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Official Student Records Policy

Official Student Records Policy

Approval Date: February 2021
Effective Date: February 3, 2021
Date Reviewed: June 2020
Replaces: Confidentiality of Student Records 2010

Purpose

To manage and protect the Personal Information of Students as found in the Official Student Records of Cambrian College (‘the College’).

Scope

All College Students and Applicants

Definitions

Applicant: an individual who makes a formal application for a program offered at the College.

Applicant Record: information submitted in support of an application to a program at the College. Includes (but not limited to): name, contact information, citizenship and immigration documents, and applicable secondary or post-secondary transcripts.

Acadstrongic Record: refers to the student acadstrongic history including courses enrolled in, credentials earned, enrolment history and final grades earned for all courses.

Financial Record: refers to the Student’s financial account, containing all financial transactions with the College, including charges, payments, sponsorships, and financial assistance provided.

Personal Information: refers to information about the student or another identifiable individual required in the administration of the Official Student Record including (but not limited to) name, Student number, citizenship, social insurance number, Ontario Education Number, and contact information.

Student: any person currently or previously registered in at least one course at the College.

Official Student Record: refers to the official collection of a Student’s Personal Information, Applicant Record, Acadstrongic Record, and Financial Record. This does not include additional records kept by the College that are not part of the Official Student Record (for example but not limited to disability-related records, parking, advising and tutoring records).

Transcript: document issued by a college or university or other authorized body that legally reports a student’s cumulative acadstrongic record, courses and credits taken, grades or achievstrongent levels obtained, and credentials earned.

Policy Statements

  1. General
    1. In choosing to pursue a college education, Students commit themselves to furnishing the College with adequate documentation to support their admission to and ongoing enrolment at the College.
    2. With such Personal Information in its possession, the College has the obligation to protect an individual right to privacy as described in the Freedom of Information and Protection of Privacy Act, 1990 (FIPPA) and, if applicable, the Personal Health Information Protection Act, (PHIPA).
    3. The College must regard each Official Student Record as a unique, private document to which access is strictly controlled and governed essentially by the Student’s wishes and the College’s responsibility, subject to FIPPA and, if applicable, PHIPA.
  2. Collection
    1. The Personal Information obtained or requested is collected under the legal authority of the Ontario Colleges of Applied Arts and Technology Act, 2002. Direct data collection of Personal Information will be made in accordance with the notice requirements of FIPPA or, in those cases where PHIPA applies, the consent requirements of PHIPA.
    2. Data held in the Official Student Record are subject to the principles of confidentiality in this policy.
    3. The College retains all documentation (e.g. portfolio, art), as per the College’s Record Retention Policy, submitted to the College in support of an application for admission, registration, financial award, or any appeal or petition.
      1. The Applicant retains intellectual property ownership for any documentation that they created for the purpose of the application for admission.
  3. Use
    1. The Personal Information of Students, as collected by the College, is used by the College for administrative and statistical purposes, including but not limited to admission, registration and record maintenance, as well as awards, scholarships and the administrative functions of the Alumni Association, the Cambrian College Foundation, and/or the ministries and agencies of the Government of Ontario and the Government of Canada.
    2. Elements of the Official Student Record may be released to third parties who have been approved by the College to provide services to Students (e.g. Student Health Insurance) or who are acting as agents for the College or for the Ministry of Colleges and Universities.
  4. Access
    1. Access to Student Personal Information through electronic methods must be controlled through conscientious use of the technology and adherence to the user guidelines provided by the Registrar.
    2. Students have access to data on their Official Student Record for their examination, under the supervision of the Office the Registrar staff. The data is protected by security measures including the regulation of access to the Student Information System.
    3. The basic guideline governing the release of information is based on the belief that the Registrar acts with discretion upon authorization from the Student, or consistently with the purpose of the collection of the Personal Information or where otherwise authorized or required under FIPPA, PHIPA or otherwise at law.
    4. In response to third party enquiries, therefore, no Personal Information will be released unless it is consistent with the purposes the student was notified of at the time of collection or a consistent purpose, unless there is another statutory exemption, or unless the Student, or someone authorized by the Student, consents to the disclosure.
      1. This applies typically to requests from family members, prospective employers, credit bureaus, finance and loan companies, private investigation agencies, banks and similar organizations.
      2. Such requests made to departmental offices must be referred to the Office of the Registrar.
    5. External requests for mass listing of directory information will be denied. Where such listings have in-house legitimacy, such as the facilitation of Student elections, they may be released to College employees with a need to know, with discretion.
    6. The original documents of an Official Student Record will not leave the Office of the Registrar; appropriate copies may be released to College employees with a need to know.
      1. There are exceptions; this rule is superseded by law, for example, where a court subpoena is in effect if originals are required.
    7. Documents from other institutions, such as high school or university transcripts, which are submitted to support a Student’s application for admission and/or Transfer Credit will generally not be released as part of the Official Student Record consented to by the student or unless required or permitted by law.
    8. Records of attendance do not form any part of the Official Student Record.
    9. The above addresses informal requests for information. In the case of an access request under FIPPA, the College will follow the formal access process set out under the Act.
  5. Student Access
    1. Upon request, each Student may access their own file (subject to FIPPA limitations if it contains the Personal Information of others), request its release to a third party or request it to be held with no release allowed, subject to FIPPA exceptions.
    2. For access requests not made under FIPPA, the College may hold back the release of the Official Student Record if the Student has debts outstanding to the College.
      1. The College will not produce an official transcript, letter or diploma, until the obligation to the College is cleared.
    3. Unless unusual circumstances prevail, no grades or certification are released by the Office of the Registrar to an individual Student prior to the official release of grades and certification to all Students by the Registrar.
    4. The posting of any final Student grade by Student name or Student number or any other identifying symbol where it can be viewed by persons other than College employees with a need to know is prohibited.
    5. Students accessing their own file may view the file but may not alter or remove any of its contents. If they believe their Official Student Record is inaccurate, however, they have the right to seek its correction by following the process outlined in FIPPA.
  6. College Personnel Access
    1. College staff who have a legitimate requirement to access an Official Student Record or records containing Student Personal Information in order to perform their job responsibilities will be permitted access to the appropriate files.
    2. If there is any question regarding the legitimacy of the request, it will be clarified by consultation with the College Coordinator for Freedom of Information and Protection of Privacy – the Director of Human Resources, or such other employee, as assigned, when appropriate.
  7. Third Party Access
    1. Parents/Guardians
      • Since the basis of all transactions with Students assumes adult levels of responsibility, transcripts or Official Student Record will not be released to parents or guardians without the Student’s consent even if the Student is a minor, unless the Student is under 16 years of age and the parent has custodial rights.
    2. International Agents
      • International Agents are entitled to access to, or release of, Official Student Records or information contained therein only upon Student or Applicant’s written authorization.
    3. Sponsoring Agencies
      • Sponsors or employers paying fees on behalf of Students are entitled to access to, or release of, Official Student Records or information contained therein only upon Student’s authorization or as otherwise permitted by FIPPA.
      • Exceptions to this policy, in response to unique requirements or legislation, may be determined only by the Registrar in consultation with College Coordinator for Freedom of Information and Protection of Privacy.
    4. Government Agencies
      • Properly identified representatives of federal, provincial or local government agencies, including local police, O.P.P. and R.C.M.P., will be treated as any third party; that is, Student authorization must accompany their request for information. An exception to this is if the information is to aid an investigation undertaken by police officers or other law enforcement agencies with a view to a law enforcement proceeding or from which a law enforcement proceeding is likely to result – FIPPA allows disclosure in this instance.
      • The College is required to disclose Personal Information such as Ontario Education Numbers, Student characteristics, and educational outcomes to the Ministry of Colleges and Universities or their authorized agents.
    5. The Courts
      • In the event that an Official Student Record is subpoenaed by the court on behalf of the Student, a certified copy of the full Official Student Record will be offered on condition that the student consents to providing such copy in advance of the proceeding that the subpoena relates to. In the absence of consent a College representative will be required to attend the proceeding with a copy of the responsive records to determine how they will be addressed
      • Should the record be subpoenaed by a party other than that representing a Student, a certified copy of the record will be surrendered to the authority who subpoenaed or summoned the records provided the student gives consents, who will then be responsible for further distribution in accordance with their jurisdiction and the law. In the absence of consent a College representative will be required to attend the proceeding with a copy of the responsive records to determine how they will be addressed
    6. Researchers
      • Requests from researchers making statistical studies must be approved by the College’s Research Ethics Committee under conditions that protect the Student’s privacy and guarantee the anonymity of the data collected. Such requests should be compliant with the requirements addressing research in FIPPA.
  8. Record Retention
    1. Records are retained or disposed of according to the College’s Retention Schedule

Responsibilities and Accountability

Associate Vice President, Human Resources and Student Services is responsible for:

  • Ensuring accessibility and communication of this policy and any associated procedures.

College Administrators are responsible for:

  • Familiarizing themselves with the requirements of this policy and any associated procedures.
  • Communicating the policy requirements and any associated procedures to employees.
  • Ensuring compliancy with the terms set out in this policy.

Office of the Registrar is responsible for:

  • Gathering and maintaining accurate data from Students, agencies, institutions and academic faculty.
  • Holding, administering or releasing the Official Student Record.
  • Providing the procedures by which accurate data, collected from Students, agencies, institutions, and academic staff, is maintained and disseminated appropriately to the Student, to third parties designated by the Student, or to other legitimate users as described in this policy.

Staff are responsible for:

  • Being familiar with the policy and its requirements.
  • Complying with the requirements of the policy.

Procedures/Forms

Retention Schedule

Related Policies

Internal Privacy Policy (however, should this policy conflict with this Official Student Records Policy or with the Personal Health Information Protection Act, either of the latter will prevail)

References

Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 (FIPPA)

Personal Health Information Protection Act, 2004, S.O. 2004, c. 3, Sched. A (PHIPA)