UCLA Procedure 603.1 : Privacy of and Access to Information (Collection, Disclosures, Amendments, and Inventory)
I . REFERENCES
UCLA Policy 603, Privacy of and Access to Information (Legal Requirements).
II. GENERAL POLICY
The Information Practices Act is indicative of legislative concern with protection of the privacy interests of an individual about whom records are maintained. These procedures, therefore, should be interpreted liberally to the benefit of the individual. Where discretion is allowed, the protection of privacy should override the option to disclose.
It may be desirable, whenever practicable, to consult the individual before releasing information about him/her in situations other than routine inter-University transfers of information. If there is a doubt as to the appropriateness of maintaining or disclosing any information, contact the Office of the Records Management Coordinator for assistance.
A. Collecting Information From Individuals (Privacy Notices on Forms)
|Department||Determines that department’s proposed or existing forms will be used to collect personal or confidential information (refer to Attachment A for definitions).|
|For department’s proposed forms, includes a privacy notice as part of form or as an attachment and sends a copy to Records Management Coordinator for approval (refer to Attachment B);
For department’s existing forms, identifies records covered by provisions of this policy, reviews forms for compliance with the law, and assures that all necessary information is included on a privacy notice attached to form when required (refer to Attachment B).
|Records Management Coordinator||Assists departments in assessment and revision of forms.|
|Department||Sends approved form to Procurement or Mail & Document Services for production.|
|Procurement and Mail & Document Services||Serve as secondary control points to review forms ordered by campus departments and ensure such forms comply with University policy requirements and include appropriate notification and access information.|
|Return orders for forms which do not meet policy requirements to originating departments for correction of deficiencies.|
B. Disclosure of Information from an Individual's Records
|Department||Receives request for disclosure of information.|
|If request is routine and clearly meets provisions summarized in Attachment C, ensures that such requests are met within specified time periods. (Confidential academic personnel records are available only through Office of Vice Chancellor, Academic Personnel.)
Note : If uncertain of appropriateness of response, requests guidance from either:
|Charges per page fee for copies of any records requested. Fee may be requested in advance and an extra charge may be levied to reflect actual cost to University if records need to be abstracted.|
|Maintains records of disclosure as required by law for 3 years or until file is destroyed, whichever is sooner. Records should include the following: Date of Disclosure, Person Receiving Information (stating their name, title, and business address), Information Disclosed (being specific), Purpose of Disclosure (being specific), Reported By and Authorized Signiture of each Disclosure (see Attachment D for Sample Disclosures log).|
|Monitors transfer of records outside University to ensure that no information is transferred unless such transfer is compatible with purposes of meeting reporting requirements of Information Practices Act.|
C. Making Amendments to an Individual's Records
|Department||Receives written requests to amend files and records from the individual and takes appropriate action, within 30 days.|
|If department makes corrections, individual is informed.
If department refuses to amend record, individual is informed of reason for refusal, and established procedures for requesting review of refusal. Reviews take place within 30 days, unless for good cause shown, campus extends review period for an additional 30 days.
|Individual||If after such review, department refuses to amend record, individual is permitted to file a statement of reasonable length setting forth reasons for disagreement.|
|Notes any portion of record which is disputed and makes available copies of the individual’s statement and copies of a concise statement of reasons for not making the amendment to any person to whom disputed record has been or is disclosed.
D. Annual Inventory of Record Systems
|Records Management Coordinator||Requests following information, annually, for each system of records containing personal or confidential information:
|Department||Provides information as requested for purpose of meeting reporting requirements of Information Practices Act.|
IV. IMPLEMENTATION AND RESPONSIBILITIES OF CAMPUS OFFICIALS
The following campus officials have been assigned general responsibilities for the implementation of the Information Practices Act. Departmental responsibilities for specific procedures are outlined in Section III.
A. Vice Chancellors and Deans are Assigned the Responsibilities to:
Ensure that the provisions of campus policies and procedures are implemented by departments within their areas of responsibility.
Review and monitor the establishment and maintenance of departmental record systems and the procedures followed by the departments in responding to requests for access to information about individuals.
Assure that all policy requirements are applied to any personal or confidential records maintained or operated, under contract, on the University's behalf.
B. The Records Management Coordinator is Assigned the Responsibilities to:
Disseminate information concerning state and federal laws and University and campus policies and procedures to the appropriate persons in individual departments.
Design and review, as necessary, the policies and procedures governing development, operation, disclosure and maintenance of general University records containing personal or confidential information and inform the Deans and Vice Chancellors of all such policies and procedures.
Gather appropriate data and prepare and file all reports as required by law.
Establish and maintain records of the types of forms kept in campus departments and assist individuals to find those records which may contain personal information about them.
Assist departments in assessment and revision of forms.
Receive formal complaints from individuals other than University employees who are dissatisfied with actions or decisions of University officials and arrange for review of the disputed actions or decisions.
Provide guidance to departments in responding to requests for general records disclosure, including consultation with the Systemwide Records Management Coordinator and General Counsel's Office when necessary.
C. The Vice Chancellor, Academic Personnel and the Assistant Vice Chancellor, Campus Human Resources are assigned the responsibilities to:
Design and revise as necessary the policies and procedures governing development, operation, disclosure and maintenance of academic and staff personnel records and inform the Deans and Vice Chancellors of all such policies and procedures.
Provide guidance to departments in responding to requests for academic and staff personnel records disclosure, including consultation with Systemwide Records Management Coordinator and General Counsel's Office when necessary.
/s/ Morabito, Sam
Administrative Vice Chancellor