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8500 R1 - Student Records System Procedures









The purpose of this system is to implement the policy of the Board of Directors of Edmonds School District No. 15 to provide procedures for all school district personnel who contribute to, maintain, process and/or release student records. These procedures are aligned with the Family Educational Rights and Privacy Act (FERPA). (See also Section IV.)


For the purposes of this policy, the School District has used the following definitions of terms.

Directory Information- is defined as the student's name, photograph, school, grade, dates of attendance, participation in officially recognized activities and sports, weight and height of members of athletic teams, diplomas and awards received and the most recent previous school attended.

Education Records- any record (in handwriting, print, tapes, film, computer, or other medium) maintained by the Edmonds School District or an agent of the District which contains personally identifiable information directly related to a student except working notes kept by a staff member.

  1. Cumulative Folder- contains individual education records which are maintained at the student's school.
  2. Special Education Records- contain information about individual students relative to special education eligibility and services.
  3. Health Care Information- means any information, oral or recorded in any form that is prepared by a health care provider and that identifies or can readily be associated with the identity of a patient or directly relates to the patient's health care.

Eligible Student- a student or former student who has reached age 18 or is attending a post-secondary school. For purposes of some health care records, different age requirements may apply.

Family Educational Rights and Privacy Act (FERPA)- FERPA describes the rights of parents and students with respect to the student's education records. A summary of FERPA relating to student education records is available at each school.

Health Care Provider- a person who is licensed, certified, registered or otherwise authorized by the law of this state to provide health care in the ordinary course of business or practice of a profession.

Parent- a natural parent of a student, a legal guardian, or an individual acting as a parent or guardian in the absence of the student's parent or guardian.

Records Official- Each school district employee responsible for specific student records.

School Official- A person employed by the District as an administrator, supervisor, instructor, or support staff member (including health or medical staff and law enforcement unit personnel); a person serving on the School Board; a person or company with whom the District has contracted to perform a special task (such as an attorney, auditor, medical consultant, or therapist); or a parent or student serving on an official committee, such as a disciplinary or grievance committee, or assisting another school official in performing his or her tasks.

Student- any person who attends or has attended a school in the Edmonds School District.

Working Notes- notes of staff about students which are maintained in the sole possession of the writer and are not accessible or revealed to any other person except a substitute for that staff member. Working notes are not considered student records within the purview of this procedure. When working notes are no longer current, they must be destroyed or placed in the student's records.


The following is a list of the types of records that the District maintains, their locations, and the records official.



Records Official

Cumulative File

School Office - Secured location

School Principal or Designee

Confidential Health Care Information

Educational Health Specialist Files (see also district guidelines for health care information)

Educational Health Specialist

Special Education Records

1) Building Cumulative File

1) School Principal or Designee


2) Student Services Records Center (ESC)

2) Special Education Records Specialist


When information from a student's record, other than directory information, is released to any person or organization other than staff or a school official, a record shall be made of any such release of information and placed in the student's cumulative folder and special education legal file, if appropriate. This record of access shall include date of access, name of the party granted access and the legitimate educational interest of the party granted access. Telephone requests for information about students shall not be honored unless the identity of the caller is known and the caller is authorized to receive the information under provisions of these procedures.

Information may be released to appropriate persons and agencies in connection with an emergency to protect the health or safety of the student or other persons.

Information contained in the student records shall be provided to persons and agencies as follows:

A. Parents/Eligible Student
Parents of dependent children have the right to inspect all student records of their children except for provisions under Health Care Information. An eligible student (a student 18 years of age) may inspect his/her cumulative folder and other records. If a record contains information on more than one student, access to that portion of the record or document which relates to that student only will be provided to a parent or eligible student. The review shall occur promptly after a request is received unless a written explanation for the failure to do so is supplied by the records official. In no case shall access occur later than 45 days after the request is made.

Inspection and review shall be conducted during normal working hours, unless the records official consents to other arrangements. Records officials shall provide reasonable assistance in the interpretation and analysis of student records as requested. Although records must remain within district control, they may be copied or reproduced for the parent or eligible student at their own expense. Upon graduation from high school, a student may request to receive a final transcript in addition to his/her diploma.

B. Staff
Staff who have a legitimate educational interest in a student shall have access to records. Health care providers cannot disclose health care information to non-health care providers (e.g., teachers) until written permission is obtained unless there is a health or safety risk. Health care information is accessible only to health care providers, unless an appropriately executed release under Ch. 70.02 has been obtained or as otherwise provided in FERPA.

In the following situations, student information may be released without parent or eligible student consent:

(1) Directory information may be released without consent upon the condition that the parent or eligible student be notified annually of the district's intention to release such information and be provided the opportunity to indicate that such information is not to be released without prior consent. This information shall be released for the purpose of providing educational, scholarship, vocational/occupational and/or military information, or to the news media and law enforcement. This information shall not be released for commercial reasons.

(2) Other districts/private schools shall be provided with records upon official request (see Disposition of Student Records).

(3) Information may be released to authorized representatives of the comptroller general of the United States, the secretary of education, and/or administrative head of an education agency or state education authorities in connection with the audit and evaluation of federally supported education programs or in connection with the enforcement of the federal legal requirements for such programs.

(4) Information may be released to state and local officials to whom such information is specifically required to be reported or disclosed pursuant to Washington State statutes adopted prior to November 19, 1974 (examples: reporting child abuse or referrals to juvenile court for truancy).

(5) The school district may release to accrediting agencies information from student records needed to perform their accrediting functions. Information may be released to organizations conducting studies for educational agencies for the purpose of developing, validating or administering predictive tests or improving instruction, if such studies are conducted in such a manner as will not permit the personal identification of students and their parents by persons other than the representatives of such organizations and if such information shall be destroyed when no longer needed for the purpose for which the study was conducted. Individual information may not be transmitted to other persons or agencies.

(6) Information may be released in compliance with a judicial order or lawfully issued subpoena, upon condition that a reasonable effort was made to notify the parent or eligible student in advance of such compliance.


Parents and eligible students shall be notified annually of their right to inspect and review the records of their children and their other rights under the Family Education Rights and Privacy Act.


At the time of inspection and review the parent or eligible student granted access to records may challenge the appropriateness and accuracy of any record directly related to the student and may request correction or deletion. Records officials may honor such requests by correcting or deleting records which are inaccurate, misleading, or violative of privacy, provided that the superintendent or designee concurs. Exception: Hearing procedures and right to challenge educational record contents as stated in the Family Educational Rights and Privacy Act of 1974 do not extend to challenge of a grade given in a particular class. A parent or eligible student may challenge a grade on the basis that an error in recording occurred but challenge of rationale for granting of a grade must be directed to the teacher granting the grade.

If a change or deletion is denied, the parent or eligible student may request an informal hearing before the superintendent or designee. That hearing shall be held within 10 school days of the receipt of such request. The District should give the parent or eligible student notice of the date, time, and place of the hearing. The District shall give the parent or eligible student a full and fair opportunity to present evidence relevant to the issues raised. The parent or eligible student may, at his or her own expense, be assisted or represented by one or more individuals of his or her own choice, including an attorney. During the hearing the superintendent or designee shall review the facts as presented by the parent or eligible student and the records official and decide whether or not to order the requested change or deletion. A written decision shall be sent to the parent or eligible student within 10 school days of the hearing.

Parents or eligible students challenging the appropriateness and accuracy of any student records may insert a written explanation of their objections in such records.

Requests for amendments to special education records should follow procedures defined in WAC 392-172-418.


School district records officials:

A. Safeguard student records from unauthorized use and disposition;
B. Maintain documentation of access to records;
C. Honor access requests from legally qualified individuals;
D. Delete or amend records upon approval of the superintendent or designee;
E. Request or exchange student records with other school districts or agencies;
F. Review, transfer, store, or destroy records, as permitted;
G. Upon transfer of the student to the next level (elementary to middle school, middle school to high school) or upon graduation or transfer outside the district, remove records for retention, preservation or destruction in accordance with applicable disposition procedures.


A. The permanent student record (see attached descriptions of elementary, middle and high school permanent student records) shall serve as the record of the student's school history and academic achievement. Permanent records filed in the student's cumulative folder are to be extracted and retained before disposition of the folder.

B. When a student transfers to another school in the district, all records, including the permanent student record shall be transmitted to the other school.

C. When a student transfers to a school outside of the district, the records official shall purge the cumulative folder of all nonofficial, extraneous information. Unless the student has an outstanding fee or fine, copies of records will be sent to the requesting school, with the originals being retained at the sending school. In those instances, the official transcript shall be withheld until the fee or fine is discharged. The enrolling school district shall be notified that the official transcript is being withheld due to the outstanding fee or fine. The enrolling school shall be provided with information regarding the student's academic, special placement, immunization history and discipline records within two school days, and the records shall be sent as soon as possible.


A. Cumulative folders of elementary or middle school students who leave the district shall be retained for three years after a student withdraws from the district.

B. Cumulative folders of high school students shall be retained for five years after the date of graduation or withdrawal from the district. In all cases, the student's permanent record card shall be retained in perpetuity by the district.

C. Confidential health care information shall be retained for three years after a student graduates or withdraws from the district.

D. Contents of a student's Special Education legal file shall be maintained for seven years after a student withdraws from the district, or graduates from school. Parents of special education students shall be notified annually of the records retention schedule as long as their students are receiving services.


After exercising care in accordance with that contained in the previous section (Retention of Student Records), the records official shall bundle all records for destruction and send them to the district office. Each bundle shall be plainly marked: "Student Records--for Destruction," dated and signed by the records official. A summary sheet shall be completed, dated and signed by the records official and retained in the school office. The sheet shall indicate: "As of this date, I have determined that the following records may be destroyed in accordance with district and state requirements and have submitted them for destruction."



1. If applicable, Notifications of Special Education Record (bright green), Life Threatening Illness (bright pink – please consult with nurse for additional information), or Health Concern (yellow).

2. Elementary School Permanent Office Record. A student profile using TetraData will replace the P-170 record card. The information included on the elementary School Permanent Office Record will be available at all times through the TetraData Dynamic Reports module. It will be updated regularly as new assessment data becomes available for each student. Regular emails will be sent to all principals and teachers with instructions about how to access this report.

3. Permanent Conference and Special ServicesConferenceRecords (C-4), including notation of student services referral

4. Washington State Test Results

5. Individual Attendance Histories for each school year (maintained until 3 years after withdrawal for Elementary and Middle School; 5 years for High School)

6. Grade Information

a. Elementary

•Report Cards (Including copies of the ELL attachments)

b. Middle School

• Report Cards (keep only the previous semester when rolling up to High School)

• Middle School Academic History (permanent record)

c. High School

• Middle School Academic History (permanent record)

• Washington State High School Transcript

7. School Registration Form

8. Registration Attachment (P-134 att.)

9. Certificate of Immunization Status (CIS) or Certificate of Exemption (COE)

10. Previous School Records

11. Student Services Records

a. notification of special education record

b. section 504 accommodation plan

c. most current release of information

d. prior written notice for evaluation results or refusal of services

12. Student Discipline Actions (RCW 28A.225.330) (Discipline Actions should be purged 3 years after the incident)

13. BECCA Files (State Truancy Law)

14. ELL Red File Folder, if applicable

15. Copy of Original Birth Certificate, Proof of Residency, or P-110, Affidavit of Student Residency

16. Elementary only – Important Information About Elementary Enrollment (P-192)

Rolling up to Middle School

Everything listed above must be sent on to the Middle School registrar when rolling up.

Purged records may consist of, but are not limited to: Discipline Actions that are three or more years old, Reading and Writing Growth Records, Form Letters, Chapter 1 and LAP Exit Paperwork, all Individual Test records (only if a Test Card is in the CUM file).

If the file contains originals of official documents such as custody paperwork, pertinent court documents, birth certificates or membership documents from Native American Tribes, for example, please return these originals to the parents. Keep copies only if necessary for ongoing legal purposes.

Rolling up to High School

Everything listed above must be sent on to the High School when rolling up.

Purged records may consist of, but are not limited to: Discipline Actions that are three or more years old, Form letters, all Individual Test Records (only if a Test Card is in the CUM file), Report Cards except for the previous semester.

If the file contains originals of official documents, such as custody paperwork, pertinent court documents, birth certificates or membership documents from Native American Tribes, for example, please return these originals to the parents. Keep copies only if necessary for ongoing legal purposes.

Contents of Special Ed Teacher File

1.Copy of current IEP and all amendments

2.Most recent evaluation report if not available on line

3.Preschool/DK student program planning sheet

Withdrawn Student Records

The student's CUM file is purged three years (elementary) or five years (secondary) after the student withdraws from our district. Only the Report Card (including copies of the IEP and ELL attachments) is sent to the Student Placement Office for microfilming. These records must be alphabetized and all staples removed.

Student Records Request

In-District Request:

Send the entire CUM file (which should include any discipline information that is not on the Skyward Student Discipline System and BECCA files if any).

Out-of-District Request:

Copies are sent of the following Edmonds School District records:

1.Report Card (including copies of ELL attachments)

2.Permanent Conference and Special Services Record (C-4)

3.Washington State Test Results

4.Vision, Hearing, and Scoliosis reports (Skyward-based)

5.Immunization Certificate (copy given to student at time of withdraw)

6.Discipline Actions (RCW 28A.225.330) (Discipline Actions should be purged 3 years after the incident)

7.Individual Attendance History

8.BECCA files, if applicable

9. ELL Red File Folder, if applicable

Originals are sent of the following records: (Copies do not need to be retained)

  1. Previous Out-of-District school records

Please note that Special Education records should be requested from the Special Education Records Specialist in student services.

We realize that due to the lack of space in some buildings, the Discipline and BECCA files are not being kept in the same physical location as the CUM file.

Regardless of their location, please note that these files are still considered part of the CUM file and should be sent with any records request as outlined above, or purged three years after withdrawal as outlined above.

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