Reinhardt University SACSCOC Compliance Certification
Comprehensive Standards - Student Affairs and Services
|3.9||Student Affairs & Services|
|Part 1||Signature Attesting Integrity|
|Part 2||Substantive Changes|
|Part 4||Inst. Summary Form|
|3.9.2 Student Records
The institution protects the security, confidentiality, and integrity of student records and maintains special security measures to protect and back up data. (Student records)
Reinhardt University protects the security, confidentiality, and integrity of all records containing personally identifiable information (including student records) and maintains special security measures to protect and back up data.
Reinhardt University’s policy mandates compliance with the Family Educational Rights and Privacy Act (FERPA). The policy is published in the Student Handbook , the Undergraduate Academic Catalog , the Graduate Catalog , and the Faculty Handbook.  This policy defines the term “education records,” specifies who has, or can have, access to the records, and what can be disclosed from a student’s record and to whom. Reinhardt defines a student record as any medium containing information related to a student that is maintained by the University or by a party acting on behalf of the University.
Students are advised of their rights and are informed of the potential need to waive confidentiality in limited circumstances, such as requesting a letter of recommendation from a faculty member.  In addition, parents are provided information about the regulations on student records.
The Reinhardt faculty and staff are educated about this policy and other information security issues. The Registrar's Office has developed a FERPA Guide for faculty, staff, and student workers, which is used to train employees and student workers.  Part of the new faculty orientation includes explanation of the FERPA terms by the Human Resources Office. In addition, professional and student staff members who handle student records are provided initial training by their supervisor and are reminded regularly of the importance of maintaining confidentiality related to student records. All staff members are responsible for the security of files, including proper filing methods, not removing files from the central office or area offices, and maintaining security protocols designated for each area related to access.
All student records and applicant records including but not limited to academic records, counseling records and disciplinary records are confidential. Directory information may be released without the consent of the students involved unless the student has completed that information not be disclosed. Directory Information may be released to parties with a legitimate interest in the information.  Parents or guardians of dependent students will be notified in cases of emergency. Parents may be informed about drug or alcohol related violations by underage dependent students.
Student records are defined as records created to assist the offices of Admissions, Financial Aid, Student Life, Academic Affairs, Institutional Research, and the Registrar. Permanent records are defined as those kept in perpetuity, such as the original admission application and the academic and labor transcripts. Paper files are maintained in locked cabinets in the appropriate offices, and student information databases are password protected.
The University stores and maintains a host of student records including, but not limited to:
Jenzabar and EagleWeb
Reinhardt University utilizes Jenzabar as its electronic student information system which allows authorized users to share real-time student information across departments. Jenzabar is a password-protected administrative platform, with access restricted by level based on designated role. Each user has his or her own unique user name and password.
EagleWeb is the web-based campus portal which integrates seamlessly with Jenzabar. EagleWeb is available to applicants, students, former students, staff, faculty, and other authorized users. Each authorized EagleWeb user has his or her own unique user name and password with access based upon their designated role. Additionally, guests are able to access limited information within EagleWeb (i.e., course schedules) without requiring a username or password.
The Jenzabar database and EagleWeb servers are backed up on a daily basis by Information Technology personnel using proprietary software. Backup tapes are stored at an off-site storage location which is located in the vault in the bank building owned by the University across the street from the main campus. Jenzabar and EagleWeb data is protected from intrusion by multiple firewalls as well as physical and logical access restrictions. Employee access to Jenzabar and EagleWeb data is granted based on the employee’s job responsibilities. Access is authorized by the employee’s supervisor, the team leader for the specific area (Student Financial Aid, Human Resources, etc.), and Information Technology personnel. Completed authorization documentation for employees is maintained by the Office of Information Technology.  The Office of Information Technology also maintains a record of access level provided to each new employee.
The Registrar’s Office maintains student records including documents that support the student's enrollment and academic record. The Office of the Registrar follows the American Association of Collegiate Registrars and Admissions Officers (AACRAO) guidelines regarding security and retention of student records.  Student files are maintained in file cabinets separated from the student access area in the Registrar’s Office. Storage of all academic student records is maintained behind doors with lock cores and access to these records is limited to the Registrar’s Office staff and Public Safety Officers only. All student workers within the Registrar's Office complete FERPA training and sign a FERPA confidentiality form. 
Residence Life Records
The Office of Residence Life maintains an electronic database for all housing applications, contracts and assignment information in EagleWeb (i.e. Jenzabar). In addition, Residence Life maintains a physical file for each residential student that contains any written correspondence with the student and standard Housing forms, such as room condition reports and lockout cards. These records are stored centrally in the Residence Life Office. Access to these records is limited to the Residence Life staff and to student assistants working in the office. All student workers within the Office of Residence Life complete FERPA training and sign a FERPA confidentiality form. 
Student Health Services Records
The Student Health Center maintains medical records of currently enrolled students as well as the records for up to 5 years after the student is no longer enrolled. Patient medical records and all clinical information relevant to the care of a patient are readily available to health-care practitioners, who observe established protocols for maintaining patient confidentiality. In accordance with the Privacy of Medical Records Policy, patient information is not revealed to other University personnel without the informed consent of the patient, except in cases of extreme urgency where there is an obvious “need to know.”  Health information required as a condition of matriculation is included as part of a student’s health record. For medical information to be released, a Medical Release Form  must be completed and on file for the transfer of any records to “other healthcare professionals.” The health records are currently all paper charts and stored in locked cabinets within the locked Student Health Center (standard “double-locked” system).
Counseling Services Records
Client records and all clinical information relevant to the care of a client are readily available to health-care practitioners, who observe established protocols for maintaining client confidentiality. Necessary information is shared between Counseling staff and Health Service staff to assure continuity of care and to protect the health and safety of the client involved. All contacts at the Counseling office are strictly confidential.  Patient information is not revealed to any other University personnel without the informed consent of the patient, except in cases of extreme urgency where there is an obvious “need to know.” The counseling records are paper charts stored in a locked cabinet in the locked counseling office (standard “double-locked” system).
Judicial and Discipline Records
The Division of Student Affairs maintains all student judicial and disciplinary records. Records are maintained for seven (7) years in a locked file cabinet that is located in a copy room that is also locked during non-business hours on the 3rd floor of the Hasty Student Life Center. The floor is also secured during non-business hours. Access to these records is limited to Residence Life staff and administrative support staff in Student Affairs. See policies regarding judicial and disciplinary records. [14, 15]
The Athletic Department maintains student records including documents that support student-athlete eligibility and financial support (scholarship, letter of intent and eligibility clearance forms), injury, treatment, drug testing, and other information related to the health and well-being of Reinhardt student-athletes. All records are centrally kept in a locked file cabinet in the offices of the Director of Athletics and the Head Athletic Trainers. Access to these records is limited to the Athletic Department Staff.
Financial Aid Records
Financial aid administrators collect student and parent data. This data includes information from the Free Application for Federal Student Aid (FAFSA), as well as information from other sources, such as tax returns, social security numbers, names of household members, citizenship information, professional judgment documents, student progress data, and other private sensitive information. This data is stored in PowerFAIDS and in a student file. The student file is kept in locked cabinets for up to seven years after the last semester attended.
Business Office Records
The Business Office maintains student billing, payment and disbursement records electronically within Jenzabar EX. Students can access their statements through EagleWeb using their unique username and password. Paper copies of promissory notes containing confidential information are secured in a locked cabinet within the Business Office where access is restricted to Business Office staff. From time to time, the Business Office must print student account statements containing financial information about a student. Those statements are either shredded, mailed directly to the student’s address of record or attached as source documents for disbursements or adjusting transactions within Jenzabar EX. Statements used as source documents are filed and kept secured within the Business Office. Access to those files is restricted to Business Office staff.
The Office of Admissions maintains electronic records for all inquiries through Jenzabar Recruitment Manager (JRM). JRM is cloud-based, built on the SalesForce platform and follows SalesForce guidelines for access and security. Each user has a unique log-in and field and user security levels are set by the JRM administrators – the Director and Assistant Director of Admissions. Electronic records for applicants are stored in both JRM and Jenzabar EX. This information is shared with the offices of the Registrar, Student Financial Aid, and Orientation as well as the School Deans on a need-to-know basis. Additionally, the Admissions Office maintains paper files for applicants that are stored in a locked file cabinet in the Admissions House. Once a student has enrolled at Reinhardt, paper files and maintenance of Jenzabar EX records are transitioned to the Registrar’s Office. Records of non-enrolled applicants are stored for three years and then shredded. All student workers within the Office of Admissions complete FERPA training and sign a FERPA confidentiality form. 
Student Records at Other Instructional Sites and the RU Online programs
The policies and procedures noted above apply consistently to all instructional sites and RU Online programs. Faculty and staff teaching in these programs follow the same procedures with respect to security, confidentiality, and integrity of student records. No official student records are maintained at other locations. In addition, faculty teaching in online programs are required to sign a contract for each class they teach. Within the contract there is a section that specifically addresses policies and procedures for protecting the privacy of students enrolled in online and hybrid courses. For students enrolled in courses leading to Basic Peace Officer Certification, the program follows the same procedures required of other programs at the University.
The confidentiality of student records is one of the University's highest priorities. The University takes appropriate precautions through its policies, procedures, and practices to protect the security, confidentiality, and integrity of student records and to protect and back up data. Thus through clear policies and procedures and dissemination of those policies and procedures to ensure adherence, the University meets and demonstrates its compliance with Comprehensive Standard 3.9.2 (Student Records).