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Columbus State University

Guidance Regarding Protection of Students’ Education Records/PII

The move by the University System of Georgia to a 100% online instructional environment due to COVID-19 presents many challenges, one of which is the protection of our students’ personally identifiable information (PII) (student information not defined as directory information by CSU) under the Federal Educational Rights and Privacy Act, otherwise known as FERPA.

Individuals motivated by ill intent have sought to take advantage of the current crisis. Indeed, the FBI recently issued guidance warning educational institutions to take appropriate precautions to avoid the recent spate of virtual teleconferencing platforms like Zoom from being hijacked. Accordingly, the university issues the following guidelines to ensure our students’ education records, and the PII contained therein, are protected:

  1. Specific Guidelines Regarding Use of Virtual Teleconferences (VTCs) to Conduct Classes
    • VTCs continue to be an authorized means of communications between faculty and staff for instruction, advice, and counsel, provided the following guidelines are followed:
      1. Use of a CSU email addresses is required to conduct VTCs; use of personal email addresses is forbidden;
      2. Use of a meeting password for participants to gain access to the VTC is required;
      3. Disable screen sharing by anyone other than the VTC host;
      4. Sharing of a link to a VTC via an unrestricted, publicly available social media post is prohibited. Links to a VTC must be provided directly to participants;
      5. Ensure use of the latest, updated version of the VTC platform;
      6. VTCs should be conducted in an area not readily accessible to family or guests; and
      7. Non-students should not participate due to the likelihood that PII will be shared.
  2. General Guidelines Regarding Protection of Students’ Education Records/PII
    • Employees providing instruction, advice, or counsel to students as a part of their official duties as a CSU employee are allowed to take and maintain education records at home, provided the employee takes reasonable steps to ensure such records are not disclosed to third parties. Reasonable steps include:
      1. Following the above-noted VTC guidelines when providing instruction, advice or counsel to students;
      2. Logging off electronic devices that contain or have access to education records;
      3. Using online learning tools and apps that have been approved by CSU; and
      4. Ensuring education records are located in a secure place at an employee's home where they are not readily accessible/visible to family and invited guests.

For a deeper dive into FERPA and its requirements to maintain the confidentiality and security of student educational records, please click here for link to Department of Education’s guidance document on FERPA and Virtual Learning (PDF).