2021 Academic Communication and Protecting Student Privacy Policy

Purpose & Scope

Purpose and Scope

The University community is required by FERPA to protect students' educational records, which include: files, documents, and materials in whatever medium, including those posted on the Internet, that contain information directly related to students and from which students can be personally identified. The University provides faculty, students, and staff with a learning management system, university email, and other software tools to promote communication and learning in a protected environment. These should be the software tools of choice for all course-related electronic network communication.

The purpose of this policy is to protect the privacy of students enrolled in USA distance and correspondence courses or programs and assure compliance with the Family Educational Rights and Privacy Act (FERPA) concerning controlling access to confidential student information. In addition, this policy is intended to explain the use and control of information gathered through the University’s learning management system and related educational software. All credit-bearing courses and programs offered through distance learning methods must not permit access to nor release of any confidential student information to any third parties without written consent of the student other than the following:

University of South Alabama officials and staff who have legitimate educational interests.
Officials of other schools to which a student has applied or plans to enroll.
Federal, state, or local officials as defined by the law.
Accrediting organizations when conducting accrediting functions.
Parents of a dependent student (according to the Internal Revenue Service code).
The courts, in compliance with a subpoena or judicial order, once the University has made a reasonable effort to contact the student.
Appropriate emergency contacts as defined by the student if the requested information is necessary to protect the safety or health of the student or other individuals.
Appropriate external parties, such as law enforcement agencies, in order to investigate and respond to suspected violations of law or University policy. Any such disclosures shall comply with all applicable laws and University policies.

FERPA & Distance Education

FERPA and Distance Education

Electronic student submissions should not be accessible to anyone other than the student and the University employee who needs the electronic submission to carry out his/her duties. This group of employees would usually include the instructor, administrators or staff approved by the Office of Academic Affairs or College Dean, and learning management system or e-learning administrators. For student work to become available to a third party, the student must give permission through a written, signed consent. The consent is voluntary, and a student may decline. If a student declines to give consent, the student cannot be denied any academic opportunity or privilege, or suffer any adverse consequences as a result. Note: If students are trading documents or projects for peer review, FERPA does not apply until the work is collected and recorded by the instructor.

Student Threaded Discussions or Forum Postings

Written consent to display student identity is not necessary for threaded discussions or forums if:

Students perform the posting (not instructors)
Electronic submissions do not contain grading or evaluative comments of a professor
Students are notified in advance before or during enrollment that posting of their work is a course requirement.
Submitted work is not available to anyone outside of the class members and faculty.

Sites Outside of University Systems

When course content dictates that the instructor supplement the University standard software tools, faculty members are required to exhibit due diligence to ensure that the selected supplemental software tools protect students' privacy consistent with FERPA guidelines. Access by anyone outside the course must be in accordance with FERPA guidelines.

If an instructor requests or requires students to post to websites or social networking sites outside of the University (e.g., for interaction with the wider community), FERPA protections for that information as to third parties cannot be assured because the material is not on a University-controlled website. However, instructors should communicate the issues, conditions, and risks associated with any postings that will be publicly available on the Internet at the beginning of the academic term, preferably in the syllabus. Instructors should never post student grades, schedules, student ID numbers or Social Security numbers, or other personally identifiable information. Likewise, instructors should remind students to be careful about posting personal information (schedules, real names, etc.) about their classmates.

Recommended Resources

Recommended Resources

University Attorney Guidance office on Zoom recording of class sessions

1 - A syllabus statement about class sessions being recorded and the potential uses for the recording ("used for educational purposes for those enrolled in this course section") is recommended.

2 - It is appropriate to notify students that they should not share the recordings outside of their intended purpose.

3 - As far as using the recorded lectures in future semesters, it is not recommended to use recordings with student discussions in them.

One other thing : Students may make requests not to be recorded based upon religious grounds, and we would need to address those through the interactive process if they are presented. [This means those would be treated on a case by case basis]

Plagiarism Detection Software

University faculty may use or require the use of software intended to deter plagiarism or provide review by instructors or peers. The University presently contracts with Turnitin.com software for these purposes.

Secure Credentials

The J-number (student ID) is not a secure credential and may be displayed in some identity badges, software systems, etc. The password used to enter the system IS a secure credential. Access passwords may not be shared nor given for any reason to anyone other than the user to whom they were assigned.

Other Information Regarding Student Privacy

The USA Registrar’s Office (http://www.southalabama.edu/registrar/) has additional important information regarding student privacy, non-disclosure of student records, and FERPA.

USAonline Data Collection

When users access USA Online, the web server automatically collects certain technical information from their computers and about the users’ connections including: Internet protocol (IP) address, date, time, browser type, referring web site address, and hostname (including domain). With regard to the application, USAonline collects user-specific information about which pages are accessed and approximates the duration of visit. This information is used to analyze traffic, diagnose problems with USAonline computer systems, plan the use of system capacity, improve the quality of the information and services available to users in the application, help manage the site and improve service generally, and customize the services offered to users.

The statistics functions of the USAonline site provide data to faculty course owners to gauge student participation in their course-related activities. In the future and consistent with the requirements of FERPA, aggregate data may also be provided to academic and institutional researchers to facilitate scholarly and institutional research. USAonline receives a certain amount of personal information from other sources at the University and maintains it for use in the application, including but not necessarily limited to: name, email address, J-number, and class enrollment information.

Voluntary User Information

USAonline may collect information directly from the user, including but not limited to: telephone number, address, photographs, IM screen names, interests, blog posts, and discussions. While USAonline does not generally require this information, mandatory completion or entry may be at an instructor’s discretion.

Cookies

A cookie is a small data file that is written to a user’s hard drive that contains information about a visit to a web page. USAonline uses cookies to store information about a user’s actions or choices on pages associated with the application. Users may set their browser to prompt before accepting new cookies. If cookies are disabled, USAonline will not operate properly.

Security

Due to the rapidly evolving nature of information technologies, no transmission of data over the Internet can be guaranteed to be completely secure. While USAonline is committed to protecting the privacy of its users, it cannot guarantee the security of any information transmitted through University web sites. However, once information is received, USAonline will use reasonable safeguards consistent with prevailing industry standards and commensurate with the sensitivity of the data being stored to maintain the security of that information on our systems. In addition, USAonline will comply with all applicable federal, state, and local laws regarding the privacy and security of user information.

Third Party Hosting

Personal information collected on this website is not disclosed to third parties unless the third party is an institutionally-authorized provider of services to the University. Users of these services are subject to the privacy policies established by the third-party provider. In addition, the University of South Alabama and USAonline will comply with all local and federal laws regarding privacy and security information.

Compliance

In accordance with the responsibilities outlined above, Deans and Directors of University and College-level units are expected to ensure that all faculty and staff within their units remain in compliance with this policy.

Frequency of Review and Update

This policy will be reviewed annually by the Office of Academic Affairs for continued alignment with the applicable federal and state laws, regulations and policies and revised as necessary.