The purpose of this document is to define policy and to determine procedures for the collection of student information and its storage, use, disclosure, transfer and protection.
Freedom Thinkers Education Society is committed to ensuring that student records are handled in accordance with all legal requirements and in a manner that is clear to its students and parents.
2. Policy Statements
The following policy statements are provided to inform all parties who collect, store, use, disclose, transfer and protect student information.
Freedom Thinkers Education Society will:
2.1 Ensure that the Principal is responsible for the establishment, security and maintenance of the Student Record and Student File (as defined in this policy) for each student registered in the school according to the procedures defined in this policy.
2.2 Only collect, use or disclose personal information with the consent of the individual student or legal guardian, unless otherwise authorized under the Freedom of Information and Protection of Privacy Act.
2.3 On or before collecting personal information, disclose to the individual student verbally or in writing the purposes for the collection of personal information.
2.4 Only collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances and that fulfill the purposes disclosed by the school or are otherwise permitted under The Freedom of Information and Protection of Privacy Act.
2.5 Secure Student Records and Student Files with access within the school authority restricted to those individuals who, by the nature of their work, are required to have access to the information.
2.6 Provide access to personal information about an individual student to the individual student (if capable of exercising The Freedom of Information and Protection of Privacy Act rights), and to a parent or legal guardian of the individual student during school hours and under the supervision of the Principal or designate.
2.7 Subject to legal requirements, ensure that personal information will be retained only for the period of time required to fulfill the purpose for which it was collected.
2.8 Inform parents that concerns, complaints and questions about personal information handling policies and practices of the school authority may be directed to the school’s Principal Educator.
3. Definitions and Student Record Components
3.1 Elements of the Student Record
A student record will contain the following:
i. The Permanent Student Record card
a) Form 1704, PSB 048 (revised 1997) completed according to the Permanent Student Record
Instructions that are effective at the time of completion; and
b) Student Progress Reports for the two most recent years or an official transcript of grades;
iii. All documents listed as inclusions on Form 1704 (see Section 3.2 below);
iv. Registration Form, verifying information about the student’s parent or guardian inrespect of students eligibility for funding;
v. A copy of the student’s current Student Learning Plan, if any; and
vi. A copy of the student’s current Individual Education Plan (IEP), if any.
3.2 Permanent Student Record (Form 1704) Inclusions
The following inclusions must be listed on Form 1704, including date rescinded (if applicable), and copies of the documents listed must be filed with the PSR:
i. Health Services information as indicated by the medical alert checkbox, such as diabetes, epilepsy, anaphylaxis producing allergies, and
any other condition which may require emergency care;
ii. Court orders as indicated by the legal alert checkbox;
iii. Other legal documents, e.g. name change or immigration document;
iv. Support services information (e.g. psychometric testing, speech and hearing tests)
v. Current IEP and/or Case Management Plan (CMP) where applicable; and
vi. Notification of a student being home schooled.
The following inclusions may be listed on PSR Form 1704, including document date, title and expiry date or date rescinded (if applicable) and if listed, copies of the documents must be filed with the PSR:
i. Records of information which an educator deems relevant and important to the educational program of the student;
ii. Documents included in special education file, including but not limited to:
a. Serious discipline reports (e.g. copies of letters to parents/guardians regarding discipline matters and corrective actions taken);
b. Copies of notes from important meetings/discussions relating to the student;
c. Standardized test scores, records of information which an educator deems relevant and important to the educational program of the student, and award information IF NOT listed as inclusions on the PSR.
If the above optional inclusions are NOT listed on PSR Form 1704, then they may be included in the
Student File (see Section 3.3, viii below).
3.3 Student File
Additional items must (see below) or may (see ii – v below) be included in the school’s student records as part of the Student File. These items include:
i. Student eligibility information (required):
a. Legal name of child – verify the original and file a photocopy or scanned copy of birth certificate or similar legitimate identification
b. Official name(s) of parent(s) or guardian(s) with home and work contact information; and
c. Verification that parent/guardian is legally admitted to Canada and a resident of BC (see Appendix I, Form A, used to collect this
ii. Care Card number;
iii. Emergency contact numbers;
iv. Doctor’s name and contact information, where available;
v. Previous Student Progress Reports (other than the two most recent years required in the PSR).
3.4 Sensitive Student Information
This may include information, which by its nature requires that school staff who have access observe a high level of confidentiality. Examples include:
i. Psychiatric reports;
ii. Family assessments;
iii. Referrals to or reports from school arranged counselling services; or
iv. Record of a school-initiated report of alleged sexual or physical abuse made to a Child Protection Social Worker under Section 14 of the Child,
Family and Community Service Act.
Sensitive Student Information will be kept in a secure protected file location by the Principal.
4.1 The Principal or designate will be responsible for overseeing that the following occurs:
i. Updating the PSR Form 1704 as information changes and the student progresses through the system;
ii. Ensuring that any electronic copies of documents are stored on a server or external hard drive, and/or optical medium in a physically secure location. If information is accessed through the Internet, an encrypted connection (https://) must be established before authenticating. Access is restricted to those employees who, by the nature of their work, are required to have access; and
iii. Ensuring that the school authority takes necessary precautions to safeguard against vulnerable, or obsolete forms of storage. The electronic storage of PSRs and other personal information will be accompanied by an adequate backup and recovery strategy for potential hardware failure and/or database corruption.
4.2 Student Records and Student File Retention:
i. Student Records – Active Students
a. Student Records (paper originals) are locked in cabinets. Access is restricted to those employees who, by the nature of their work, are required to have access.
b. The school authority protects personal information from unauthorized access, collection, use, disclosure, copying, modification, or disposal, or similar risks. Procedures for such protection are outlined in Sections 5 and 6 below.
c. The Principal or designate will regularly review Student Records to ensure that the information is current and complies with legal requirements.
Required inclusions must be listed on the PSR – see section 2.2 above
ii. Student Records – Inactive Students
a. Unless another school requests a Student Record (see section 6 below), the school authority archives Student Records for 55 years after a student has withdrawn and not enrolled in another Pre-K to grade 8 school, or graduated from the school.
b. The archived Student Records are stored securely and in a manner that ensures their preservation from calamity (fire, flood, etc.) Access is limited to the Principal or designate.
c. The designated records clerk keeps a record of Student Records that are destroyed after 55 years.
iii. Student Files – Active Students
a. Student Files are locked in cabinets. Access is restricted to those employees who, by the nature of their work, are required to have access.
b. The school authority protects personal information from unauthorized access, collection, use, disclosure, copying, modification, or disposal, or similar risks. Procedures for such protection are outlined in sections 5 and 6 below.
c. The Principal or designate will review regularly Student Files to ensure that the information is relevant and important to the educational program of the student
iv. Student Files – Inactive Students
a. The school authority archives Student Records for 55 years after the student has withdrawn and not enrolled in another K-12 school, or graduated from the school.
b. The archived Student Records are stored securely and in a manner that ensures their preservation from calamity (fire, flood, etc.) Access is limited to the administration or designate.
c. The Principal or designate is responsible for determining the relevancy of the contents in Student Records before being archived.
4.3 Currency of Student Records
Student eligibility information will be updated using student registration forms. As stated above, the Principal or designate will review regularly Student
Records and Student Files to ensure that the information is current and complies with
4.4 Security of Student Information Off Campus
The Principal is responsible for ensuring that in cases where it is necessary that personal information be taken off campus that it is safely stored and that personal information is protected. This includes off-site backup of information.
4.5 Handling of Sensitive Student Information
Access to Sensitive Student Information is restricted to the Principal or a person or persons authorized by the Principal to access such information defined in section 2.4 of this policy.
In cases where a parent chooses to do psychometric, psychological, or psychiatric testing of a child privately, the decision to share results with the school or to include them in the appropriate record or file remains with the parent. All documentation received will be stored in the appropriate place in the student’s records.
The Principal or designate will obtain parental consent (written, dated and signed) for the collection, use and disclosure of Sensitive Student Information, including psychiatric reports and family assessments, and will store these as highly confidential documents with restricted access. The original document will remain in a secure protected file location with the Principal.
Sensitive Student Information will only be disclosed or transferred in accordance with the law.
The Principal is responsible for ensuring that school initiated reports under section 14 of the Child, Family and Community Service Act are retained only for the purpose of child protection proceedings and that information is not disclosed to third parties or transferred to other schools. Such reports are strictly confidential and should only be stored where the Principal or designate can access them.
5. Use of Student Personal Information
The school authority may use an individual student’s personal information for the following purposes, assuming that the school has disclosed such purposes to the individual student verbally or in writing on or before collecting the personal information:
5.1 To communicate with the student and/or the student’s parent or legal guardian, to process a student’s application, and to provide a student with the educational services and co- curricular programs provided by the school authority.
5.2 To enable the authority to operate its administrative function, including payment of fees and maintenance of school programs such as parent voluntary groups and fundraising activities.
5.3 To provide specialized services in areas of health, psychological or legal support, or as adjunct information in delivering educational services that are in the best interests of the student.
6. Access to and Disclosure of Student Records
Please refer to the Access and Disclosure of Student Information Policy.
i. Access to a Student Record or Student File will only be granted, upon assurance of confidentiality (with consent), to professionals who are planning for or delivering education, health, social or other support services to that student. Consent will be obtained in writing, listing the name and date of birth of the student, the name and signature of the parent/guardian, and the date of the request.
ii. In the case of a request for personal student information from separated or divorced parents, the school authority will be guided by the legal custody agreement, a copy of which should be provided to the Principal. In cases where the Principal is unsure if the non-custodial parent is entitled to access personal student information, legal counsel will be consulted for a recommendation.
7. Transfer of Student Records
i. On receipt of a request for student records from a school, a Board of Education, or an independent school authority from within British Columbia where the student is (or will be) enrolled, the school authority will transfer that student’s PSR (including declared inclusions), the current Student Learning Plan (if any), and the current IEP (if any) to the requesting institution. The school authority will retain a copy of the PSR, indicating the school where the records have been sent and the date of the student record transfer.
ii. If the requesting institution is outside British Columbia, a photocopy of the PSR will be sent (including declared inclusions), along with the current Student Learning Plan (if any), and the current IEP (if any).
iii. Requests for a student’s record from a public school require that the public school administration provide a copy of the PSR (including declared inclusions) and current
Student Learning Plan (if applicable) and IEP (if applicable) to the independent school authority. The original PSR must be retained by the public school.
iv. The school authority will only transfer sensitive, confidential information (e.g. psychiatric assessments) after dated and signed parent/guardian consent has been obtained.
v. The school authority will not transfer a record of a Section 14 Child, Family and Community Service Act report of alleged sexual or physical abuse made to a child protection social worker.
vi. A summary of a former student’s school progress may be provided to prospective employers, at the written request of a former student. The school authority reserves the right to assess a fee for this service.
vii. A Student Record will be reviewed when a student transfers. The Principal or Special Education designate will ensure that the documents listed as inclusions are still required inclusions (e.g., not expired or rescinded) or still deemed to be relevant and important to the educational program of the student. Expired, rescinded, or irrelevant inclusions will be removed from the Student Record and the documents themselves will be destroyed.