The goal of the Cobb County School District (District) is that all academic, attendance, disciplinary and health records necessary for maintaining thorough and current information on each student in the District shall be properly kept by principals, teachers, counselors and other designated personnel in compliance with the Family Educational Rights and Privacy Act (FERPA).

RULE:

A. GENERAL PROVISIONS:
    1. Educational Records:
        FERPA broadly defines an education record as any record, file, document or other
        material that contains information directly related to a student and that is maintained
        by a school district or a person acting on behalf of a school district. 20 U.S.C.
        §1232g(a)(4)(A). Possible exclusions to education records are discussed in 20 U.S.C.
        1232g(a)(4)(B).
    2. Confidentiality:
        Information which is part of the educational record of a student shall be held in strict
        confidence. Permanent records shall be kept in a secure area of the school.
    3. Student Debts:
        The forwarding of records for students who have unpaid debts related to lost or
        damaged materials or equipment shall be in accordance with Administrative
        Rule ECAD (District Property Replacement/Restitution).
    4. Transcript Charges/Delivery:
        a. The District shall provide one (1) copy of a student record without charge.
        b. Additional copies of a student’s transcript produced by the school shall cost $2.00
            each.
        c. The cost for each copy of a student’s transcript or verification of education produced
            by Records Management, Cobb County School District, is $2.00.
        d. The District shall charge $.25 per page for copies of student records released to
           third-parties and for additional copies of records that have been previously provided
           to the parent/guardian/eligible student.
        e. Official transcripts may be picked up at the school, mailed to the post secondary
            school, or electronically released to colleges using GAcollege 411. The official
            transcript that is picked up or mailed will be:
            (1) Sealed in an envelope with a signature or stamp to secure confidentiality; and
            (2) Signed for in the guidance office by the receiving individual
        f. Students who wish to release transcripts to colleges using GAcollege411 must first
           set up a student account. All requests for electronic release may be completed by
           following the directions contained in www.gacollege411.org.
    5. Records Custodians:
        The following is a list of the type of records that the District maintains, their locations,
        and their custodians:
 

    6. District Records Center:
        The Records Center maintains records, including transcripts, of students who have
        graduated or withdrawn from the District. To obtain records from the Records Center:
        a. Submit a written release providing all required information (Form JRA-1 [Records
            Center Request]). No records, including a transcript, will be issued without the
            submission of this release.
        b. A student must be 18 years of age or older;
        c. Parents/Guardians may obtain or authorize the release of education records,
            including a transcript, for students under the age of 18.

        d. The individual requesting the record will be required to provide a photo ID.       

B. CUMULATIVE RECORDS:
    A cumulative record shall be established for all students entering the District:
    1. It shall be the responsibility of the personnel registering the student to acquire the

        necessary releases to obtain a student’s cumulative folder (Administrative Rule JF

        (Admissions/Withdrawals).
    2. The Principal shall designate the school personnel responsible for creating and/or

        updating the cumulative folder.
    3. The record shall be written legibly in black ink and corrected appropriately:
        a. Entries should be dark enough to be copied clearly on a standard bond paper
            copy machine.
        b. If a mistake is made in recording information, the error must be corrected so
            that the record does not give the appearance that it has been altered by
            unauthorized persons.
    4. Required Information:
        Information recorded must include the following:
        a. Personal information (Student’s full legal name only and date of birth);
        b. Immunization record;
        c. Indication of administrative placement or retention in grades K-8;
        d. Standardized test information;
        e. Grade levels for each school year;
        f.  Date of withdrawal; for "no shows," indicate with “N/S 20” ;
        g. Date of graduation, rank in class and grade point average for graduation;
           (1) Records of students who meet the requirements to graduate from the District
                but receive their diploma from another school system will reflect that the
                student is a graduate. The record should be marked with the following
                statement:
                "Graduation requirements met (date). Diploma received from (name of school or

                school system, city, and state and country, if the diploma is awarded by an

                agency in a foreign country)."
           (2) When a student completes all graduation requirements, including coursework,

                but does not pass all sections of the Georgia High School Graduation Test

                (GHSGT), the permanent record is filed at the school with the student’s original

                graduation class. When the student subsequently passes all sections of the

                GHSGT:
                (a) The date of passing will be used as the date of graduation and placed on
                     the student’s transcript and diploma.
                (b) A “Revised Date of Graduation” form (Form JRA-2) shall be filled out and
                     placed in the student’s permanent record.
                (c) Schools should copy Form JRA-2 on pink paper.
                (d) If the student’s permanent record has been sent for storage to the Records

                     Center, the local school’s guidance department should send an updated

                     transcript with the revised date of graduation. The Records Center will

                     file/store the permanent record in the year of the student’s original date of

                     graduation.
    5. Challenge of Contents:
        Parents/guardians/eligible students may challenge the contents of their/their child’s
        education records and request corrections if they feel entries on the records are
        inaccurate, misleading, or otherwise in violation of the privacy rights of the student;.
        However, a properly recorded grade or score may not be challenged for the purpose
        of having it changed to a higher grade. The review procedure for challenging entries
        is as follows:
        a. Step I:
            When a parent/guardian/eligible student wishes to challenge entries on a record,
            the request shall be submitted to the Principal of the school in which the student
            is or has been enrolled. The Principal or designee shall investigate the complaint

            and endeavor to settle the matter.
         b. Step II:
            If the conflict is not resolved at the school level, the request shall then be
            submitted in writing to the appropriate Area Assistant Superintendent for a
            hearing by the Review Board. This hearing shall be held within twenty (20) days
            of receipt of the request. The parents/guardians/eligible students shall be given

            reasonable notification of the date, place, and time of the hearing.
            (1) The Review Board consists of the following people who shall be disinterested
                 parties:
                 (a) The Superintendent, or designee;
                 (b) The Assistant Superintendent, Curriculum and Instruction or

                       designee; and
                 (c) The Area Assistant Superintendent for the school from which the request
                       originates.
            (2) The decision of the Review Board shall be given in writing to the concerned
                 parties no more than ten (10) school days after the date of the hearing. The
                 decision shall be based solely on the evidence presented at the hearing and
                 shall include a summary of the evidence and the reason(s) for the decision.
            (3) The parents/guardians/eligible students may disagree with the Review Board’s
                 and have the right to issue a written statement to be placed in the student's

                 record stating the reasons for disagreement.

C. PROCEDURES FOR ACCESSING RECORDS:
    The following procedures will be used for granting access to student records and other

    confidential information pursuant to the Family Educational Rights and Privacy Act:
    1. Record of Access:
        A record of access shall be maintained for each educational record file:
        a. The record of access shall indicate who has accessed the education record and the

            purpose of their access as required by FERPA.
        b. This requirement does not apply to access by:
            (1) Parents/guardians/eligible students;
            (2) A school official as defined in B.4.a. below;
            (3) A party with written consent from the parent/guardian/eligible student;
            (4) A party seeking directory information as available pursuant to the annual
                 FERPA Notification; or
            (5) A party seeking or receiving records as directed by a federal grand jury or
                 other law enforcement subpoena if the issuing court has ordered that the
                 existence of the contents of the subpoena or the information furnished in
                 response to the subpoena not be disclosed.
    2. Parent/Guardian/Student Access:
        In compliance with FERPA, parents/guardians/eligible students shall be given access
        to the records of the student including the permanent records, attendance register,
        discipline records and results of any individual testing which might have been given.
        A student who is 18 years old or attending a post secondary school shall have access
        to his/her own records. Form JRA-3 (Parent/Guardian Request for Education Records)
        may be used.
        a. Records may be inspected by parents or eligible students within a reasonable length

            of time after the request, but in no case later than forty-five (45) days after the

            request is made.
        b. An appointment should be made with the Principal or counselor to review records.

            If the records are at the Records Center, the appointment should be made with the
            Staff Assistant in Records Management.
        c. Requests for interpretation of psychological reports shall be made to the

            Psychological Services Department.
        d. The District will not provide a parent/guardian/eligible student a copy of

            standardized test questions or test protocols.
    3. Non-Custodial Parent Access:
        The right of natural parents who are not the custodians of their children to see school

        records shall be recognized by each school. Such parents may see school records at

        intervals of not less than six weeks and in emergency situations when approved by the

        appropriate Director of Curriculum and Instruction, depending on the school from

        which the request originates.
    4. Disclosure to Individuals/Agencies Other than Parents/Guardians/Eligible
        Students/Non-Custodial Parents:
        NOTE: A correctly executed written request and/or release is required before a

                  transcript or information may be released to any agency or individual other
                  than the parent/guardian/eligible student.
        a. Without Consent of Parent/Guardian/Eligible Student:
            Upon receipt of a correctly executed written request, copies of student records may

            be disclosed without the written consent of the parent/guardian/eligible student,

            only to the persons or offices listed below:
            (1) Officials of schools in which the student seeks or intends to enroll;
            (2) Any appropriate party in connection with an emergency if knowledge of the
                 information is necessary to protect the health or safety of the student or other

                 individuals;
            (3) Other school officials, including teachers within the District, who have been
                 determined by the District to have legitimate educational interest, defined as
                 follows:
                 (a) School Official:
                      A school official is:
                      1) A person employed by the District as an administrator, supervisor,

                          instructor, or support staff member;
                      2) A person elected to the Cobb County Board of Education;
                      3) A person employed by or under contract to the District to perform a

                          special task, including but not limited to, an attorney, auditor, medical
                          consultant, therapist, or insurance adjuster.
                 (b) Legitimate Educational Interest:
                      A school official has a legitimate educational interest if the official is:
                      1) Performing a task that is specified in his/her position description or by a

                          contract agreement;
                      2) Performing a task related to a student’s education;
                      3) Performing a task related to the discipline of a student;  

                      4) Providing a service or benefit relating to the student or student’s family,

                          health care, counseling, or job placement, including but not limited to, an

                          attorney, auditor, medical consultant, therapist, or insurance adjuster.
            (4) Federal, state and local educational officials or authorities;
            (5) Officials involved in financial aid for which the student applied or received;
            (6) Parents of a dependent student or such parents as defined in Section 152 of
                 the Internal Revenue Code of 1954;
            (7) Organization or individuals conducting authorized research if:
                 (a) The studies are carried out in such a way that no personal identification of

                      students or their parents/guardians can be made by persons other than the

                      persons or organizations conducting the studies (Administrative Rule ILD

                      [Educational Surveys and Research]); and
                 (b) Such information will be destroyed when no longer needed for the purpose

                      for which it was collected;.
            (8) Accrediting organizations in order to carry out their accrediting functions.
        b. Third Party Requests:
            (1) When a copy of a record is requested by court order or subpoena, the Principal
                 or designee is to immediately transmit the court order or subpoena to Policy,
                 Planning and Student Support for review and direction regarding the release of

                 records.
            (2) Policy, Planning and Student Support shall notify, by telephone or by letter

                 mailed to their last known address, parents/guardians/eligible students when

                 the District is complying with the following types of requests:
                 (a) A judicial order;
                 (b) A lawfully issued subpoena.
            (3) If the record is released to the third party, a statement will be attached

                 indicating that the third party is not to release a copy of the record without
                 obtaining written permission from the parent/guardian/eligible student.

D. NOTIFICATION REQUIREMENTS:
    1. Student Directory Information:
       a. Public Notice shall be given to inform parents/guardians/eligible students when
           student directory information is to be released. In all other cases written consent
           of the parent/guardian/eligible student shall be obtained before information from
           student records is released to sources other than those included on a specified list
           of exceptions. Students and their parents/guardians shall be notified of these
           rights. A review board will be established to investigate and adjudicate complaints
           and violations of this policy.
       b. Parent Information Guide:
           Parents/guardians/eligible students will be notified of their rights under FERPA
           annually by publication in the District’s Parent Information Guide. The Guide is
           provided to every student on the first day of school each year or when the
           student enrolls (Form JICDA-3 [Receipt of the Parent Information Guide]).

Reclassified an Administrative Rule: 9/1/04
Revised: 10/13/04; 6/14/06; 6/11/08