This article was originally published in the September 2014 issue of the PACRAO Review.
Several months ago, the Registrar’s Office received a call from a department on campus. The caller was frustrated and expressed his concern about FERPA violations that were happening in his department. One such violation pertained to faculty members returning graded papers and homework outside their office doors without student permission. The caller claimed his faculty had been told many times this was a violation.
Does this scenario sound familiar? With yes most likely being the answer, the important question we should ask is how do we help faculty and staff adhere more adequately to FERPA? Training is a foundational piece to FERPA compliance. A well trained campus reduces risk of non-compliance. More importantly it aids in the protection of student rights.
While not all training programs need to look the same, the approach matters. This article addresses how Brigham Young University attempted to increase FERPA-compliance and create more awareness at our institution through training. Our FERPA training approach is built upon the universal principles of Fun, Educational, Responsive, Participatory, and Assessable. Though resources vary across institutions, we hope to stimulate ideas and opportunities available on your campus that may not have been considered previously.
Brigham Young University is a private not-for-profit four-year teaching based institution located in Provo, Utah (about an hour south of Salt Lake City). Undergraduate enrollment hovers around 30,000 with an additional 3,000 graduate students. There are around 1,600 full-time faculty and 2,500 full-time staff and administrative employees.
Brigham Young University developed and maintains a homegrown student information system. Access to this system is granted after need/roles are assessed, and users have reviewed FERPA policy and training. Since not all BYU faculty and staff need access to the system, some fall outside of the bounds of required FERPA training.
FERPA training on BYU’s campus has evolved from 20 minute VHS tapes available for checkout, to widely distributed DVDs, to online streaming video. Currently, BYU has implemented an online modular training environment.
What type of emails or videos are the most popular among your office staff? Is it the latest policy change? Perhaps it’s the mission and vision statements? If your office is like many others, it is probably the emails or YouTube videos with animals posing in Star Wars attire, demotivational cat posters, or 100 creative things to do with duct tape. Why are these so popular? It’s because, fun is memorable. Fun is refreshing. Fun gets peoples’ attention.
Because of personnel’s different learning styles, traditional methods of writing, verbal communication, email correspondence, or website text do not have a significant impact on FERPA knowledge (Maycunich, 2002). Instead, seek to provide training that will appeal to several different aspects of your audience’s learning approaches. Create fun scenarios in video format (or other training formats) that strive to increase impact and retain FERPA knowledge.
Imagine a scenario where a supervisor approaches a member of his staff and has the following conversation:
Supervisor: “Amber, can you look up a student for me? Here is her information.”
Amber: “Sure, is she a new student you’ll be advising?”
Amber: “Do you need that information to finish your reports?”
Supervisor: “No. I think she is dating my son.”
Obviously, under FERPA it would not be appropriate to release student information to the supervisor for personal reasons. Dating is a culturally humorous topic at Brigham Young University. By creating a scenario around this topic, it creates an environment that sparks humor for the participant. Embrace your culture in your training. Especially if it is fun. It only takes a bit of observation and a little creativity to incorporate fun into your FERPA training.
What are some other ways fun can be introduced around a seemingly daunting training topic such as FERPA? Here are some approaches:
- Use lively and interesting individuals. There is a great pool of talent on most campuses. Access to talent may be easier than you think. Does your campus have a film/theatre department? Often there is an eagerness for projects in these departments. This is a great resource for incorporating interesting and lively individuals into your video training environment.
- Create humorous situations. It is possible to create humor around a serious training situation; however, do not go overboard. Making light of a FERPA regulation may diminish its intended training purpose. Use subtlety in your approach. Use others to collect ideas. Does someone in your office have a funny experience when helping a customer, faculty, or staff member? Could this experience translate into a training opportunity? An office brainstorm of ideas can quickly give a long list of options. You may be surprised how much the right environment (and a little chocolate) get the ideas flying.
- Use animated and unexpected graphics. Our design team created several visuals and animated graphics that were used in the introduction portion of the training. Such visuals included boxing gloves that punch words, or cartoon figures to demonstrate FERPA principles. Let’s face it, who doesn’t enjoy lively and animated cartoons? If you are not an artist or graphic designer, try contacting your campus animation or design department for help.
In the early stages of this project we asked ourselves if building a training environment would increase knowledge and awareness of FERPA. It has been suggested that self-perception of FERPA knowledge increased significantly for institutions after a FERPA tutorial was administered regardless of faculty or staff status or years at the institution of the individual (Turnage, 2007). However, in order for the training to provide as much educational punch as possible, the incorporation of a few concepts was required.
First and foremost, the training topics have to address common or relevant situations. A team of individuals was sent around campus to interview faculty and staff on topics covered in FERPA. This research provided feedback on areas of FERPA that needed special attention, such as; returning graded homework, grade privacy, determining legitimate need to know, parents roles (or lack of) in student grades, third-party access, and use of email. Obviously we couldn’t cover every FERPA policy, but at least we had something to work from.
The next consideration was to determine how to keep training scenarios and situations current. One of the great challenges faced today is understanding and applying FERPA in the digital age. New apps, cloud storage, and email access have not only changed the FERPA policy landscape but also opened up new possibilities for FERPA training using these new platforms. Training that is structured modularly allows content to be more current and relevant. It is much easier to replace many small individual modules than redo a continuous 20 minute video.
Lastly, in order for educational environments to be maximized, we train more specifically using smaller amounts of information. The training is not, and cannot be, all encompassing. Keep training scenarios and information specific and to the point.
Everyone has different training needs. So what are the needs faculty, staff, and students have when it comes to training? How quickly can you respond to these needs?
Develop a plan that will help identify user needs before you begin. Part of this plan should include technological resources available on campus, a breakdown of both staff and faculty preferences, etc. Training that is easily accessible, available on demand, and role specific should account for a majority of the need.
Not too long ago our FERPA training environment consisted of a continuous play DVD that faculty and staff were required to watch before being granted access to our student information system. This training method provided little flexibility. Providing training in a web based environment has allowed greater flexibility in access and formatting. With the advent of responsive design technology, training environments can render on a variety of devices, thus creating easy access, greater mobility, and on demand environments.
As is true on many campuses, faculty and staff usually knew when a situation they encountered was potentially FERPA sensitive, but they didn’t exactly know how to respond. Training that is role-based, with specific examples of how to navigate the common situations successfully, addresses needs before they arise. Additionally, provide quick access to these scenarios within a training environment specific to the user so they can refresh their knowledge on the subject by quickly jumping to relevant scenarios.
For many, training materials included handbooks, pamphlets, and other written text explaining FERPA policy. Most could tell you, however, that simply posting information about FERPA in a faculty handbook or university policy document alone is insufficient to help campus personnel understand the law (Maycunich, 2002).
Engaging in the process, on the other hand, creates an internalization of the information. Retention occurs at a higher level when they are engaged, focused, and challenged. Here are some ideas on how to build stronger participation into your training:
- Invite the user to react to a situation. After a short video segment setting the stage for the FERPA situation, we presented the trainee with a “what would you do” situation and asked them to select one of four options. Once the answer was submitted, they received instant feedback on their response. If they answered incorrectly, they were told what the correct answer was. This should be a learning process for the participant and not just an exam or certification.
- Ask the user at the time the information is presented if they understood the principle(s) being taught. If users have further questions or comments allow for the selection of an “I have questions regarding this…” option. Have these questions collected and available within the system. In the case of BYU, our FERPA compliance coordinator reviews and responds to each inquiry regularly. Since its deployment in August of 2013, more than 80 questions have been posted and responded to on a variety of topics. A key aspect of this process is to watch for trends in questions so they can be accounted for in future modules.
- Confirm or correct responses and explain why. No matter what was answered, our system confirms the answer as correct or informs the user that it was incorrect but then tells them what the right answer is. In either scenario, the user is informed of the principles behind why the answer was what it was. Having an understanding of why something is the way it is can often add sustainability to compliance.
In some circles the term “assessable” refers to a basis for taxation. The intent is not to impose a tax on the system, but a determination of the system value. It is important to understand if there were mistakes in questions posed or determine if concepts are frequently misunderstood. It is also important to make sure your campus is not at risk due to a lack of understanding on key concepts. Much of this can be ascertained if a system is created that would allow measurement of individual performance and system usage patterns. All of this measurement should lead back to an understanding of risk for FERPA violations.
By tracking individual scores and responses you can assess the comprehension of the individual. As a result of the authentication system we implemented (this ties into the university CAS authentication) we are able to determine the user information based off their user ID. Since its inception, over 700 faculty sessions have been completed with an average score percentage of around 90% correct. Nearly 2,400 staff sessions have been completed with average percent correct near 80%. Because the scenarios are different between faculty and staff, a comparative cannot be inferred.
Not all tools are perfect. Not all questioning is sound. Build in a mechanism that allows the tracking of each question and show the distribution of answers. Several months into the system usage, we noticed a question was missed more frequently than others. We were curious if this was a misunderstood concept or a poorly worded question. Evaluation of the issues lead us to believe it was a poorly worded question. We modified the question. As a result, the accuracy of the responses increased significantly for this question.
Lastly, integrate your environment with an analytic tool. We chose Google analytics, mostly because it’s “free.” This would allow us to understand how the environment is being accessed (mobile/tablet vs. desktop), how long they stayed, what areas were used most, etc. Google allows so many ways to slice and dice information. All of which can lead to more informed decisions on content structuring and framework.
So what’s next? To watch and learn. The system created at BYU will continue to collect data that can be used for future development initiatives. Other topics of interest have surfaced that we plan to build as training modules into the system.
We are also working with the administration to see if we can require FERPA training on a regular basis as opposed to only once when they first request access to the student information system. Now that the infrastructure is in place, most of the future initiatives can be managed in house and won’t require resource planning.
While the specific approach taken at BYU may be daunting to some, the FERPA training principles are universal. Fun, Educational, Responsive, Participatory, Assessable. Resources always seem to be the foremost concern for those approaching a solution similar to that of BYU. It is not to be denied that access to quality resources helped in this project; however, most campuses are equipped with the resources needed. Do you have computer science students who can help develop the framework as a class project? Registrar staff can write scripts and then use the film and theatre department to create videos, or just have some students use their YouTube skills. If you have a graphic design department, or an employee with those talents, they can create visuals, graphics, and marketing. Coordinating this may seem challenging, but the payoff in building relationships and creating awareness of FERPA is substantial.
If you’d like to see what we did and get a feel for our videos, quizzes and administrative site, go here: http://registrar.byu.edu/registrar/ferpaDemo/index.php
Maycunich, Ann. FERPA : an investigation of faculty knowledge levels and organization practices at three land-grant universities. Ames: Thesis (Ph. D.)–Iowa State University, 2002.
Turnage, Casey Carlton. School officials’ knowledge of the Family Educational Rights and Privacy Act of 1974 at the University of Southern Mississippi. Hattiesburg: Dissertation (University of Southern Mississippi), 2007.
Barry K. Allred is the University Registrar at Brigham Young University. He currently serves as the chair of the university FERPA Compliance Committee. Prior to joining the registrar’s office, he worked as the Associate Director of Technology Applications and manager of data reporting at BYU.
Jearlene Leishman is the Senior Associate Registrar at Brigham Young University with responsibilities over Records, Registration, Transfer Evaluation, Petitions, Data Entry, FERPA and data access. Jearlene currently serves as the FERPA Compliance Coordinator for the university.
Brian Chantry is an Associate Registrar at Brigham Young University with responsibilities over technology, academic data reporting and other internal Registrar Office support. He has over 11 years of experience in higher education focused primarily around the development of technology initiatives that improve business processes.