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FERPA - access control

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a01

Junior Member
Here is a somewhat off-the-wall FERPA question. I am attending a postsecondary institution which, like most post-secondary institutions nowadays, provides each student with an ID card that, among other things, functions as an access token to most buildings on campus and many locked rooms and hallways within the buildings, as well as a purchasing card for food and other transactions. It is run by a card office. One thing that I find very annoying about this card office is that they take away door access when you least expect it -- especially for special labs and hallways for which access has to be specially requested by specific room or building managers -- without any communication with the student whatsoever. This happens whenever a set expiry time hits (like at the end of the semester) or when the room/building manager manually requests a change; they simply don't communicate it with the student who is affected and sometimes even consider it confidential from the student.

I have tried to ask the card office to notify me when changes are made -- for changes I am expecting, ones I'm not expecting, when certain expiry times are, etc. -- and although they sometimes agree to do so, they are very disorganized about it and almost never follow through, and they seem to be bad at giving me expiry times even if I ask what they are. If I try to ask what specific doors they've set up that I can or can't access, they will often refuse to disclose to me these specifics (beyond the normal student access plan) and what changes they made or plan on making. It causes a great inconvenience.

The catch is that all of this information is stored concretely in a central database, so the information is there. All the "special" access changes and automatic expiry settings are entered by them into the database by hand. I was wondering, due to the following facts:

1) the access control information is stored in an electronic database (which I know lets them easily generate all kinds of reports),
2) the requests for change by the managers are official and are sent in e-mail memos (or by phone) with the student ID # to be changed,
3) the configuration has a substantive impact on my life at the institution

... whether their configuration would count as an "educational record" about me, and if FERPA (Family Education Rights and Privacy Act) applies to this situation to give me the right to know the configuration and when it expires, and to be notified (i.e. by e-mail/telephone) when they change it. I believe this would most closely tie with FERPA's clause that gives students the right to inspect (or be provided copies of) their educational records. (However a 45-day grace period is impractically long when you want to know the day you'll no longer be able to get in a building/room, except when they set the automatic expiry months in advance.)

I also know that this card office is very FERPA-aware because they've said so and they often cite that law as the basis for many of their other policies and procedures (even for non-disclosure of certain information to faculty and non-dean employees).

If FERPA does apply to this situation in the way I have suggested, then in what manner should I make this request? -- I don't want to seem confrontational but I do want to eliminate this inconvenience stemming from their bureaucratic refusal/failure to disclose/communicate.

Thanks
 



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