Nicholls State University protects the security, confidentiality, and integrity of its student records.

The Student Rights and Responsibilities section of the University's Bulletin communicates Nicholls' commitment to the confidentiality of student records [1], as specified by the Family Educational Rights and Privacy Act of 1974 (FERPA) [2].

As identified in the Section 5.8.7 of the University's Policy and Procedure Manual [3], the department of Records and Registration in collaboration with Computer Services maintains students' academic records in electronic format in the Student Information System (SIS).

5.8.7. Records and Registration

Records and Registration reports directly to the Associate Provost.

The responsibility of this office is to assure the accuracy and integrity of student academic records. The office operates registration services, drop/add, resignations, class rosters, and enrollment verifications. Transcripts of the student's academic record are sent at the request of the student.

Other responsibilities of this office include monitoring compliance with the Family Education Rights and Privacy Act of 1974 (described in the NSU Bulletin), NCAA student athletic eligibility, academic renewal, grade changes, credit petitions, and recording credit by examination.

Confidentiality of these electronic records is strengthened by stringent user profile security measures. Nightly data backups are taken by Computer Services in the event of any major, unforeseen problem. Hard copies of records are kept in a secured vault in which only Records and Registration staff members have keys and electronic codes to unlock. These records are maintained for prescribed periods of time; afterwards many are imaged to CD before being shredded. Employees are required to complete a User Privilege Statement [4] guaranteeing confidentiality before gaining access to student records. These completed statements are maintained in the Office of Computer Services.

Other Student Records

Various departments maintain student records that are separate from academic records. Each of these departments is committed to the same confidentiality, security, and integrity of its records.

Judicial Affairs Office
The Judicial Affairs Office maintains a written record for all students who have received discipline sanctions. As explained in the Code of Student Conduct, Section Three, Educational Records-Discipline, "Records of discipline proceedings are confidential in accordance with federal (FERPA) and state laws, which govern access of Educational records. The content of the student's record may not be revealed to anyone not associated with campus discipline except upon the written request of the student or a court-ordered subpoena" [5].

University Counseling Center
The University Counseling Center (UCC) [6] maintains confidential records of all counseling sessions as per the standards of its accrediting body, the International Association of Counseling Services [7]. The UCC is fully accredited and adheres to the ethical guidelines of the American Counseling Association, which addresses the maintenance of written and electronic records [8].

All written case files are kept in locked filing cabinets in a room that locks from both sides and is separate from the waiting area and office suite. Only the counselors and the Executive Secretary have authorized access to the files in this cabinet. Student workers are trained regarding confidentiality of records and sign a Statement of Confidentiality.

The database, which maintains demographic information and number of visits, is maintained on the Executive Secretary's computer to which only she has access by secure password. The University has installed an ID card reader in the UCC for clients to swipe upon entry, which verifies their student status and tracks the times and frequency of visits. Data goes directly to a central system maintained by the ID Coordinator. According to the ID Coordinator, UCC data is accessible only to her and upon the request of the UCC Director. She has also signed an "associate" contract under Health Insurance Portability and Accountability Act of 1996 (HIPAA) regulations.

Clients are informed of confidentiality standards as well as exceptions to those standards in the Declaration of Practices and Procedures form, the Intake Form, the UCC's "Policy and Procedure Manual" [9], and in the confidentiality statement on UCC's Web site [10].

University Health Services
University Health Services (UHS) [11] maintains a health record system with appropriate safeguards for confidential patient information in accordance with American College Health Association (ACHA) guidelines [12] (hard copy available in the UHS office). Health records are legible, documented accurately in a timely manner, and readily accessible to health care practitioners. UHS forms are electronically available [13].

•	Upon entry to the University, students are asked to provide proof of required immunizations detailed in UHS's Immunization Compliance Policy. Hard copies of immunization records are stored in locked, fire-resistant filing cabinets within a locked area of UHS. Immunization dates are entered into the University's Student Information System. Admissions has access to immunization records, and a signed contract is in place in accordance with HIPAA guidelines.
•	Individual health records are established for patients through a unique, non-identifying, chart-numbering system. Patients' chart information is maintained via an in-house database and is accessed using students' social security numbers.
•	When students are serviced by the University Counseling Center and are referred to UHS (or vice versa), a Release of Information Consent form is completed [14].
•	Patient information is not revealed to any other college or institution personnel without the informed consent of patients, as per the Release of Information policy.
•	All clinical information relevant to patient care is readily available to health care practitioners, who observe established protocols for maintaining patient confidentiality.
•	A designated keeper of records has responsibilities which include but are not limited to the following: º   The confidentiality, security, and physical safety of health records; º   The timely retrieval of health records; º   The unique identification of all patients' health records; º   The supervision of collecting, processing, maintaining, storing, retrieving, and distributing of health records; and º   The maintenance of predetermined organized health record format(s).
•	Policies concerning health records address but are not limited to the following: º   The retention of active records; º   The retirement of inactive health records, as required or allowed by state statute; º   The timely entry of data into health records; and º   The release of information contained in health records, including instances in which written permission is required, consistent with applicable federal and state law.
•	For each visit, entries in health records include but are not limited to the following: º   Patients' informed consent; º   Refusals to comply with treatment; or º   Adverse outcomes.
•	With the specific consent of patients, summaries or copies of health records are transferred to health care practitioners to whom patients are referred and, if appropriate, to the organizations where future care is to be rendered, thus assuring continuity of care.

Health information required as a condition of matriculation, such as immunization records or athletic physicals, are included as part of students' health records, according to standard policies and practices.

Office of Disability Services
Established in 1992, the Office of Disability Services /Testing Center (ODS/TC) keeps records for current and former students with disabilities who register with ODS [15]. The office protects the security of student records by keeping them in secured areas, in locked filing cabinets. Only the staff of the ODS/TC is allowed to pull or view student files. A Release of Information form, signed by students, is required to discuss confidential information over the telephone and/or to release information to any outside agency [16]. As new students register with ODS, they sign an Authorization Form for Release of Information. For both offices, ODS/TC maintains a separate Web site which contains a confidentiality statement regarding student files [17, 18] Staff members of ODS/TC are required to read and sign a Statement of Confidentiality Form [19].

Financial Aid
The Office of Financial Aid maintains all financial aid paper files in a locked vault (424 Candies Hall). Electronic records are stored in our Student Information System (SIS) and backed up by Computer Services every night. Backups are kept in a secured location. All Office of Financial Aid staff and student workers have access to paper files and electronic records. Specific staff members in the Academic Success Office have electronic access to financial aid data because they oversee a Federal program that requires the use of this data.

The Office of Financial Aid follows FERPA guidelines. Records created and maintained by the office are considered to be education records and may not be disclosed without student consent. This includes but is not limited to the following records:

    •  Records relating to eligibility and disbursement of Federal student aid funds;
    •  Student accounts;
    •  Federal work-study payroll records;
    •  Financial aid applications;
    •  SARs and ISIRs;
    •  Documentation of professional judgment decisions;
    •  Documentation relating to refusals to certify Federal education loans;
    •  Financial aid history information (for transfer students);
    •  Cost of attendance information, including documentation relating to any adjustments;
    •  Satisfactory Academic Progress (SAP) documentation;
    •  Documents used for verification;
    •  Entrance and exit counseling records; and
    •  Financial records.

Financial Aid staff members and student workers are instructed on FERPA regulations when they begin employment. Signed student statements are required to release information to any outside agency.

Controller's Office
The Controller's Office maintains student financial records and is committed to preserving the confidentiality and integrity of those records. Records include payments received from students or on behalf of students as well as charges to student accounts. While the majority of these records are maintained in electronic format in the Student Information System (SIS), some financial information is maintained in hard copy format. Regardless, all student financial information is considered confidential as per FERPA mandates.

All financial records are kept in a secure environment with limited access. Only authorized employees have access to these records.

University Computer Services/Academic Computing
All student academic records are entered into the University's mainframe computer maintained by University Computer Services. Any changes made to the database during the day are saved and backed up to tape that evening. In addition to nightly tape backups, all files are transferred to a backup mainframe located in a secure disaster-recovery site on campus.