[ARCHIVED] New FERPA requirements for cross-listed courses!

[John_Lowe]

With this statement that just came out today from LeRoy Rooker, what will be Instructure’s take on this interpretation of FERPA?  What will your institution's take be on this interpretation?

Ask the FERPA Professor| resources| AACRAO

Essentially, LeRoy Rooker’s statement is that an institution can allow a student to see other students in a course for which the student is officially registered, but cannot allow a student to see (or be seen by) other students in another (cross-listed) class in the LMS.  To me, it sounds like the door remains open for true cross-listed, in-person courses (like a Psychology and Neuroscience course which are really one-in-the-same, but some students register as PSY and others as NEU) since those students meet at the same time in the same physical classroom with each other.  But this new interpretation seems to shut down courses where one instructor teaches 4 sections of the same Accounting course and simply wants to cross-list those into one course shell in Canvas for the sake of their own convenience and the students would not normally see each other in the physical classroom since they are 4 separate Accounting classes.

Thoughts?  Comments?  Alternate interpretations of LeRoy's answer?  How will you adapt in Canvas?

Deactivated user​, Deactivated user​,  @Renee_Carney ​,  @scottdennis ​, mitch​,  @jared ​

[richard-jerz · Accepted solution]

"I can think of many reasons why a student in Class A would not want to be identified by students in Class B, but reasons do not matter, .."

Kelly, out of curiosity, might you be able to give some reasons?

In a physical classroom, a student in class A can be identified by any other student in Class A, and this doesn't seem to be a problem.  Also, a student in Class B can walk by the Class A classroom and see who is in it.  In fact, anyone can walk by a classroom and see who is in it.  (Will schools need to cover all classroom windows?)

Yes, reasons do not matter, but if there is not solid logic behind the reason, maybe the rule should be challenged.

(I am probably the only one who does not understand this, so I look forward to some explanations.  I anticipate being sorry that I asked.)

[richard-jerz]

I am not an expert on this topic but I have followed a lot of the discussion, Greg.

Your approach (your school's approach) seems to be the most reasonable approach that I have seen so far.  Yes, it seems to me that BIO 101 is really "the course," and that sections are the result of other administration reasons (i.e., resource constraints and trying to satisfy timing issues.)  These reasons do not seem to exist with Canvas, just like they don't exist for other university resources that are combined, such as the library, study halls, guest presentations, computer labs, cafeterias, etc.  If some students are not to be "near" other students, the administration should deal with these non-course issues separately.  Well, you have my opinion.

Good luck to you and your school.

[John_Lowe]

Based on the LeRoy Rooker answer to the question about combined courses, the real variable seems to be would the students otherwise see each other in the same physical classroom or not.  If not, then changing the name of the course is still letting students in different areas see each other based on an administrative action.

[arovner]

 @John_Lowe ​ Yes - that's in line with what we have been told by our Registrar.  Plus there is the added concern that if a student needs to be kept apart from another student, you lose the ability to accommodate this if you lump all students from all sections into 1 "Class".  It was important on our campus to make sure there is always an option for a student to move to a separate F2F or online section.  There has definitely been a bit of grumbling from faculty about the change to no-cross-listing on our campus but mostly because it wasn't decided/announced until just before the quarter began.  We are now collecting "Tips" from instructors about how they manage their separate sections in Canvas, how to remember where you have posted, edited, etc.  We should start a list to share them centrally in the Community!  I could start a public google doc but can I use a document in here somewhere?  stefaniesanders​?   @kmeeusen ​?  Please advise.

Thanks!

Amy

[Nancy_Webb_CCSF]

Thanks for the idea of instructors sharing their ideas,  @arovner ​ .  Look forward to seeing it.

Also I would (or somebody who's better at writing Ideas) like to create a new Idea that "Limit this user to only see fellow section users" be changed to apply to discussions and other activities that are currently not affected by that setting.  Should be some good discussion; maybe everyone with separate sections would not care to keep discussions separate.  Though if you are keeping sections separate seems like you would want discussions to be separate.

[kmeeusen]

Amy:

Great idea, and thanks for tagging me. I in turn will at-mention  @Renee_Carney ​ and  @scottdennis ​ who might be able to make this happen. This is a good idea to better support the great discussions occurring around this topic. Not sure what form it will take, but they will know!

Thanks Amy!

KLM

[Stef_retired]

 @arovner ​, that's a great idea! I would love to read that collection of "tips," and I'm sure others would as well. You can create a document in any Community group of which you are a member; you can make it a collaborative document if you want others to contribute to it. Just navigate to the group and select Document from the Actions dropdown at the upper right of the group home screen. After you've published it, you can then share it out to any other groups to which you belong. And if you share it directly with me as well, or @mention me in the comments, I'll make sure to share it out even more.

[arovner]

Thanks stefaniesanders​!  I decided that the logical group to create this in would be the Instructional Designers one so here's a link to the document.  Everyone - please add your tips and tricks for this as well.  Looking forward to a great resource to share with our communities!

[Stef_retired]

Wonderful,  @arovner ​! I've shared the document with the Higher Education​ group to increase participation and keep comments unified in a single spot.

Do the participants in this discussion think I should share this to the K-12​ group as well?

[jbrady2]

stefaniesanders​ I think it would be good to share with the K-12 group.  The more input the better.

[Stef_retired]

One vote is all I needed,  @jbrady2 ​! Done!

[John_Lowe]

Thank you  @arovner ‌!

[kmeeusen]

There is a new wrinkle in the cross-listing issue - Title IX.

Many of the schools in our system have run this issue by their Assistant Attorney Generals (AAGs), and they were not concerned about FERPA, but raised real red-flags about Title IX. Many of our colleges enroll Running Start students (high school students doing dual college/high school work). Many of our colleges also enroll sex-offenders. The Inbox could provide a sex-offender with unsupervised communication with a high school student.

We are awaiting the final combined legal opinion from our state AAGs, and I will share that here as soon as it becomes available.

KLM

[jbrady2]

 @kmeeusen ​ This does present an interesting new wrinkle.  Recently our school brought up that individuals who have contact with dual-enrolled students from the high school will need to undergo a background check, but this was aimed at faculty, staff, and administrators, and one thing that was not mentioned was whether or how this renewed scrutiny would affect other students.

[Stef_retired]

Just so that I can solidify my understanding,  @kmeeusen ​--this new Title IX issue is something that can arise whether a course is cross-listed or not, yes? My experience with dual enrollment has been that my high school students are enrolled in the same section as my college students, so even if I was only teaching a single section, the issue of having to restrict communications would have to be addressed. Right?

[kmeeusen]

Absolutely! However, this can be managed by turning off a student's ability to Inbox fellow students. This is not an ideal solution as it penalizes everybody because of one scumbag.

KLM

[John_Lowe]

Title IX issues are always a big concern with convenience cross-listing scenarios.  Beyond the sex-offender and minor situation you described, even just current adult student complaint about another current adult student can be impacted by this when one of the remediation steps is class schedule changes to help avoid potential contact between students.

[jhartnett]

Hi all,

I'm sorry if I missed an answer addressing this within the thread.  It has been very enlightening!

As it stands now if: an instructor does the following for cross listed classes (Parent/child sections)

1) change every student to "see only own section"   manually   (would be nice to have a global option)

2) Hide "people", "chat", "collaboration" "conference" on the student menu for all sections

3) set up "groups" by course section enrollment

4) make all discussions "group" discussions aligned with the section "groups"

If all of those are done, are there any other places that students can access information about students in other sections?  If they can't then doesn't that process seems to meet all FERPA requriements?  Of course it would be preferable to have some of those steps able to be implemented globally.

Thanks in advance for any response.

Joe H

[Nancy_Webb_CCSF]

Hi Joe,

A few other things we do:

1) Disable comments on announcements

2) Don't allow students to have editing rights on any content pages unless those pages are in a section’s group workspace area.

3) Disallow "Let students create discussion topics" in course settings.

There may be 3rd party apps that are a problem, check any used in the course.

If anyone has other suggestions let me know.

Nancy

[arovner]

Hi  @ucla1  and nancy.webb great lists!  Thank you!  It's my understanding that the last FERPA hurdle has to do with the Inbox.  Perhaps the "seeing only own section" handles this but it is important to make sure because students can see each other in the Inbox even if in groups, etc.  The only way to disable this is for your campus admin to turn off student-student Inbox communications campus-wide (or by sub-account).  😞  Not an option we are willing to consider.

We have a welcome/resource classroom that we had been routinely putting all online, hybrid and web-enhanced students.  Last quarter we made it self-enroll but only 23 students (out of the usual ~3500 we put in there). Some wise person suggested that we put them all in a special sub-account just for this and turn off the Inbox for that sub account and that seems to be working.  Thank you wise person (sorry I don't know who to give credit to!).

Best of luck to all as we figure out how to adhere to these new requirements.

Amy

[Nancy_Webb_CCSF]

Yes, the setting to "seeing only own section" takes care of Conversations (inbox),  @arovner .

[kmeeusen]

For those of you still wrestling with cross-listing, not violating either FERPA or Title IX, and to answer the angry mobs of teachers with pitchforks and burning brands mobbing your departments; we have worked out a limited work-round.

The problem has been in thinking of the Canvas Inbox as being associated with courses, and hiding it from students in merged course sections. The reality in the Canvas code is that the Inbox is associated with users and their permission settings.

What we have done at our school is:

• Create a new Role in Permissions based on the student role,
• Removed three permissions:
  • See the list of users
  • Send messages to individual course members
  • Send messages to the entire class; and (optionally depending on need)
  • View discussions, and
  • View the group pages of all groups

The first three are the most important.

Then we manually enroll the students into the primary course shell using the newly defined role. Students cannot see student names in the People list, and when they go to the Inbox, they see only their own name and cannot communicate with anybody using that feature.

Obviously, this works better if you don’t have large numbers of cross-listed courses, and works best for manually created courses. For example, we create a Canvas course where WorkFirst students document attendance and progress, and we similarly manually create a course for all Nursing Programs (NAC, LPN & RN) to access and share important documentation. For our Nursing Portal as we called it, the faculty need to get information out to students based on their discipline; to accomplish this we manually created discipline-based sections in the portal, the used CSV files to upload the students into the appropriate sections. Those programs provide us with a spreadsheet of student IDs which makes manual enrollment easy. It could also be accomplished with uploaded CSV files.

O hope this helps at least some of you.

Enjoy!

[Nancy_Webb_CCSF]

 @kmeeusen , that's a very interesting idea, creating a new role.  I am not sure if manually enrolling students using that role will be less work than changing the student permission in the course to "Limit this user to only see fellow section users".  When that is changed, they can only see their own section's students in the Inbox (Conversations), Collaborations, Chat, and People.

How do I limit a user to only interact with other users in the same course section?

But there's still a problem with all sections' student names appearing in discussions, therefore section groups are necessary, along with making each discussion limited to section groups. Or else if discussions are not used, hiding discussions in the course's navigation menu which is very easy to do.  Also teachers should not allow students to edit Pages, since their names show up in the page history.  Those kinds of settings are discussed elsewhere.

[kmeeusen]

Hi Nancy:

By using a CSV upload, or simply a list of student IDs, I can populate the course enrollments in one fell swoop. Changing the access setting one student at a time after they have all been merged is rather tedious. Also, we have found issue with "Limit this user to only see fellow section users" in that they still see the list of all enrollees in the Inbox - unless Instructure has recently fixed this.

I am off to check!

Thanks,

KLM

[jhartnett]

Kelley,

Looking forward to hearing your test.  Canvas help is saying that when Limit this user to only see fellow section users" is enabled (however that is done) that students can not see other students in different cross listed sections.

I wonder if it might be affected by emails to "all students" across sections if the email is not sent as "send individual emails".

Joe H

[bgibson]

So, I haven't been paying attention to this discussion for a while... because I thought our Faculty Development people were going to handle it;-)  Shouldn't there be a switch under Course Settings that would limit all students to seeing only others in their section?  Maybe the switch wouldn't even need to be there, unless the course had been cross-listed.

*The Canvas Help Desk is supposed to be sending me a guide on how to use an API setting to set this "view sections" option.  Not sure "tedious" would be the term, if I had just cross-listed a course and had 60 students in the single Canvas site.  If faculty have to manually go to each student to make the "section view" change that would probably mean far less would want to use cross-listing.  If I have to manually do it, then it's obvious, "Don't cross-list."

[John_Lowe]

 @bgibson ‌, the suggestion of "a switch under Course Settings that would limit all students to seeing only other in their section" is exactly what I've been advocating all along. It appears that Instructure is planning a SIS Import "fix" for this, but that isn't really a fix at all.  Since the problem is almost always created in the GUI when instructors cross-list their own courses for their convenience, a SIS Import fix for a non-SIS-Import created problem is almost as useless as the API fix for the non-API created problem.  This is a GUI created problem that should have a GUI-based solution like you indicated.

Please join me for the upcoming AMA with Jared Stein on Feb 15 to tell him your thoughts about this, and I'd encourage you to ask that very question.  "Shouldn't there be a switch under Course Settings that would limit all students to seeing only others in their section?"

https://community.canvaslms.com/events/1925-ask-me-anything-jared-stein-vp-product-strategy-for-he-i... 

[jhartnett]

Bill,

It seems like your suggestion would be an appropriate fix, as long as student could not see other sections' students in the inbox.  Has this idea come up for voting?  I would certainly upvote that!!

Joe

[gouldt]

We have been watching this closely as well. We don't allow our instructors to cross list their own courses. We cross list courses for instructors or courses that are taught at the same time by the same instructor that would virtually be in the same place, like our ITV courses. We also have some courses that are different course id's but the same content at the same time and same instructor. We also have some courses that have honors and regular students in them. But because the honors student receives a different credit type, we must cross list those courses. We have tried to adopt some guidelines of when we will or won't cross list based on those criteria. 

But of course, there are always those courses that don't follow the guidelines, and we have to make an adjustment. As the person who does all of the cross listing, I would love to see some automation. In some cases it would be nice to not only automate the cross listing, but also creating a new course in Canvas for those that don't have the same course id. 

[John_Lowe]

I should probably clarify my previous response.  A SIS Import *only* fix is not a solution to a GUI created cross-listing.  A SIS Import fix is definitely a step in the right direction and would be great for people in your situation, Tracey. But we still need a GUI option for institutions like ours where we do allow our faculty to perform cross-listing for their own convenience instead of being cross-listed based on SIS data.

[Stef_retired]

Here's your chance to ask  @jared ‌ about this as well as other salient topics! Be sure to RSVP to the CanvasLIVE event Ask Me Anything: Jared Stein, VP Product Strategy for Higher Ed which is coming up this Wednesday, February 15, 2017. RSVP “yes” if you will be there--and if you’re interested, but your schedule doesn’t allow you to attend in real time, RSVP "no" or "maybe" to receive all event updates. Your RSVP ensures that you will receive a notification should the event be cancelled or changed.

[ProfessorBeyrer]

I am glad to see that the SIS import now includes a field to limit sections as announced in today's https://community.canvaslms.com/docs/DOC-9113-canvas-beta-release-notes-2017-03-20 , so for those who have the concern about FERPA and cross-listed courses this will hopefully soon be an option to make easy this limit.

[John_Lowe]

I'm glad to see steps in the right direction as well, but this is still a per-enrollment setting that either gets applied globally (not ideal or desired) or requires that the SIS know who should or should not be restricted on an enrollment-by-enrollment basis at the time the SIS Imports are processed.  In the case of convenience cross-listing by instructors, the SIS will never know that the instructors have cross listed their own courses.  In my opinion, this is step above having to set this flag via the API but still less useful than a course-level GUI setting.

[tthayer]

I would love to see the option for us to limit access in messaging for students to be Teachers Only. Like a switch that can be flipped. We use Canvas for a number of student services departments on campus. WE LOVE IT! But because Canvas is focused on instruction it has limitations. We need/want students to be able to message us (teachers) but do not want them to be able to see any other participants in the course. Having the ability to switch things off and on much like the notification set up would be awesome possum. Any thoughts on this option? 

[ProfessorBeyrer]

 @tthayer ‌ you bring up a good point about using Canvas with student services especially in connection with this thread on FERPA. Certainly there are good reasons for courses used for student services not to display who is enrolled. I have some instructional faculty who do not like the idea of displaying a list of students, even if it is a class that has only one section, and I remind them that they can hide the People link in Course Navigation so that students do not see it. The only way students can see who else is enrolled in the Canvas course is if the courses use Discussions or the instructors allow replies to Announcements. That might work in your situation too. I do something similar in a self-paced course on how to use Canvas. The only Course Navigation links visible to students are Home, Syllabus, and Modules.

[cms_hickss]

 @ProfessorBeyrer ‌ and  @tthayer ‌, hiding the People tab will work for this --to mostly keep students from seeing other students while in the course; however, they will still be able to see the students if they go to the Conversations Tool. 

Now that is a tool I would like to be able to turn off for certain courses --especially for courses like Academic Probation.

[richard-jerz]

So, it appears that we need a course-level setting to allow "people" to show or not to show anywhere (even the Conversations Tool), in Canvas.  To a non-programmer, like myself, this seems like a very simple setting and adjustment in program code.  If the switch is set to "Don't Show", then the course behaves as if there are no students in it.  Also, when a course is set to "Don't Show", some features (such as discussions) should not be allowed.  Otherwise, what should happen when as students types "Hello, I am Bill Gates..." and self-identifies?

Is there a "feature request" available somewhere for this feature that I can vote for?

[tthayer]

Exactly! The messaging/conversation tool is super helpful. Our students love this feature and so do we. It has increased our student participation and communication.

[tthayer]

Yes, we hide the people link. Our students do not have access to the roster. We show them what areas are public and private conversations. But in messaging when they begin to write a message to an instructor a drop down comes down of all individuals in the course. This is what I would love to change.

[myanalunas]

Another reason for having the ability to securely switch off communication between students is the Student Orientation required in California as part of the funding formula. Instead of making hundreds of individual courses for each unique student, having one course that students are enrolled in for the purpose of Orientation requirement, would be a significant reduction in course sections. At our college we recently discussed that by making a course shell for each new student the amount of "single use" or not used at all course shells will exponentially increase, and potentially cause excess weight on the Canvas instance.

[kmeeusen]

We have created a new user called "Cross-listed Student" based on the student user. For this new user, access to all communication tools is closed off. We use this whenever we need to enroll users from disparate courses/section. We manually enroll these students into the courses using a CSV upload.

As for cross-listing itself, we only do this in special cases where the same students are physically together in a live classroom regularly (cohorts).

Kelley