Cobb County School District Administrative Rules
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The goal of the District is that all academic, attendance, disciplinary and health records necessary for maintaining thorough and current information on each student in the Cobb County School District (District) shall be properly kept by principals, teachers, counselors and other designated personnel in compliance with the Family Educational Rights and Privacy Act (FERPA).

RULE:

A. GENERAL PROVISIONS:
    1. Confidentiality:
        Information which is part of the educational record of a student shall be held in strict
        confidence. Permanent records shall be kept in a secure area of the school.
    2. Student Debts:
        The forwarding of records for students who have unpaid debts related to lost or
        damaged materials or equipment shall be in accordance with Administrative
        Rule IFAC (Textbooks, Library Media and Supplementary Instructional Materials
        Accountability).
    3. Transcript Charges/Delivery:
        a. The District shall provide one (1) copy of a student record without charge.
        b. Additional copies of a student’s transcript produced by the school shall cost $2.00
            each.
        c. The cost for each copy of a student’s transcript produced by Records
            Management, Cobb County School District, is $2.00.
        d. The District shall charge $.25 per page for copies of student records released to
            third-parties and for additional copies of records that have been previously
            provided to the parent/guardian/eligible student.
        e. Official transcripts may be picked up at the local school and/or mailed to the post
            secondary school. The official transcript will be:
            (1) Sealed in an envelope with a signature or stamp to secure confidentiality; and
            (2) Signed for in the guidance office by the receiving individual
    4. Records Custodians:
       The following is a list of the type of records that the District maintains, their locations,
       and their custodians:

    5. District Records Center:
        The Records Center maintains records, including transcripts, of students who have
        graduated or withdrawn from the District. To obtain records from the Records Center:
        a. Submit a written release providing all required information (Form JRA-1 [Records
            Center Request]). No records, including a transcript, will be issued without the
            submission of this release.
        b. A student must be 18 years of age or older;
        c. Parents/Guardians may obtain or authorize the release of education records,
            including a transcript, for students under the age of 18.

B. CUMULATIVE RECORDS:
A cumulative record shall be established for all students entering the District:
    1. It shall be the responsibility of the personnel registering the student to acquire
        the necessary releases to obtain a student’s cumulative folder (See
        Administrative Rule JF (Admissions/Withdrawals).
    2. The principal shall designate the school personnel responsible for creating
        and/or updating the cumulative folder.
    3. The record shall be written legibly in black ink and corrected appropriately:
        a. Entries should be dark enough to be copied clearly on a standard bond paper
            copy machine.
        b. If a mistake is made in recording information, the error must be corrected so
            that the record does not give the appearance that it has been altered by
            unauthorized persons.
    4. Information recorded must include the following:
        a. Personal information (Student’s full legal name only and date of birth);
        b. Immunization record;
        c. Indication of administrative placement or retention in grades K-8;
        d. Standardized test information;
        e. Grade levels for each school year;
        f. Date of withdrawal; for "no shows," indicate with “N/S 20” ;
        g. Date of graduation, rank in class and grade point average for graduation;
           (1) Records of students who meet the requirements to graduate from the District
                but receive their diploma from another school system will reflect that the
                student is a graduate. The record should be marked with the following
                statement:
                "Graduation requirements met (date). Diploma received from (name of
                school or school system, city, and state and country, if the diploma is
                awarded by an agency in a foreign country)."
           (2) When a student completes all graduation requirements, including coursework,
                but does not pass all sections of the Georgia High School Graduation Test
                (GHSGT), the permanent record is filed at the local school with the student’s
                original graduation class. When a the student subsequently passes all sections
                of the GHSGT:
                (a) The date of passing will be used as the date of graduation and placed on
                     the student’s transcript and diploma.
                (b) A “Revised Date of Graduation” form (Form JRA-2) shall be filled out and
                     placed in the student’s permanent record.
                (c) Local schools should copy Form JRA-2 on pink paper.
                (d) If the student’s permanent record has been sent for storage to the
                     Records Center, the local school’s guidance department should send an
                     updated transcript with the revised date of graduation. The Records
                     Center will file/store the permanent record in the year of the student’s
                     original date of graduation.
    5. Challenge of Contents:
        Parents/guardians/eligible students may challenge the contents of their child’s
        education records and request corrections if they feel entries on the records are
        inaccurate, misleading, or otherwise in violation of the privacy rights of the student;
        however, a properly recorded grade or score may not be challenged for the purpose
        of having it changed to a higher grade. The review procedure for challenging entries
        is as follows:
        a. Step I:
            When a parent/guardian/eligible student wishes to challenge entries on a record,
            the request shall be submitted to the principal of the school in which the student
            is or has been enrolled. The principal shall investigate the complaint and endeavor
            to settle the matter.
         b. Step II:
            If the conflict is not resolved at the local school level, the request shall then be
            submitted in writing to the appropriate Area Assistant Superintendent for a
            hearing by the review board. This hearing shall be held within twenty (20) days
            of receipt of the request. The parents/guardians/eligible students shall be
            given reasonable notification of the date, place, and time of the hearing.
            (1) The review board consists of the following people who shall be disinterested
                 parties:
                 (a) The Superintendent, or designee;
                 (b) The Director of Curriculum and Instruction for the level of school involved;
                      and
                 (c) The Area Assistant Superintendent for the school from which the request
                       originates.
            (2) The decision of the review board shall be given in writing to the concerned
                 parties no more than ten (10) school days after the date of the hearing. The
                 decision shall be based solely on the evidence presented at the hearing and
                 shall include a summary of the evidence and the reason(s) for the decision.
            (3) The parents/guardians/eligible students may disagree with the review
                 board's ruling and have the right to issue a written statement to be placed
                 in the student's record stating the reasons for disagreement.

C. PROCEDURES FOR ACCESSING RECORDS:
The following procedures will be used for granting access to student records and other confidential information pursuant to the Family Educational Rights and Privacy Act:
    1. Record of Access:
        A record of access shall be maintained for each educational record file:
        a. The record of access shall indicate who has accessed the education record and
            the purpose of their access as required by FERPA.
        b. This requirement does not apply to access by:
            (1) Parents/guardians/eligible students;
            (2) A school official as defined in B.4.a. below;
            (3) A party with written consent from the parent/guardian/eligible student;
            (4) A party seeking directory information as available pursuant to the annual
                 FERPA Notification; or
            (5) A party seeking or receiving records as directed by a federal grand jury or
                 other law enforcement subpoena if the issuing court has ordered that the
                 existence of the contents of the subpoena or the information furnished in
                 response to the subpoena not be disclosed.
    2. Parent/Guardian/Student Access:
        In compliance with FERPA, parents/guardians/eligible students shall be given access
        to the records of the student including the permanent records, attendance register,
        discipline records and results of any individual testing which might have been given.
        A student who is 18 years old or attending a post secondary school shall have access
        to his/her own records. Form JRA-3 (Parent/Guardian Request for Education Records)
        may be used.
        a. Records may be inspected by parents or eligible students within a reasonable
           length of time after the request, but in no case later than forty-five (45) days
           after the request is made.
        b. An appointment should be made with the principal or counselor to review records.
           If the records are at the Records Center, the appointment should be made with the
           Staff Assistant in Records Management.
        c. Requests for interpretation of psychological reports shall be made to the
            Psychological Services Department.
        d. The District will not provide a parent/guardian/eligible student a copy of
            standardized test questions or test protocols.
    3. Non-Custodial Parent Access:
        The right of natural parents who are not the custodians of their children to see
        school records shall be recognized by each school. Such parents may see school
        records at intervals of not less than six weeks and in emergency situations when
        approved by the appropriate Director of Curriculum and Instruction, depending on
        the school from which the request originates.
    4. Disclosure to Individuals/Agencies Other than Parents/Guardians/Eligible
          Students/Non-Custodial Parents:
          NOTE: A correctly executed written request and/or release is required before a
                 transcript or information may be released to any agency or individual other
                 than the parent/guardian/eligible student.
           a. Without Consent of Parent/Guardian/Eligible Student:
             Upon receipt of a correctly executed written request, copies of student records
             may be disclosed without the written consent of the parent/guardian/eligible
             student, only to the persons or offices listed below:
             (1) Officials of schools in which the student seeks or intends to enroll;
             (2) Any appropriate party in connection with an emergency if knowledge of the
                  information is necessary to protect the health or safety of the student or
                  other individuals;
             (3) Other school officials, including teachers within the District, who have been
                  determined by the District to have legitimate educational interest, defined as
                  follows:
                  (a) School Official:
                       A school official is:
                       1) A person employed by the District as an administrator, supervisor,
                           instructor, or support staff member.
                       2) A person elected to the Cobb County Board of Education.
                       3) A person employed by or under contract to the District to perform a
                           special task, including but not limited to, an attorney, auditor, medical
                           consultant, therapist, or insurance adjuster.
                  (b) Legitimate Educational Interest:
                       A school official has a legitimate educational interest if the official is:
                       1) Performing a task that is specified in his/her position description or by
                           a contract agreement.
                       2) Performing a task related to a student’s education.
                       3) Performing a task related to the discipline of a student.
                       4) Providing a service or benefit relating to the student or student’s
                           family, health care, counseling, or job placement, including but not
                           limited to, an attorney, auditor, medical consultant, therapist, or
                           insurance adjuster.
             (4) Federal, state and local educational officials or authorities;
             (5) Officials involved in financial aid for which the student applied or received;
             (6) Parents of a dependent student or such parents as defined in Section 152 of
                  the Internal Revenue Code of 1954;
             (7) Organization or individuals conducting authorized research if:
                  (a) The studies are carried out in such a way that no personal identification
                       of students or their parents can be made by persons other than the
                       persons or organizations conducting the studies; and
                  (b) Such information will be destroyed when no longer needed for the
                       purpose for which it was collected;
             (8) Accrediting organizations in order to carry out their accrediting functions.
          b. Third Party Requests:
            (1) When a copy of a record is requested by court order or subpoena, the principal
                 or designee is to immediately transmit the court order or subpoena to Policy
                 and Planning Division for review and direction regarding the release of records.
            (2) Policy and Planning shall notify, by telephone or by letter mailed to their last
                 known address, parents/guardians/eligible students when the District is
                 complying with the following types of requests:
                 (a) A judicial order,
                 (b) A lawfully issued subpoena.
            (3) If the record is released to the third party, a statement will be attached
                 indicating that the third party is not to release a copy of the record without
                 obtaining written permission from the parent/guardian/eligible student.

D. NOTIFICATION REQUIREMENTS:
    1. Student Directory Information:
       a. Public Notice shall be given to inform parents/guardians/eligible students when
           student directory information is to be released. In all other cases written consent
           of the parent/guardian/eligible student shall be obtained before information from
           student records is released to sources other than those included on a specified list
           of exceptions. Students and their parents/guardians shall be notified of these
           rights. A review board will be established to investigate and adjudicate complaints
           and violations of this policy.
       b. Parent Information Guide:
           Parents/guardians/eligible students will be notified of their rights under FERPA
           annually by publication in the District’s Parent Information Guide. The Guide is
           provided to every student on the first day of school each year or when the
           student enrolls.

Reclassified an Administrative Rule: 9/1/04
Revised: 10/13/04; 6/14/06