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3 Conceptual Issues for ESRS (Generic Concerns)
In addition to the universal systems issues discussed in section 2, there are some issues that are specific to student records. This section will cover issues that are relevant regardless of how the systems are implemented, while section 4 will address some implementation issues.
Historical Perspective for student records
Historical Perspective for student records
The historical development of recordkeeping systems is an important part of the context of records, one that is surprisingly often overlooked by recordkeepers. The following overview is based largely upon information provided in AACRAO's Guide. 12 Other sources are noted.
In the nineteenth century, some universities maintained the academic record in a ledger book, such as those used by accountants. In these ledgers, each page represented a class roster. Final exam results and grades were noted next to each name in the ledger. Demographic information was captured in another volume, often referred to as the "matriculants book." Some universities, such as Cornell, captured the academic record information on cards. The transcript is so called because they were originally produced or transcribed by hand. When needed, the secretary of the faculty, the registrar, or the "scrivener" produced transcripts in letter form. The typewriter was an early innovation in the compilation of a transcript. When students all followed the same curriculum, a note was made of the degree obtained, graduation status, the number of years of study, etc.
By the twentieth century, the introduction of electives and majors and minors demanded an adjustable ledger that contained a page for each student with demographics and milestones noted on the page. At that point, the information required for transcripts was stored in one place. Ledgers soon were replaced by record cards, or the Permanent Record Card (PRC). The PRC with the admissions application, high school and other transcripts, class lists and grade reports provided the audit trail for the academic record. Until after World War II, transcripts were still typed upon request until the number of students and associated requests for transcripts made that system inadequate, and new forms of copying emerged.
Photocopies and thermofax of academic records replaced typed transcripts. This raised some privacy issues as the recipient might receive more than just the usual subset of information that was normally provided on a typed transcript. The introduction of computers again allowed transcripts to include only a designated subset of information. Punchcard technology was widely used for compiling and accessing student records information until the introduction of databases. 13 The transcript became a subset of the academic record, which, in turn, is a subset of the database for each student. Electronic Data Interchange (EDI) now provides the possibility to provide secure electronic copies of transcripts.14 AACRAO has actively supported the development of the SPEEDE/ExPRESS system for electronic transcripts. This system uses EDI to provide a protocol for automatically initiating requests for transcripts at the sending end of a transcript request and additional protocols for acknowledging and responding to requests at the receiving end. This process provides a secure transaction that is intended to prevent the delivery of fraudulent transcripts. See Appendix L for more detailed information on SPEEDE/ExPRESS.
Roles and Responsibilities
Roles and Responsibilities
The role of the registrar is central to the maintenance of the student records. Maintaining academic records, transcripts, and registration and enrollment statistics are all part of the registrar's responsibility. The role of the registrar has evolved with the introduction of new technologies, as well as changing social trends. Registrars have had to respond to the education benefits provided by GI Bill, student rights protests of the 1960s and 1970s, civil rights, student loans management requirements, the influx of international students, distributed campuses, FERPA, and distance learning. These changes have had a profound effect on the records that need to be created and retained, on the variety of users of the records, and on access constraints on the records that are retained. Because student records are vital records and therefore maintained within the control of the registrar for long periods of time, there is an overlap between the role of the registrar and the role that is traditionally played by records managers and archivists in managing the lifecycle of records. Access to records is the key area where this overlap exists.
Archivists, as the custodians of records, control access to records, interpret and apply relevant regulations, and translate organizational and regulatory policies to the users of records. For student records, registrars usually perform these services until the records are transferred to the custody of the archives. To do so, registrars must also insure that they properly preserve student records so that the records can be made accessible.
Insuring that the university complies with FERPA requirements is one of the primary responsibilities of the registrar as the owner of non-historical student records. The Family Educational Rights and Privacy Act of 1974 was followed by the FERPA Regulation in 1988 and the FERPA Rule in 1993. FERPA stipulates stringent controls on what can be made available to whom and why. In addition to establishing a written policy that is reissued annually, AACRAO recommends consulting with their publications and various government-sponsored websites for current FERPA information. FERPA covers all records that identify individual students including: academic information (all records and documents pertaining to admission, enrollment, and academic progress); academic advising records; financial aid information, job placement information, and student affairs information. These records may be located in multiple offices across the organization. FERPA also demands that records that do not meet the definition of educational record should not be stored with educational records, that changes to the educational record be tracked by the university, and that records be retained to document all disclosures of information for the life of the educational record. 15
Design considerations and requirements
Design considerations and requirements
The key sources of authoritative requirements for electronic student records systems are FERPA and two publications by AACRAO: Academic Record and Transcript Guide; and Guide to Implementation of Electronic Transcripts and Student Records.
While FERPA does not provide implementation guidelines for student records, all electronic student records systems must be able to comply with the recordkeeping requirements and access restrictions stipulated in FERPA.
The Academic Record and Transcript Guide introduces the distinction between the transcript and the student records database. This distinction has important archival implications for establishing the preservation strategy that are discussed in section 5. This Guide provides a list of required and optional data elements in the transcript and in the database. Appendix I, AACRAO Transcript and Database Metadata, contains the list of AACRAOs data elements.
The Guide to Implementation of Electronic Transcripts and Student Records defines the metadata definition for an electronic transcript transaction. Electronic transcripts are discussed under implementation in section 4.1.
There are two high-level processes in a student records system, delivery of transcripts and controlled access to the student records database. The requirements for transcripts are well defined by the three sources indicated above. The requirements for the database, as long as FERPA compliance can be assured, are less specific and must meet the needs and requirements of the university. Like most universities, Cornell closely monitors FERPA and AACRAO developments, and carefully considers when and how to implement changes that will insure compliance with regulations and guidelines.
Universities are applying a number of new technologies to university computing problems. The trend towards online, distributed computing at universities began in the 1990s. In fact, Cornell was a leader in this area with the innovative Mandarin project which was initiated in 1990 to build tools for distributed applications to support faculty and students. The software produced by the consortia of universities that participated in the Mandarin project had a major impact on distributed university computing. Universities are meeting the demand for access to records by students, faculty and administrators through the development of Internet-based applications, and the application of ATM and other secure, distributed computing technologies. AACRAO's Breakthrough Systems: Student Access and Registration provides case studies on a number of innovative projects in this area, some of which are probably outdated now with the speed of technology development.
FERPA and AACRAO are two consistent sources for tracking changes in electronic student records systems requirements. Technology will continue to have a big impact on what is possible and feasible for student records.
3.1 Retention Guidelines and Records Management Concerns
AACRAO, as previously stated, has been very active in insuring the adequate retention and protection of university records. Since AACRAO is the foremost professional body for registrars and registrars are the owners of student records, this is an extremely important and positive situation for the retention of student records. The most recent edition of Academic Record and Transcript Guide states that the purpose of producing that publication is to "assist individuals charged with the responsibility of records management in postsecondary institutions."16 While there are references to several recordkeeping publications in the Guide, there is no evidence of direct cooperation with recordkeeping professionals. The Guide does provide a very useful outline of student records issues. They conclude that "records systems, whether manual or electronic, should contain the same basic information and adhere to similar, generally acknowledged, good recordkeeping practices."
AACRAO's publication entitled: Student Records Management, edited by Ruzicka and Weckmueller addresses many issues that are of interest to archivists and records managers, but there is no indication of active interaction with archivists or records managers. The authors do encourage the consistent implementation of retention schedules and the participation of the records manager.
SAAs Guidelines for College and University Archives identifies three types of university records that should be retained that are relevant to this project:
The 2000 version of AACRAOs Retention of Records: A Guide for Retention and Disposal of Student Records states that the successive updates to the publication since the first edition in 1960 reflect the impact of technology. FERPA focused the attention of universities on recordkeeping practices. They have evolved principles for retention and disposal:
AACRAO identifies a number of federal laws and regulations affecting university records that have been issued by a range of agencies, including Department of Education, Veterans Administration, Public Health Service, Internal Revenue Service, FERPA, and the State Department. They recommend that universities stay current with these laws and regulations.
AACRAO reminds the users of their Retention Guidelines that the recommendations:
Records management issues for student records appear to be widely addressed and well-defined. AACRAO has a large, representative membership and their publications are well known within universities. It is also clear from a comparison of the AACRAO and Cornell retention schedules that when universities are guided by the AACRAO recommendations, the resulting schedules will most likely not be very different than the AACRAO schedules. A universitys records schedules must reflect the requirements and priorities of the organization, but some level of standardization is possible and desirable. Appendix J presents the comparison of the AACRAO and Cornell retention schedules.
In spite of the absence of ongoing cooperation and collaboration between AACRAO and various recordkeeping professional associations, it would be difficult for recordkeeping professionals to disagree with the principles expressed and the general recommendations provided in the Guide. Recordkeeping professionals have been aware of AACRAO's Guide for a long time and have expressed some concerns about the recommendations in the Guide.18 The following recommendations address persistent records management concerns.
It can be difficult to compare the records schedules of individual universities with the retention schedules in the Guide. This observation is based primarily on comparing Cornells records retention policy with the retention schedules in AACRAO's Guide. This case may not be representative, but it is probable that the adoption of universal and common descriptions, standard IDs for scheduled items on university retention schedules and compatible classification structures for the categories of university records would be increasingly useful as universities build partnerships and consortia. This would also provide an opportunity to consider minimum versus ideal retention periods.
While there is general agreement that these records should be retained, universities have not been consistently and comprehensively retained these records, nor have universities considered the impact of technology on the nature and sources of these records. This is particularly important because these records may be required to verify the completion of degree requirements, document the content of courses, and to form the basis for evaluation of curriculum to meet a variety of needs, including administrative, legal, fiscal, and historical. This is the key area in records retention that should be addressed.
3.2 AACRAO Transcript and Database Metadata
AACRAO has devoted extensive time and resources to the development of transcript metadata and Electronic Transcript transaction metadata. The metadata definitions are based on decades of work on the uniform content, presentation, documentation, and handling of transcripts. AACRAO's Academic Record and Transcript Guide contains extensive information on the development and management of transcripts and student record databases. University archivists should become familiar with this publication and consider proposing archival considerations or volunteering to participate in the preparation of the next version of the publication. The 1996 edition of the Guide added a matrix that compares the elements in a transcript to the elements in a database, identifying optional, recommended and required elements. The complete set of Electronic Transcript metadata elements is available online at AACRAOs Web site (see Appendix D, Relevant Sources). Appendix I provides a summary list of AACRAO's transcript and database metadata elements.
Archivists have also recognized the value of metadata for preservation and access. Currently, however, there is no accepted archival metadata standard. Appendix D contains citations for several major archival metadata initiatives. The Indiana University Electronic Records Project produced a case study on the Office of the Registrar analyses metadata requirements using the University of Pittsburgh approach on Indiana's system.
Archivists should consider initiating a cooperative project to undertake a comprehensive and systematic analysis of AACRAO, SPEEDE/ExPRESS, and archival preservation metadata requirements. Working with AACRAO, archivists may be able to insure that archival requirements are incorporated. The SPEEDE/ExPRESS model may also be adapted to the secure delivery of archival records to users. A joint project with AACRAO, ARMA and SAA would probably be the most effective approach.
3.3 Archival Concerns
Though there have been many publications on university archives, these articles and books do not contain much on electronic records, and less on student records.19 The Family Educational Rights and Privacy Act of 1974 (FERPA) and its related regulations stipulate stringent controls on access to records to which universities must comply. To meet these requirements, universities often engage in de facto records management, under the guidance of authorities, such as the American Association of Collegiate Registrars and Admissions Officers (AACRAO), without calling upon the services of records management professionals. A recordkeeping professional did participate in the publication of the 1987 version of AACRAO's Retention of Records, but since then there appears to have been little further cooperation. 20
Student records are a vital record of the registrar's office. The registrar must be able to produce a transcript and other components of the academic record for certification, license maintenance, patent renewal, estate management, and other authorized purposes, possibly even beyond the death of the student. Maher does identify the transcript as a vital record, but student records have not generally been discussed as vital records in recordkeeping literature. 21 This status has important implications for student records. It means that while student records may be a permanent record of universities, they remain the primary responsibility of the registrar until they are no longer considered to be a vital record. Given the indefinite long-term requirements, there is no identifiable point at which a student record ceases to be a vital record and becomes solely a permanent record, though most student records would cease to be actively used long before the death of the student.
The normal delay between when records are created and when records are preserved in an archives or by another authorized custodian is longer for vital records. Vital records remain in the control of creators, or in the control of those who are responsible for maintaining the records, until the records are no longer considered to be vital records. At Cornell, for example, while there is a good relationship between the registrar and the archives, there is no formal agreement on short-term and long-term access to student records to establish at what point or in what circumstances responsibility for access shifts from the Registrar to the Archives. For most electronic student records systems, either the electronic record is not the format that will be preserved or the records are still vital records and so not yet the responsibility of archivists.
Given the importance of student records as both vital records and as valuable historical records, it is clear that there needs to be clear understanding and cooperation between the Registrars Office and the Archives. There should be agreement about the role that each should play in maintaining and providing access to student records over the lifecycle of the records. There are possibilities for cooperation and shared resources.
Comprehensive student records
Comprehensive student records
Transcripts and student records systems are generally the focus of discussions about student records. Course documentation is often included, but not always. In Varsity Letters, Helen Samuels identifies an additional category of records to insure the comprehensive documentation of student records. She identifies three levels of documentation: policy, aggregate, and individual records. Individual records issues are well documented, and aggregate records are adequately covered in records schedule guidelines. Policy records, however, may be scheduled for permanent retention, as they are at Cornell, but may not be included as a necessary component of student records. These records may provide essential pieces of information to verify degree requirements and course delivery. They also provide a context for the creation and maintenance of student records at the university.
The role of policy records in student records documentation should be evaluated and documented by universities, and the relationship between policy records and student records should be identified. The Archives could consider preparing a student records finding aid that identifies the components of student records, where they are located and how access to records over time is made possible. This would tie all of the pieces together.