A Perspective on Student Records Management
Teresita Flores, J.D., is providing this month’s commentary on student records management practices. I would like to encourage others to provide guest commentaries on AACRAO research or other higher education related research of interest to the community. Please contact me if you are interested in contributing.
From my perspective, and in my experience, it is unnecessary to retain documents any longer than required by the governing law or regulation that applies to that document. In higher education institutions, there should be records retention schedules that are separated by the part of the business that is in question. One body of law applies to employment records retention; another governs financial records. Education records, as that term is meant in a FERPA context, present an entirely separate body of concerns. What unifies these documents is the importance of an existing body of established business practices for documents retention. I find it notable that your research revealed almost half (46%) do not purge any student records or only purge some records in accordance with the student records retention policy and/or schedule. This is a significant issue.
Unnecessary documents retention comes with a number of costs and risks. In a legal context, the problem with excessive documents retention is the risk of liability. Liability can show up in a variety of ways, further complicating matters. If an institution retains documents longer than required by the governing law or internal policy, then it becomes responsible for that decision. For example, if there is a public records request, the institution has an obligation to respond in a timely fashion. Excessive documents retention could hinder the institution’s ability to do that. Documents subject to subpoena must be produced, but only if they exist. If the institution has retained every document, including report or investigation drafts as well as completed final documents, all the documents that exist are required for production. If document destruction had occurred as allowed or as prescribed by law or policy, the document would not be available to produce as a matter of regular business practice. Responses to subpoenas must also be timely, and the institution runs into the same problem as under the request for public records. Absent ongoing litigation, if a document no longer serves a business or public purpose and the institution retains it past the time dictated by law and policy, the institution has literally decided to increase its costs and the risks associated with discovery of documents. The best practice is simple: Follow the law or regulation applicable to the type of business document in question, and definitely follow your own policies. To do otherwise invites significant risk of liability that could have been appropriately and lawfully avoided.
Teresita M. Flores, JD, SPHR
Dr. Flores is currently a consultant working with leaders and CEOs on compliance, training, investigations and HR. Formerly she was a higher education administrator responsible for legal affairs, human resources, EEO/AA/ADA, public records and copyright, and grants/contracts compliance.
AACRAO Research Insights
More than 1,000 institutions responded to the 60-Second Survey on Student Records Management Practices. The results are highlighted below and the full report is here.
- Nearly all (94%) of the responding institutions have a student records management schedule and/or policy.
- Nearly all (97%) identify the transcript as a permanent document.
- Almost three quarters (73%) of institutions with a policy and/or schedule use AACRAO guidelines as a student records management practice resource.
- More than half (59%) have a single records management document that covers both policy and the retention schedule.
- Document retention periods vary considerably among institutions.
- The institution’s SIS/ERP is identified as the official source of student records for fewer than half (46%) of respondents. Fifteen percent (15%) still identify paper as the official copy, and 19% identify the scanned paper copy as the official record..
- More than 8 in 10 (84%) retain more than one copy of a student record for all or at least some current student records..
- Almost half (46%) do not purge any student records or only purge some records in accordance with the student records management policy and/or schedule. .
- For most (71%) the office who “owns the record” is responsible for purging the records.
Upcoming AACRAO Research
The AACRAO research agenda for the next few months includes the following:
- A comprehensive undergraduate grading practices survey to update the data collected for the 2004 AACRAO book on the same subject
- A 60-Second survey on the availability of mentorship in the workplace and related topics
- Impact of the college completion agenda at community colleges
Current Higher Education Research and Related Topics
Encouraging a Sense of Belonging Improves Outcomes in MOOCS for Certain At-Risk Learners
In the October 2016 Eye on Research, I mentioned the lay-theory intervention that helped incoming freshmen overcome doubt that they have the means to succeed in college. Dr. Geoffrey L. Cohen, one of the authors of that study, has collaborated with others on a similar set of field experiments to improve success in MOOCS. Similar to the original study, the authors randomly assigned students from less-developed countries (LDCs) and more-developed countries (MDCs) enrolled in MOOCS in one of three conditions: “the value relevance affirmation, the social belonging intervention, or the control condition . . .” The interventions had a positive effect on persistence for students from LDCs but a negative effect on students from MDCs. The author’s look to prior research as an explanation for this difference.
CAPSEE White Paper - Estimating Returns to College Attainment: Comparing Survey and State Administrative Data-Based Estimates
Using recent data from the National Longitudinal Survey of Youth (1997) the authors of this CAPSEE white paper developed a new estimates of returns to college attainment and how college degree attainment relates to interstate mobility. They also discuss the advantages and disadvantages of using survey data versus state administrative data for estimating returns to college. Findings include:
- “relative to high school credentials only, there are substantial returns to bachelor’s and associate degree, as well as to enrollment in four-year colleges without obtaining a degree”
- There are “positive effects on other labor market outcomes including likelihood of employment, full-time, full-year employment, and earning an annual ‘living wage’”
- “four-year college enrollees and graduates are significantly more likely to work outside of their home state after college”
CAPSEE White Paper - How and Why Do Adjunct Instructors Affect Student’s Academic Outcomes? Evidence from Two-Year and Four-Year Colleges
The authors of this white paper used two statistical models to estimate the impact on student outcomes based on the type of instructor a student had at their initial exposure to a topic. The results suggest that introductory courses taught by adjuncts have a positive impact on introductory course grades. However, the opposite was found to be true for subsequent course enrollment and performance. Instructor demographics such as highest degree attainment, full-time employment and previous non-teaching working experience, can largely explain the estimated differences.
Coursera Maps Learning Regions Based on Online Course Topics
The image below was produced by Coursera. They used the relative popularity of their online courses to create topical interest regions.