V.Students†††† ††††††††††††††††††††††† ††††††††††† ††††††††††† ††††††††††††††††††††††††††††††††††††††††††††† (formerly #5122)


††††††††††† A.Administrative Policies


††††††††††††††††††††††† 10.Use and Display of Student Social Security Numbers


††††††††††††††††††††††††††††††††††† a.Confidentiality


Appropriate records of attendance, evaluation, suspensions, or withdrawal shall be maintained for each child, kept in a protected location, and treated in a confidential manner.Parents shall be informed by typewritten notice in their spoken language, unless clearly not feasible to do so, of all Rights and Privacy Act of 1975 regarding the collection, maintenance, use, or destruction of any personally identifiable information related to their child which are as follows:


Access Rights -- The Narragansett School System shall:


††††††††††† 1.†††††††† Permit parents to inspect and review any education records* relating to their child which are collected, maintained, or used by such agency.


††††††††††† 2.†††††††† Comply with any parent request to inspect and review with their childís education records without unnecessary delay and before any meeting regarding an individualized education program or hearing relating to the identification, evaluation, or placement of the child, and in no case more than 14 calendar days per Regulation Revisions 4.1.2, after the request has been made.


††††††††††† 3.†††††††† Respond to parent requests for explanations and interpretations of their childís records.


††††††††††† 4.†††††††† Provide parents with copies of their childís records if failure to provide such copies would effectively prevent the parent from exercising the right to inspect and review their childís records.


††††††††††† 5.†††††††† Allow a parentís representative to inspect and review the records of their child.


††††††††††† 6.†††††††† Presume that the parent has authority to inspect and review records relating to his or her child unless the Narragansett School System has been advised that the parent does not have the authority under applicable State Law governing such matters as guardianship, separation, and divorce.




*Education records means those records, files, documents, and other materials which (1) contain information directly related to the student, and (2) are maintained by an educational

agency or institution, or by a person for such agency of institution.


Record of Access -- The Narragansett School System will keep a record of persons obtaining access to education records collected, maintained, or used under this part (except access by parents and authorized employees of the Narragansett School System) including the name of the person(s), the date access was given, and the purpose for which the person is authorized to use the records.


Records on More Than One Child -- If any education record includes information on more than one child, the parents of those children shall have the right to inspect and review only the information relating to their child or to be informed of that specific information.


Lists of Types and Locations of Information -- The Narragansett School System shall provide parents, on request, a list of the types and locations of education records collected, maintained, or used.


Fees -- The Narragansett School System:


††††††††††† 1.†††††††† May charge a fee for copies of records which are made for parents if the fee does not effectively prevent the parents from exercising their right to inspect and review those records.In no event may fees exceed the actual cost of copies.


††††††††††† 2.†††††††† May not charge a fee to search for, or to retrieve, information.


Amendment of Records at Parentís Request


††††††††††† 1.†††††††† A parent who believes that information in education records collected, maintained, or used is inaccurate or misleading or violates the privacy or other rights of the child, may request that the Narragansett School System, which maintains the information, to amend such information.


††††††††††† 2.†††††††† The Narragansett School System shall decide whether to amend the information in accordance with the request, it shall inform the parent of the refusal, and advise the parent of the right to a hearing in accordance with the provisions of Section One, IX-6.0 of the Regulations of the Board of Regents Governing the Special Education of Handicapped Children.The Narragansett School System shall, on request, provide an opportunity for a hearing to challenge information in education and evaluation records to ensure that it is not inaccurate, misleading, or otherwise in violation of the privacy or other rights of the child.


Results of Hearing -- If as a result of the hearing it is decided that:


††††††††††† 1.†††††††† The information is inaccurate, misleading, or otherwise in violation of the privacy or other rights of the child, the information shall be amended accordingly and the parents will be so informed.


††††††††††† 2.†††††††† The information is not inaccurate, misleading, or otherwise in violation of the privacy or other rights of the child, the parents shall be informed of the right to place in the records relating to their child a statement commenting on the information or setting forth any reasons for disagreeing with the decision rendered in the hearing.


††††††††††† 3.†††††††† The information is correct, then any explanation or statement placed in the records must:


††††††††††††††††††††††† a.†††††††† Be maintained by the Narragansett School System as part of the childís record as long as such records or contested portion is maintained by that agency.


††††††††††††††††††††††† b.†††††††† If the records of the child or contested portion is disclosed to any party, the explanation must also be disclosed to such party.


Consent* -- Parental consent must be obtained before personally identifiable information** is:


††††††††††† 1.†††††††† Disclosed to anyone other than officials of the Narragansett School System collecting or using such information.




*Consent means that the parent has been fully informed of all information relevant to the††

††† activity for which consent is sought, in his or her native language, or other mode of

††† communication.The parent understands and agrees in writing to the carrying out of the

††† activity for which his or her consent is sought, and the consent describes that activity and

††† lists the records (if any) which will be released and to whom; and the parent understands that

††† the granting is voluntary on the part of the parent and may be revoked at any time.


**Personally identifiable means that information that includes:

††† (a)††† The name of the child, childís parent, or other family member.

††† (b)††† The address of the child.

††† (c)††† A personal identifier, such as the childís social security number or studentís number; or

††† (d)††† A list of personal characteristics or other information which would make it possible to

††††††††††† identify the child with reasonable certainty.



††††††††††† 2.†††††††† Used for any purpose other than meeting a requirement under this section.


††††††††††† 3.†††††††† The Narragansett School System, subject to the Family Education Rights and Privacy Act, may not release information from education records to participating agencies without parental consent unless authorized to do so under the Family Education Rights and Privacy Act.*


Safeguards -- The Narragansett School System shall:


††††††††††† 1.†††††††† Protect the confidentiality of personally identifiable information at collection, storage, disclosure, and destruction stages.


††††††††††† 2.†††††††† Designate one official who shall assume responsibility for insuring the confidentiality of any personally identifiable information.


††††††††††† 3.†††††††† Provide training and instruction regarding Federal and State policies, procedures, rules, and regulations under the Family Educational Rights and Privacy Act of 1974 to all persons involved in the collecting or using of personally identifiable information.


Destruction of Information -- The Narragansett School System shall:


††††††††††† 1.†††††††† Inform parents when personally identifiable information collected, maintained, or used is no longer needed to provide educational services to the child.


††††††††††† 2.†††††††† Destroy personally identifiable information relating to a child when requested to do so by the parents of that child (parents of handicapped children must be informed that such records may be needed for social security benefits).However, a permanent record of a studentís name, address, and phone number, his or her grades, attendance record, classes attended, grade level completed, and years completed, may be maintained without time limitations.




*Federal Law and Regulation [Section 438 (b) of the General Provisions Act and Part 99 of the

Code of Federal Regulations] permits state and educational authorities to have access to student

or other records which may be necessary in connection with the audit and evaluation of federally

supported education programs or in connection with the enforcement of the federal legal

requirements which relate to such program.In these instances, it is not necessary that written

consent be obtained from parents.


Childrenís Rights -- Children who attain the chronological age of eighteen shall be afforded the rights of privacy similar to those afforded to adults unless otherwise specified by an adjudication process.



Adopted:††††††††† December 11, 1974

Amended:†††††††† January, 1980

Amended:†††††††† December 9, 1987†††††††††††††††††††††††††††††††††††††††††††††††††††††† Narragansett School System

Revised:†††††††††† September 19, 1990†††††††††††††††††††††††††††††††††††††††††††††††††††† Narragansett, Rhode Island