Vestigo - FERPA Compliance Policy V1.6
Vestigo Health Solutions, LLC (products known as TracPracⓇ, ClinicalWalletⓇ) services comply with all applicable provisions of the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). Student Data is received by registered student users only and only authorized Instructors or Administrators as a “school official” under FERPA can access Student Evaluation Data for educational purposes. In the event we receive a subpoena or judicial order for the disclosure of education records, we will notify the associated School/Program Customer(s) prior to fulfilling the request in accordance with §99.31(a)(9). For additional information on FERPA, please visit the U.S. Department of Education’s Privacy Technical Assistance Center.
Vestigo Compliance Policies
Vestigo Health Solutions, LLC takes student data privacy seriously. In alignment with U.S. Federal Law and Article 1 – Section 2D of the Laws of ARIZONA, Vestigo takes the following actions to protect student data privacy and completes a FERPA audit annually to maintain this policy:
Vestigo Health Solutions, LLC (Vestigo) limits access to students’ clinical evaluation records to instructors and administrators who are named and authorized employees of the institutions or Nursing/Health Professions program with whom we partner, and only for legitimate educational interests.
a. No formal “grade book” exists in TracPracⓇ (Product of Vestigo). TracPracⓇ is designed to collect and track Formative feedback for the development and progress of practical skills required in healthcare clinical experience logs for State Boards of Nursing documentation requirements. Clinical Evaluations in TracPracⓇ are a “qualitative” [non-numerical, individual opinions/views] evaluation and not a quantitative [measured by a score] grade from the authorized evaluator/instructor.
Vestigo maintains reasonable administrative, technical and physical safeguards to protect the security, confidentiality, and integrity of personally identifiable student information in our possession. (See also: TracPrac System Requirements [https://s3-us-west-1.amazonaws.com/tracprac-learning-center/10754870111648142137.pdf])
Vestigo uses advanced encryption technology and unique code development methodologies to proactively protect all student data while in motion or in static storage state while in our possession from unauthorized disclosure using a technology or methodology. Specified by the secretary of the United States department of health and human services in guidance issued under Section 13402(H)(2) of Public Law 111-5. Below are examples of technical safeguards:
a. Registered Student Name format (custom security measure unique to Vestigo): In addition to our encryption methodologies, Student Names are formatted and encrypted on servers so that first and last names are not connected but stored on separate servers apart from their evaluation data and is unidentifiable to unauthorized individuals
b. Archives: All Student Evaluation Data is moved to Vestigo AWS secure cloud server at the end of each term/semester/quarter as required by our policy. Schools have the ability to manually export all evaluation data from TracPracⓇ in a zip file and request that all storage archives be permanently deleted upon written request to Vestigo Customer Support (INFO@vestigohealthsolutions.com) Vestigo maintains secured archive storage for the length of time requested by the school (Standard: 7 years post student graduation)
c. New Instructors/Evaluator access: All Instructors must be authenticated by the school before they can be added to the TracPracⓇ system. Instructors cannot self-register for access to any school, program, or student information. Instructors are limited to only their specific assigned active course.
d. Active Term Access: Only Active Term data is visible to authorized instructors and the current registered students. All Users at schools are “unassigned” at the conclusion of each term/semester so no active data is accessible. At the beginning of each new term, Vestigo Support collects official Student and Instructor rosters to reassign for the active term. The previous term history of clinical evaluations is NOT visible to active users.
Updated Jan 27, 2022 (Vestigo FERPA Policy)