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POLICY NAME: Student Records Policy	POLICY NUMBER: 104
AWSNA POLICIES AND PRACTICES AREA:                    VERSION: 3 & 10                                 2	APPROVED: Oct. 18, 2022
ASSOCIATED POLICY: Student Records Forms	ASSOCIATED POLICY NUMBER: 501
CHANGES FROM PREVIOUS VERSION Moved items from Part II: Additional Student Record Items; Additional Items to Optional Items, items #3,4	-

For the purpose of this policy BC Waldorf Schools commit to following Student Records: Requirements and Best Practice Guidelines for Independent Schools.

Rationale
The purpose of this policy is to determine procedures for the collection of student information and its storage, use, disclosure, transfer and protection.

Policy Statement
The Personal Information Protection Act (PIPA) came into effect on January 1, 2004. The following three principles in PIPA apply to all BC Independent Schools regarding Student Records: 

1. BC Waldorf Schools will not collect, use or disclose personal information without the consent of the individual (unless otherwise permitted under the Act).
   
2. On or before collecting personal information about an individual from the individual, BC Waldorf Schools will disclose to the individual verbally or in writing the purposes for the collection and, on request, contact information.
   
3. ​BC Waldorf Schools will only collect, use or disclose personal information for the purposes that a reasonable person would consider appropriate in the circumstances and that fulfill the purposes the independent school disclosed or are otherwise permitted under the Act.

Definitions
Personal information means any information about an identifiable individual, as further defined under British Columbia’s Personal Information Protection Act or other applicable laws. Personal information excludes the name, position name or title, business telephone number, business address, business email, and business fax number of an individual, as well as any publicly available information as designated under applicable laws, such as information available from a public telephone directory or from a public registry.
Parent means the parent, guardian, or other legal representatives of a student. 
Student means a current or past student of a BC Waldorf School.
Student record refers to the Permanent Student Record (PSR) and additional items placed in student records as described below.

Procedures
This policy defines guidelines for five areas under the following headings:

• PART I -  Permanent Student Record: required and optional contents; Form 1704 inclusions, completion, currency and format
  
• PART II - Additional Student Record Items: required and optional contents; sensitive information
  
• PART III - Access and Disclosure of Student Records
  
• PART IV - Transfer and Retention of Student Records 
  
• PART V - Updating Permanent Student Records​

PART I -  Permanent Student Record 
The following items make up a student’s Permanent Student Record (PSR):

1. Permanent Student Record Form 1704, PSB 048 (revised 1997) completed according to instructions that are effective at the time of completion.
   
2. Copies of a minimum of the two most recent years of Student Progress Reports or an official transcript of grades.
   
3. Copies of Form 1704 inclusions.

PSR (Form 1704) Inclusions 
Inclusions are documents (or copies) used to plan or support a student’s educational program. Not all students will have inclusions. Inclusions are listed in the “Inclusion Section” on Form 1704, noting date entered, title and expiry/rescinded date (if applicable). If the space for inclusions becomes full, it may be necessary to create a second portion and attach it to the form for future additions. Documents listed as PSR inclusions on Form 1704 become components of the PSR and are to be transferred with Form 1704 if the student enrolls at another school.

Required Inclusions
The following items must be filed with Form 1704, and dated and listed as an inclusion in the appropriate section on Form 1704, for any student to whom they may apply:

1. Health services information as indicated by a medical alert;
   
2. Court orders as indicated by the legal alert;
   
3. Other legal documents (e.g. name change or immigration document);
   
4. Support services information (e.g. psychometric testing, speech and hearing tests, adjudication requirements for completing assessment activities);
   
5. Individual Education Plans (IEP’s) or Case Management Plan (CMP);
   
6. ​​Notification of students being homeschooled.

Optional Inclusions
The following optional inclusions will not be listed on Form 1704. 

1. Standardized test scores;
2. Records of information which an educator deems relevant and important to the educational program of the student;
3. Ministry Award information (information should include year, date and the serial number of the award).

BC Waldorf Schools will include these items as additional items (defined in Part II).

PART II - Additional Student Record Items 
In addition to the PSR, other items must and may be included in student records. Student and parental/legal guardian information are required. The location of all PSRs and additional items will be in one paper file that is locked in a fireproof cabinet and/or digital files.

A. Additional Items 
Required Items 
The following items must be included in student records to meet independent school inspection/ funding requirements and student safety/emergency standards:

1. Legal name of child (verify the original and file a photocopy of birth certificate);
2. Official name(s) of parent(s) or guardian(s) with home and work contact information;
3. Parental/guardian verification - legally in Canada and resident of British Columbia (see Appendices for verification details and the format for inclusion in school registration forms).                                                            

Optional Items
The following items will be included in the additional items according to school policy:

1. Doctor’s name and contact information;
2. Care card number (if possible);​
3. Allergies, medication and/or other health concerns (other than those with medical alerts; medical alerts are included in the PSR);
4. Emergency contact numbers;
5. Standardized test scores;
6. Records of information which an educator deems relevant and important to the educational program of the student;
7. Previous student progress reports (can be archived separately and stored in a secure location that is not necessarily fireproof);
8. Serious student discipline reports (e.g., copies of letters to parents/guardians regarding discipline matters and corrective actions that have been taken);

​NOTE: To determine the appropriateness of including information in a student’s file, ask the following question: 

Is this necessary or clearly helpful for educators to know when working for the benefit of this student?
                                                            
All documents entered into student records will have the date recorded on them and whenever possible be signed by the appropriate person.

B. Sensitive Information
“Sensitive information” is information which requires that school staff observe a high level of confidentiality, such as:

1. Psychiatric reports;
2. Family assessments;
3. Referrals to or reports from school arranged counselling services;
4. Record of a report of alleged sexual or physical child abuse made to a child protection social worker under section 14 of the Child, Family and Community Service Act.                                                           

Section 14 reports should be retained only for the purpose of the child protection proceedings and this information must not be disclosed to third parties or transferred to other schools. Such reports are strictly confidential and should be stored where only the school Principal or persons authorized by the Principal can access them. Retention of such reports is important for the school to provide confirmation that the report has been made and for evidence purposes in the event that school staff members are subsequently called as witnesses in the child protection proceedings.
                                                
If sensitive information is placed in a school record, the following handling procedures apply:

1. Obtain parental consent for retention of psychiatric reports and family assessments (written consent to be stored with document(s));
2. Store where only the school principal or persons authorized by the Principal can access such information;
3. Disclose or transfer only according to the guidelines in the next section “Access and Disclosure”;
4. Handle records of reports under section 14 of the Child, Family and Community Service Act, according to instructions defined under "Sensitive Information".

PART III - Access and Disclosure of Student Records 
BC Waldorf Schools’ policies and procedures ensure the confidentiality of information contained in a student’s record and we strive to maintain privacy for all students and their families. While disclosures may be made to parents/guardians regarding their children/students, disclosures will not be made that would reveal private information about other students or individuals.

A student capable of exercising PIPA rights and parents/guardians of a student should be permitted (unless restricted by a court order) to:

1. Examine all student records kept by a school pertaining to that student, while accompanied by the Principal or a person designated by the Principal to interpret the records;
   
2. Receive a copy of their/their child’s student record (BC Waldorf Schools, or their School Authorities, may charge a fee that does not exceed the cost borne to the school for providing the copies).

When applicable, graduating students will be provided with interim and/or final transcripts for Grades 10, 11 and 12 courses when graduating, and upon future request of the graduate. Copies will be mailed directly to institutions of higher learning or as requested by the graduate. BC Waldorf Schools reserve the right to assess a reasonable fee for transcript requests. 

Further directives relating to the examination of student records can be found in the Student Records Order (s.3).

BC Waldorf Schools will not withhold report cards from students and parents as leverage to collect tuition arrears or for other purposes. Students have earned their marks and have a right to receive them. Parents have a right to view and receive copies of student records which include current and past report cards.

In addition to parents/guardians and students, access to student records should only be granted, upon the assurance of confidentiality to:

1. Professionals who are planning for, or delivering education, health, social or other support services to that student;
   
2. The School Authority’s insurer to defend any claim/potential claim.                                                                         
   

​
Before access is granted to professionals who are planning for or delivering education, health, social or other support services to that student; or school authority’s insurer to defend any claim/potential claim, the professional or insurer must ensure, in writing, that:

1. They will maintain the privacy of the student and the student’s family with respect to matters disclosed in the record;
   
2. They will not use or disclose the information in the student record except for the specific purposes for which the information is provided.            

Further directives relating to student record disclosures can be found in the Student Records Order (s.6).

If a student’s parents are separated or divorced, school staff may receive requests from the non-custodial parent for student record information or for visits with the student at the school. In these cases, BC Waldorf Schools will confirm the entitlement of the non-custodial parent to obtain such information or to have contact with the student. This will include reviewing applicable court orders respecting custody of, and access to the student and other relevant documents. The custodial parent should be notified of a non-custodial parent’s request for student information or for contact with the student at the school. If BC Waldorf Schools are unsure as to the legal entitlement of the non-custodial parent or if there is serious conflict between the parents with respect to the request, then the schools shall obtain legal advice from their Society’s legal counsel.

PART IV - Transfer and Retention of Student Records 
BC Waldorf Schools will retain permanent student records for 55-years from the date on which the student withdraws or graduates from school either digitally or in a locked storage unit on school grounds unless otherwise arranged. Additional required items will be retained and stored in the same way for 1-year.

On receipt of a request from a school, school board or school authority in British Columbia where the student is enrolled, BC Waldorf Schools will transfer the Permanent Student Record for a student, to the requesting school, board or authority as well as two years of student reports. BC Waldorf Schools will retain the original or a copy of the Form 1704, indicating the school and date where and when the PSR was sent. 

NOTE: If an independent school enrolling a student requests the student’s record from a public school, the public school must transfer a copy of the Permanent Student Record and current Student Learning Plan and IEP to the requesting independent school. The original Permanent Student Record will be retained by the public school (Public School Minister’s Order entitled Permanent Student Record Order).

If the requesting educational institution is outside British Columbia, a photocopy of the PSR should be sent as well as two years of student reports. The original PSR should be retained.

A summary of a former student’s school progress may be provided to prospective employers, at the written request of a former student. BC Waldorf Schools reserve the right to assess a fee for this service.

NOTE: A report to a child protection social worker of alleged sexual or physical child abuse made under section 14 of the Child, Family and Community Service Act should be retained by the independent school in strict confidentiality and the information should not be transferred to another school.

Transfer of any sensitive, confidential information should only occur after written, dated and signed parental/ guardian consent has been obtained to do so (other than section 14 reports - see NOTE above). 

The administration should retain written records of all student record transfers (e.g. student name, date of birth, name and address of receiving school and date of record transfer).

If a BC Waldorf School closes, the school authority shall transfer PSR’s to the schools in which students will be enrolled to continue their education. All PSR’s not transferred must be sent, within 60 days of the closure of the school, to the Inspector of Independent Schools.

Further directives relating to student record transfers can be found in the Student Records Order (s.5). 

PART V - Updating Permanent Student Records

1. All existing students are sent a Registration form for the following school year. 
2. Once the registration form is returned, office staff check over all forms to ensure completeness.
3. Report cards are added to Student Files.
4. A renewal package for the following school year is sent to returning families. This package may include the following but is not limited to:  
   1. PIPA Form
   2. Walk-about Permission Form
   3. Student Emergency Release Form
   4. Tuition Agreement and Payment Plan
5. ​FINAL report cards are added to Student Files and Permanent Student Records Cards are updated with comments and grades as applicable. Students in grade four or higher require a grade for their subjects on the permanent student records. Grades are added to PSR as per final summary report card completed in June.
6. ​Office Staff update student information in computer files and in student records files in preparation for the start of school
7. Report cards are added to Student Files. 

 
Information for Determining Student Eligibility
The following information may be helpful to schools, school authorities and school auditors attempting to verify the eligibility of certain students for provincial operating grants.

To be deemed eligible for funding in BC, the student’s parent/legal guardian must be:

1. Lawfully admitted to Canada,
2. A resident of British Columbia.

​
The Independent School Regulations section 1 “Interpretation” reads as follows: “eligible student” means a student

1. Who is of school age, and;
2. Whose parent or guardian; 
   1. Is, or was at the time of that parent’s or guardian’s death, a citizen of Canada or a permanent resident, as defined in the Immigration and Refugee Protection Act (Canada), who is or was at the time of the parent’s or guardian’s death, ordinarily resident in British Columbia, or;
   2. Is lawfully admitted to Canada and is ordinarily resident in British Columbia.

 
“Guardian” means guardian of the person of a child within the meaning of the Family Relations Act; Parent/legal guardian is lawfully in Canada if he/she meets one of the following:

• Canadian citizen
• Landed immigrant
• Refugee
• Student Visa (more than one year)
• Work Visa (more than one year)
• Diplomat or consular official

Indicators of “residency” include such criteria as:

• Ownership of dwelling or long-term lease or rental of a dwelling
• Residence of spouse, children and other dependent family members in dwelling
• Mailing address
• Telephone listing
• Driver’s license
• Employment
• Registration of automobile, etc.
• Bank accounts
• Credit cards
• Insurance policies

Quick Reference Chart

QUICK REFERENCE CHART	Permanent Student Record - PSR (Transferable)	Additional School File Items (Non-transferable)
Required Elements	1704 with list of inclusions (if any) Student Progress Reports (most recent 2 years or transcript) Copies of inclusions (if any) Health services information in reference to the ‘Medical Alert’ checkbox Court orders in reference to the ‘Legal Alert’ checkbox Support services information (Psychometric Assessments, etc.) IEP or CMP Notification of student being homeschooled	Legal Name (copy of birth certificate) Official names of parents or guardians and contact information Parental/Guardian Legal residency in BC
Optional Elements	Standardized Tests Records of information relevant to student’s educational program Award information ​ ​ Note. These items, once included as part of the permanent student record, Do become transferable.	Carecard/BC Service Card Number Other health or medical concerns that may affect the student in less serious ways Emergency contact informatio Family Physician’s name and contact information ​Other progress reports Serious discipline reports Important meeting reports Sensitive information

BC Waldorf Collective - AWNSA Registered Initiative, Associate, and Full Member Waldorf Schools of BC