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Comment: Proposed Confidentiality of Student Information Policy 2013

In comments for the Office of the State Superintendent of Education, Children’s Law Center suggests improvements to the proposed Confidentiality of Student Information Policy, which provides important clarification to local education agencies about student records. Read a summary below or review the full comments as submitted.

The draft policy states that LEAs may charge a fee for copies of student records that are made for parents. However, DC regulations state that parents of children with disabilities are eligible to review records at no cost. And many other DC families are struggling, with 72% of schoolchildren eligible for free or reduced lunch. It is more efficient to provide records for free to everyone than to make case-by-case determinations about whether requiring a parent to pay for copies effectively prevents the parent from exercising his or her right to inspect and review the records. Children’s Law Center recommends revising the policy and eliminating the fee.

The policy also notes that schools may sometimes disclose records without consent from the parent, but doesn’t clarify the circumstances under which this can happen. Children’s Law Center would like this clarification, and urges OSSE to incorporate in the policy the provisions of the recent federal Uninterrupted Scholars Act, which gives child welfare workers the right to access student records without parental consent.