act

http://www.kctcs.edu/employee/policies/volumeII/section6.cfm

2

Comprehensive Database Reporting Guidelines-State Supported Institutions 2006-2007

http://cpe.ky.gov/NR/rdonlyres/E2FC0AF8-FA87-4047-AD65-A19D58D9A207/0/PDFVersion200607.pdf

3

Kentucky Community and Technical College Code of Student Conduct, Article 1.4.1

http://www.kctcs.edu/student/studentcodeofconduct.pdf

4

Kentucky Revised Statutes 164.283 Student academic records confidential-exceptions

http://www.lrc.state.ky.us/KRS/164-00/283.PDF

5

KCTCS Business Procedures Manual 1.5

1.5_Request_a_PeopleSoft_System_User.pdf

6

KCTCS Business Procedures Manual 1.5.3.B

1.5_Request_a_PeopleSoft_System_User.pdf#page=2

7

Crestone Report on Controls in Operation and Test of Operating Effectiveness

3.9.2_7_Doc_Creststone_Manual.pdf

8

FERPA Orientation Document

http://www.ed.gov/print/policy/gen/guid/fpco/ferpa/index.html

9

BSCTC Student Handbook

http://www.bigsandy.kctcs.edu/admissions/docs/studenthandbook.pdf

10

BSCTC 2006/2007 eCatalog pg. 43

http://www.bigsandy.kctcs.edu/admissions/docs/catalogs/Catalog_2006_2007.pdf#page=43

11

KCTCS 2006/2007 Catalog pg. 56 Webpage "Student Records"

http://www.kctcs.edu/catalog/index.cfm?action=display&cs_id=6

12

BSCTC Webpage Current Students

http://www.bigsandy.kctcs.edu/current_students/index.html