Policies
Middletown Public Schools No. 4150
Confidentiality of Information
The School Committee recognizes its legal and ethical obligation to protect the confidentiality of student, employee, and District information. All confidential information shall be safeguarded against unauthorized access, use, disclosure, or dissemination in accordance with federal law, Rhode Island General Laws, and Rhode Island Department of Education (RIDE) regulations and guidance.
No employee, contractor, volunteer, or agent of the District shall access, use, or disclose confidential information except as authorized by law, School Committee policy, or administrative procedures, and only where a legitimate educational or operational interest exists.
The purpose of this policy is to:
This policy applies to all District employees, School Committee members, contractors, consultants, volunteers, and any other individuals or entities acting on behalf of the District.
Confidential information includes, but is not limited to:
● Personally identifiable information (PII) as defined in FERPA (34 C.F.R. § 99.3)
● Student data as defined under the Rhode Island Student Privacy Act (R.I. Gen. Laws § 16-71)
● Educational records
● Personnel and employment records not subject to disclosure under law
● Health and medical information
● Financial and operational data not designated as public
Confidential information includes any information protected under federal or Rhode Island law or designated confidential by the District, including but not limited to:
● Student academic, disciplinary, attendance, and assessment records
● Special education and disability-related information (IDEA/Section 504)
● Demographic data
● Parent/guardian contact information
● Student identifiers and login credentials
● Digital records, metadata, and communications
● Employment application and personnel information
Records, files, documents, and other materials directly related to a student and maintained by the District or a party acting on its behalf, as defined by FERPA.
A need to access information in order to fulfill professional responsibilities, consistent with FERPA and District policy.
Any individual or entity without a legitimate educational or operational interest in the information, as defined by law or District policy.
The Superintendent, Assistant Superintendent, Director of Finance/Administration, building principal, or designee authorized by the Superintendent.
All individuals covered by this policy shall:
Staff and other covered individuals shall not:
● Access confidential information without authorization
● Disclose confidential information to unauthorized individuals
● Use confidential information for personal gain
● Store confidential information on unauthorized or unsecured devices
● Remove or transmit confidential information outside District systems without authorization
All staff shall:
● Secure physical and electronic records at all times
● Follow District data security and acceptable use protocols
● Use only District-approved systems and encryption methods
● Maintain a “clean desk” environment
● Prevent unauthorized viewing or access to confidential materials
Confidential information shall be maintained and destroyed in accordance with:
● Rhode Island records retention requirements
● Municipal and District retention schedules
● Applicable federal laws
All individuals must immediately report:
● Unauthorized access, disclosure, or use of confidential information
● Loss or theft of devices containing confidential data
● Any suspected or confirmed data breach
Reports shall be made to a supervisor and/or a Senior Administrator immediately.
The District shall respond to breaches in accordance with the Rhode Island Identity Theft Protection Act and applicable RIDE guidance.
All confidential information remains the property of the District. Individuals must return all materials upon separation of employment or upon request. Confidentiality obligations continue after separation.
The District shall:
Violation of this policy may result in disciplinary action, up to and including termination of employment, consistent with:
● Applicable collective bargaining agreements
● Rhode Island law
● District policies
The District may also pursue legal remedies where appropriate.
Nothing in this policy shall be interpreted to conflict with the Rhode Island Access to Public Records Act (APRA). Confidential records, including student and certain personnel records, shall not be disclosed except as permitted by law.
Federal Law:
● Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g; 34 C.F.R. Part 99
● Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seq.
● Section 504 of the Rehabilitation Act of 1973
● Protection of Pupil Rights Amendment (PPRA), 20 U.S.C. § 1232h
Rhode Island Law:
● Rhode Island Student Privacy Act, R.I. Gen. Laws § 16-71
● Rhode Island Identity Theft Protection Act, R.I. Gen. Laws § 11-49.3
● Rhode Island Access to Public Records Act (APRA), R.I. Gen. Laws § 38-2
● R.I. Gen. Laws § 16-2 (General Powers and Duties of School Committees)
● R.I. Gen. Laws § 16-39 (Education Records and Appeals)
Regulations & Guidance:
● Rhode Island Department of Education (RIDE) Data Governance and Privacy Guidance
● RIDE Student Data Privacy and Security Standards
● U.S. Department of Education FERPA Guidance
1st Reading - January 27, 2022
2nd Reading and Approval – February 17, 2022
Review - April 16, 2026
3 Year Review Due - April 2029