District administrators can opt to include students' full names or first names/last initials in Risk Alert email notifications or remove student names entirely.

• Adjusting Risk Alert email settings

• Risk Alert emails and FERPA

Adjusting Risk Alert email settings

From the "Notifications" tab of your Settings page, the Risk Alert Email Settings section allows you to adjust the level of student information contained in Risk Alert notification emails.

• Hide names: Removes student names and includes only the placeholder "Student"

• Full name: Includes students' first and last names in the email body only

• First name and last initial: Includes students' first name and last initial in the email body only

Click "Save" to confirm your selection. Note: Changes will only take place for email notifications sent after you've made this change.

Risk Alert emails and FERPA

Based on research done by our clinical and program administration teams, commonly, the following criteria must be in place in order to include student names in the body of an email:

1. If an e-mail contains confidential student information, only those individuals with a legitimate educational interest in that information should be included or CC’d on the message.

2. Only send confidential student information to non-district personnel if the appropriate legal release has been signed to allow the non-district personnel access to that information.

Emails are not educational records under the Family Educational Rights and Privacy Act of 1974, 20 U.S.C. 1232g (FERPA), or the Individuals with Disabilities Education Improvement Act of 2004 (IDEA) 20 U.S.C. §§ 1401-1482, unless the school district's policy happens to include emails. (http://www.sweetstevens.com/newsroom/i-want-all-the-emails).

Given that school email systems are typically password protected, emails are not considered educational records, and program administrators are able to identify appropriate personnel to receive risk alerts with legitimate educational interests, Rhithm has determined that the practice of including names only within the body of an email to authorized school personnel is an acceptable practice.

❗If your district or state policy prohibits student names from appearing in the body of an email, we recommend using one of the options listed above to de-identify student last names or remove student names completely.

Additional Resources:

• https://studentprivacy.ed.gov/training/email-and-student-privacy

• https://studentprivacy.ed.gov/content/personally-identifiable-information-education-records

• https://content.govdelivery.com/attachments/NCSBE/2021/03/01/file_attachments/1709138/handlingidentifiableinfo.pdf

• http://smhp.psych.ucla.edu/netexchange.php?tag=312