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G-23-3 Data Security

Approved: 5/11/2026

Policy Overview: Central Oregon Community College is committed to protecting its information resources from accidental or intentional intrusion, damage or public exposure and is equally committed to preserving and nurturing the open, information-sharing requirements of its academic culture. The privacy of student and employee information is protected by state and federal laws regulating the use of confidential and personally identifiable information. Moreover, COCC imposes its own requirements regarding the safeguarding of Central Oregon Community College data assets.

Policy Information: This policy describes employee responsibilities for safeguarding, recording or accessing records and the policies, procedures, rules and statutes of Central Oregon Community College, the State of Oregon and the United States Government by which they are governed.

Personal Responsibility: By law (including but not limited to FERPA, HIPAA and Social Security regulations), most data is confidential and cannot be released by the College without proper authorization. Each employee is responsible for understanding COCC’s confidentiality requirements for the data to which they have access. Intentional disclosure of individually identifiable information to any unauthorized person could subject that person to criminal and civil penalties imposed by law. Willful or unauthorized disclosure also violates Central Oregon Community College policy and could constitute just cause for disciplinary action and may be referred to appropriate COCC offices and/or, as appropriate, law enforcement authorities.

Acceptable Use: Access to student and employee data is provided to support an employee’s official College responsibility and shall only be used for legitimate College business. A person who has access to student or employee data may not:

  • Access student or employee records unless there is a work-related reason to do so.
  • Reveal the content of any record or report to anyone, except in the conduct of that person’s work assignments and in accordance with College policies and procedures;
  • Make or allow any unauthorized use of information;
  • Knowingly include any false, inaccurate or misleading entry in any report or record;
  • Expunge or modify any data entry from any record, report or file except as officially authorized;
  • Share individual access passwords or PIN numbers with any other person;
  • Remove any official record or report, or copy thereof, from the area where it is maintained, except in the performance of official duties;
  • Seek personal benefit or allow others to benefit personally from knowledge of college data.

Student Data: Unless the law provides an exception, non-directory information, as defined by the Federal Family Education Rights and Privacy Act (FERPA) and Central Oregon Community College's FERPA policy, may not be released to a third party without a Release of Information form on file for the current academic year. A “third party” is considered anyone (including parents, spouses, guardians, or other relatives) without a "legitimate educational interest" in the student record. Information may be shared with other college employees in the completion of work only.  Please reference COCC’s Confidentiality and FERPA web page for more information.

Student Confidentiality Indicator: If a student requests that his/her student information not be released to any-one, a flag will appear on any Banner screen that includes student information. If a student confidentiality indicator exists, the staff person may not release any information on that student to anyone other than the student themselves. Contact the Admissions & Records Office for if further guidance is required.

Employee Data: COCC expects all college personnel that are granted access to personal employee information to strictly protect the confidentiality of information to which they may have access. Any violation of privacy may result in disciplinary action.

Accounts and Passwords:  Passwords are the first line of security and must remain confidential. Do not reveal your password or allow anyone to use the accounts assigned to you.  Accounts access and passwords assigned to individual employees are to be used in connection only with assigned duties as an employee of Central Oregon Community College and may be revoked without notice.  Please reference COCC’s Acceptable Use of Information Technology Resources for more information.