The Smithfield Public Schools have a responsibility to safeguard Directory Information and Student Records to maintain privacy and unauthorized access. Because the Smithfield Public Schools rely on the services of software vendors and other parties to manage such data, and because such software vendors and other parties may have access to Directory Information and Student Records in connection with services being rendered to the Smithfield Public Schools in support of the curriculum and this policy.

Under R.I.G.L. Section 16-71, the Rhode Island Educational Record Bill of Rights, the Smithfield Public Schools must maintain the confidentiality of Directory Information and Student Records. Parents and students over age 18 have the right to have the records kept confidential and not released to any other individual, agency or organization without prior written consent of the parent, legal guardian or eligible student, except to the extent that the release of the records is authorized by the provisions of 20 U.S.C.??1232g or other applicable law or court process.

This policy governs the confidentiality and release of Directory Information and Student Records in accordance with R.I.G.L. Section 16-71 and 20 U.S.C.?? 1232g.

Directory Information – Defined

“Directory Information” includes the student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student. It is intended that this definition be consistent with 20 U.S.C. ?? 1232g(a)(5)(A).

Directory Information – Access – General Public

The Smithfield Public Schools may make Directory Information available to one or more parties at the discretion of the Superintendent or his/her designee. The Smithfield Public Schools shall give public notice annually of the categories of information which it has designated as Directory Information with respect to each student enrolled in the Smithfield Public Schools. The public notice may be published in the student handbook, on school websites or via other means that give reasonable notice to parents and students. Parents and students over age 18 shall have fourteen (14) days after such notice has been given to inform the Smithfield Public Schools that any or all of the information designated should not be released without the parent or student’s prior consent.

Student Record –Access – Software Vendors – Curriculum

The Smithfield Public Schools may provide access to Student Record information to software vendors which fulfill curriculum related functions provided that the following conditions are satisfied:

  1. The contract of the software vendor is in writing and is approved by the School Committee.
  2. The software vendor is designated an agent of the Smithfield Public Schools or school official within the meaning of 20 U.S.C. ?? 1232g for purposes of managing Student Record information.
  3. The Superintendent has determined that the software vendor maintains security procedures reasonably designed to maintain the privacy and security of data.
  4. The software vendor shall have access to Student Record information as directed by the Superintendent and only to the extent required to fulfill a function set forth in the contract and only to the minimal extent necessary to carry out the function.
  5. The Superintendent must approve in writing any change in the data to be accessed in the Student Record.
  6. The software vendor shall maintain security procedures for employees, and its agents and representatives that limit access to Student Record information to:
    • correct technical problems and provide systems maintenance
    • protect the property of the software vendor
    • comply with an order of a court of competent jurisdiction
    • require recorded approval by an immediate supervisor of access by an employee

ADOPTED: October 16, 2006