Student Records Requirements Policy
The purpose of this policy is to determine procedures for the collection of student information and its storage, use, disclosure, transfer and protection. The legal framework for the development of this policy is provided by section 6.1 of the Independent School Act, Sections 9 and 10 of the Independent School Regulation, the Student Records Order (1 1/07) (the Order), and the Personal Information Protection Act (PIPA). Section 9(2) of the Regulation obliges independent school authorities to, subject to the requirements of the Order, (a) establish written procedures regarding the storage, retrieval and appropriate use of the student records, and (b) ensure confidentiality of the information contained in the student records and ensure privacy for students and their families.
1. Policy Statements
Gaglardi Academy will:
• Ensure that the Director/Principal is responsible for the establishment, security and maintenance of the Student Records and Student Files for each student registered in the school according to the procedures defined in this policy.
• Only collect, use or disclose personal information with the consent of the parent, legal guardian or individual student, unless otherwise authorized under PIPA.
• On or before collecting personal information, disclose to the parent, legal guardian or individual student, in writing, the purposes for the collection of personal information.
• Only collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances and that fulfill the purposes disclosed by the school or are otherwise permitted under PIPA.
• Secure Student Records and Student Files with access within the school authority restricted to those individuals who, by the nature of their work, are required to have access to the information.
• Provide access to personal information about an individual student to the parent, legal guardian or individual student (if capable of exercising PIPA rights), during school hours and under the supervision of the Director/principal or designate.
• Subject to legal requirements, ensure that personal information will be retained only for the period of time required to fulfill the purpose for which it was collected.
• Inform parents and legal guardians that concerns, complaints and questions about personal information handling policies and practices of Gaglardi Academy may be directed to the school's Director by calling the school office. 1
2. Definitions and Student Record Components
2.1 a) Elements of the Student Record:
• The Permanent Student Record (PSR), as defined in the Students Records Order (I 1/07):
a. Form 1704, PSB048 (revised 1997) completed according to the PSR instructions that are effective at the time of completion; and
b. Student Progress Reports for the two most recent years or an official transcript of grades;
• All documents listed as inclusions on Form 1704 (see below);
• Form A, verifying the information about the student's parent or guardian in respect of students eligible for funding (see Appendix I);
• A copy of the student's current Student Learning Plan (SLP), if any, and
• A copy of the student's current Individual Education Plan (IEP), if any.
2.2 Permanent Student Record (Form 1704) inclusions:
The following must be listed on Form 1704, including document date, title and expiry date or date rescinded (if applicable), and copies of the documents listed must be filed with the PSR:
• Health Services information as indicated by the medical alert check-box, such as diabetes, epilepsy, anaphylaxis producing allergies, and any other condition which may require emergency care;
• Court orders as indicated by the legal alert check-box;
• Other legal documents, eg name change or immigration document;
• Support services information (eg psychometric testing, speech and hearing tests, adjudication requirements for completing assessment activities);
• Current IEP and/or Case Management Plan (CMP) where applicable; and
• Notification of a student being home schooled.
The following inclusions may be listed on PSR Form 1704, including document date, title and expiry date or date rescinded (if applicable) and if listed, copies of the documents must be filed with the PSR:
• Records of information which an educator deems relevant and important to the educational program of the student;
• Award information; and
• Standardized test scores (if deemed relevant and important to the educational program of the student).
If the above optional inclusions are NOT listed on PSR Form 1704, then they may be included in the Student file.
2.3 Student File
I) Resident Students
The following items must be included in the school's student records as part of the Student File. These items include:
• Legal name of child – verify the original and file a photocopy or scanned copy of birth certificate or similar legitimate identification documents;
• Official name(s) of parent(s) or guardian(s) with home and work contact information; and
• Verification that parent/guardian is legally admitted to Canada and a resident of BC.
• Care Card number
• Emergency contact numbers
• An eligible individual who have permission to pick-up children from school.
• Doctor's name and contact information
• The two most recent years of Student Progress Reports
II) International Students
The following items must be included in the school's student records as part of the International Student File. These items include:
• Legal name of child – verify the original and file a photocopy or scanned copy of international passport;
• Official name(s) of parent(s) or guardian(s) with home/work contact and email information; and
• A copy of a valid student visa non-expiring within 3 months to end of school year or term of stay.
• Signed and notarized Custodian Declaration forms for Homestay Coordinator.
• Evidence that students have appropriate medical coverage during time in-country.
• Home stay contacts including names, phone numbers and email addresses.
• Emergency contact numbers for home-stay families.
• Signed International Application forms.
• Signed PIPA consent forms.
• Signed Code of Conduct.
• International Transcript from last grade attended.
• The two most recent years of Student Progress Reports.
The following items may be included in the school's student records as part of the Student File. These items include:
• Additional Student Progress Reports
• Serious discipline reports (MyEdBC)
• Reports of serious meetings with parents/guardians (MyEdBC)
• Standardized test scores
2.4 Sensitive Student Information. This may include information which by its nature requires that school staff observe a high level of confidentiality. Examples include:
• Psychiatric or OT reports;
• Family assessments
• Referrals to or reports from school arranged counseling services; or
• Record of a school-initiated report of alleged sexual or physical abuse made to a child protection social worker under section 14 of the Child, Family and Community Service Act.
3.1 The school's Administrative Assistant will be responsible for:
• Updating the PSR Form 1704 as information changes and the student progresses through the educational system;
• Ensuring that electronic copies of documents are stored on a server in a physically secure location. If information is accessed through the internet, an encrypted connection (https://) must be established before authenticating. Access is restricted to those employees who, by nature of their work, are required to have access; and
• Ensuring that Gaglardi Academy takes necessary precautions to safeguard against deprecated or obsolete forms of storage. The electronic storage of PSRs and other personal information requires the school authority to have an adequate backup plan and recovery strategy for potential hardware failure and database corruption.
3.2 Student Record and File Retention:
i) Student Records – Active Students – Domestic & International
• Student Records are locked in a fireproof cabinet. Access is restricted to those employees who, by nature of their work, are required to have access.
• Gaglardi Academy protects personal information from unauthorized access, collection, use, disclosure, copying, modification, or disposal, or similar risks.
• The Director/principal or designate will regularly review Student Records to ensure that the information is current and complies with legal requirement (see 2.3 above).
ii) Student Records – Inactive Students – Domestic & International
• Unless another school requests a Student Record, Gaglardi Academy will archive Student Records for 55 years after a student has withdrawn and not enrolled in another K-12 school or graduated from the school.
• The archived Student Records are stored securely and in a manner that ensures their preservation from flood or fire etc. Access is limited to Director/principal or the school Administrative Assistant.
• The school Administrative Assistance keeps a record of Student Records that are shredded after 55 years.
3.3 Currency of Student Records
• Student eligibility information will be updated during student registration each year.
• The Director/principal or designate will regularly review student files to ensure that the information is relevant and important to the educational program of the student.
3.4 Security of Student Information off-campus
• The Director/principal or designate is responsible for ensuring that personal information taken off campus is safely stored and that personal information is protected.
3.5 Handling of Sensitive Student Information
• Access to sensitive student information is restricted to the Director/Principal, Head Teacher or a person or persons authorized by the Director/Principal to access such information define in Section 2.4 of this policy.
• The Director/principal or designate will obtain written parental consent for the collection, use and disclosure of sensitive student information, including psychiatric reports and family assessments, and will store these as highly confidential documents with restricted access.
• Sensitive student information will only be disclosed or transferred in accordance with the law.
• The Director/principal is responsible for ensuring that school initiated reports under section 14 of the Child, Family and Community Service Act are retained only for the purpose of child protection proceedings and that information is not disclosed to third parties or transferred to other school. Such reports are strictly confidential and should only be stored where the Director or designate can access them.
4. Use of Student Personal Information
Gaglardi Academy may use an individual student's personal information for the following purposes, assuming that the school has disclosed such purposes to the parent/guardian or individual student verbally or in writing on or before collecting the personal information.
4.1 To communicate with the student and/or the student's parent or legal guardian, to process a student's application, and to provide a student with the educational services and co-curricular programs provided by the Gaglardi Academy.
4.2 To enable Gaglardi Academy to operate its administrative function, including payment of fees and maintenance of ancillary school programs such as parent voluntary groups and fund-raising activities.
4.3 To provide specialized services in areas of health, psychological or legal support, or as adjunct information in delivering educational services that are in the best interests of the students.
5. Access to and Disclosure of Student Records
• A student (capable of exercising PIPA rights) and a parent/legal guardian of a student is permitted (unless restricted by court order) to:
• Examine the Student Record and Student File kept by Gaglardi Academy pertaining to that student, while accompanied by the Director or designate to interpret the records; and
• Receive a copy of any student record upon request. Gaglardi Academy reserves the right to recover the direct cost of copying records.
An entitled person may access and verify personal information in the Student Record and Student file pertaining to the particular student with appropriate notice to the school administration. Access will be provided during school hours.
• Access to a Student Record or Student File will only be granted, upon assurance of confidentiality (with consent), to professionals who are planning for or delivering education, health, social or other support services to that student. Consent will be obtained in writing, listing the name and date of birth of the student, the name and signature of the parent/legal guardian, and the date of the request.
• When applicable, graduating students will be provided with interim and/or final transcripts for Grades 10, 11 and 12 courses when graduating, and upon future request of the graduate. Copies will be mailed directly to institutions of higher learning or as requested by the graduate. Gaglardi Academy reserves the right to assess a reasonable fee for transcript requests.
• In the case of a request for personal student information from separated or divorced parents, Gaglardi Academy will be guided by the legal custody agreement, a copy of which should be provided to the Director/Principal at time of student registration. In cases where the Director/principal is unsure if the non-custodial parent is entitled to access personal student information, the school's legal counsel will be consulted for a decision.
6. Transfer of Student Records
• On receipt of a request for student records from a school, a Board of Education, or an independent school authority from within B.C. Where the student is (or will be) enrolled, Gaglardi Academy will transfer the students PSR, the current Student Learning Plan, and the current IEP to the requesting institution. Gaglardi Academy will retain a copy of the PSR, indicating the school where the records have been sent and the date of the student record transfer.
• If the requesting institution is outside B.C., a photocopy of the PSR will be sent, along with the current Student Learning Plan, and the current IEP to the requesting institution.
• Requests for a student's record from a public school require that the public school administration provide a photocopy of the PSR and current Student Learning Plan, and the current IEP to Gaglardi Academy. The original PSR must be retained by the public school.
• Gaglardi Academy will only transfer sensitive information after dated and signed parent/guardian consent has been obtained.
• Gaglardi Academy will not transfer a record of a Section 14 Child, Family and Community Service Act report of alleged sexual or physical abuse made to a child protection social worker.
• A summary of a former student's school progress may be provided to prospective employers, at the written request of a former student. Gaglardi Academy reserves the right to assess a fee for this service.
• A Student Record will be reviewed when a student transfers. The Director/principal will ensure that the documents listed as inclusions are still required inclusions (ie not expired or rescinded) or still deemed to be relevant and important to the educational program of the student. Expired, rescinded, or irrelevant inclusions will be removed from the Student Record and the documents themselves will be shredded.
This policy is taken directly, with updates, from the FISA Student Records Requirements and Best Practices Policy, March 2013.
Updated for International Students, September 2015.