Policies/EducateONE Organizational Policy § 11.1.00. Corporate Records

Version: 2026-07-12 draft.

Article I. EducateONE Organizational Policies

EducateONE Organizational Policy § 11.10.00. Participant Record Collection and Maintenance.

(a) Purpose.

(1) In order to document participation, satisfy legal and institutional requirements, recognize qualifications, support continuity between programs and roles, and preserve an accurate account of each participant’s relationship with EducateONE, EducateONE shall maintain participant records in accordance with this policy.

(2) EducateONE recognizes that the same person may participate as a student, learner, educator, mentor, advisor, contributor, leader, volunteer, employee, contractor, or in another role at different times or within different programs.

(3) Participant records shall therefore be organized around the person and the person’s participation, rather than assuming that each person has only one permanent institutional role.

(b) Scope.

(1) This policy applies to every person who participates in an EducateONE institution, school, program, service, activity, educational experience, or other institutional offering.

(2) For purposes of this policy, a “participant” means any person participating in EducateONE or any controlled EducateONE institution, school, program, service, activity, operation, or offering in any capacity.

(3) A person may have more than one participant role simultaneously or over time.

(c) Required Participant Record Categories.

(1) EducateONE shall maintain the following categories of participant records:

(A) identification information;

(B) program enrollment information;

(C) attendance;

(D) demographic information; and

(E) qualification information.

(2) EducateONE may maintain these categories in one record system or in multiple connected record systems.

(3) EducateONE may determine the format, structure, terminology, technology, and administrative method used to maintain participant records.

(d) Identification Information.

(1) EducateONE shall maintain identification information reasonably sufficient to distinguish the participant from other persons and connect the participant with the participant’s records.

(2) Identification information may include:

(A) the participant’s name;

(B) alternate, prior, preferred, or additional names;

(C) a unique participant identifier;

(D) contact information;

(E) parent, guardian, family, or authorized-representative information when applicable; and

(F) other identifying information reasonably necessary for lawful educational, administrative, safety, reporting, or institutional purposes.

(e) Program Enrollment Information.

(1) EducateONE shall maintain a record of each program in which a participant is enrolled or otherwise formally participates.

(2) Program enrollment information may include:

(A) the institution, school, program, service, activity, or educational experience;

(B) the participant’s role or roles;

(C) the start date;

(D) the end date, if any;

(E) the current or final status;

(F) changes in role, status, or participation;

(G) withdrawal, completion, transfer, suspension, discontinuation, or other disposition; and

(H) other information reasonably necessary to describe the participant’s relationship with the institution, school, program, service, activity, or educational experience.

(3) A participant’s role shall be recorded separately for each program when the participant performs different roles within different programs.

(f) Attendance.

(1) EducateONE shall maintain attendance records.

(g) Demographic Information.

(1) EducateONE shall maintain demographic information in accordance with EducateONE Organizational Policy § 11.9.00. Demographic Information Collection and Confidentiality.

(2) Demographic information shall be collected, classified, maintained, used, and disclosed according to that policy and any specific legal or regulatory requirement applicable to the participant, institution, school, program, or activity.

(3) Demographic information shall not be treated as qualification information merely because the information concerns a personal characteristic of the participant.

(h) Qualification Information.

(1) EducateONE shall maintain a record of any qualifications a participant has.

(2) Qualification information may include qualifications held before participation in EducateONE and qualifications earned, developed, demonstrated, awarded, verified, or recognized while participating with EducateONE or any controlled EducateONE institution, school, program, service, activity, or operation.

(3) Qualification information may be used for any lawful educational, programmatic, operational, or institutional purpose, including, without limitation:

(A) program placement;

(B) participation in educating or supporting others;

(C) assignment of roles or responsibilities;

(D) recognition of prior learning, experience, or achievement;

(E) determination of readiness or eligibility for a program, role, activity, or opportunity;

(F) documentation of qualifications earned through EducateONE or its controlled institutions; and

(G) other purposes reasonably related to the participant’s involvement with EducateONE.

(4) Qualification records may include information modeled on professional-profile categories made available through LinkedIn or comparable professional-profile systems, including:

(A) experience;

(B) education;

(C) licenses and certifications;

(D) skills;

(E) courses and other learning experiences;

(F) projects;

(G) publications;

(H) patents, inventions, and other original works;

(I) honors and awards;

(J) assessments and test results;

(K) languages;

(L) volunteer experience;

(M) organizational participation and leadership;

(N) recommendations and references; and

(O) supporting evidence, links, files, documents, images, recordings, or other media.

(5) EducateONE shall maintain a full EducateONE transcript for each participant.

(6) The transcript may include qualifications, experiences, achievements, competencies, credits, recognitions, awards, results, and other information documented or recognized by EducateONE or a controlled EducateONE institution.

(7) EducateONE may identify whether qualification information is:

(A) reported by the participant;

(B) reported by another person;

(C) independently verified;

(D) issued or awarded by EducateONE or a controlled EducateONE institution;

(E) demonstrated through participation or performance; or

(F) otherwise documented.

(8) EducateONE is not required to independently verify every qualification unless verification is required by law, contract, accreditation, program requirements, institutional determination, or another binding requirement.

(9) Qualifications may arise from education, employment, independent learning, lived experience, service, projects, performance, leadership, training, licensure, certification, recognition, or any other source.

(i) Collection and Updating.

(1) Participant records may be created or updated from:

(A) information provided by the participant;

(B) information provided by a parent, guardian, authorized representative, educator, evaluator, partner, or other person;

(C) EducateONE’s direct observations or records;

(D) records received from another institution or organization;

(E) qualifications issued, awarded, verified, or recognized by EducateONE or a controlled EducateONE institution; or

(F) another lawful and reasonably reliable source.

(2) EducateONE may permit participants or authorized persons to submit additions, updates, corrections, evidence, or supporting information.

(3) EducateONE may preserve historical information when necessary to maintain an accurate record of prior enrollment, participation, status, attendance, qualifications, or institutional action.

(j) Confidentiality and Access.

(1) Individually identifiable participant records shall be treated as confidential except when access, use, or disclosure is authorized by the participant or authorized representative, reasonably necessary for an institutional purpose, permitted by EducateONE policy, or required by law.

(2) Access to participant records shall be limited to persons with a legitimate educational, administrative, legal, regulatory, safety, accreditation, research, reporting, or institutional need for the information.

(3) Nothing in this policy creates a right of access, correction, amendment, disclosure, confidentiality, or appeal beyond what is required by law or expressly established by EducateONE policy.

(k) Materials Distinguished From Records.

(1) This policy governs participant records.

(2) Courses of study, curricula, instructional materials, brochures, catalogues, advertisements, solicitation materials, publications, and other institutional materials are not participant records merely because they concern, describe, or are used in connection with a participant, institution, school, program, service, or activity.

(3) Materials shall be governed by any separate policy or requirement applicable to those materials.

(l) Retention and Destruction.

(1) Participant records shall be retained and destroyed in accordance with EducateONE Organizational Policy § 11.6.00. Records Retention and Destruction, any applicable institution-specific record-retention policy, and any specific legal, contractual, accreditation, funding, or program requirement.

(2) This policy does not establish a separate retention period for each participant-record category.

(m) Institution-Specific Requirements.

(1) A controlled EducateONE institution may establish additional participant-record requirements when required by law, regulation, accreditation, contract, grant, funding condition, program rule, institutional need, or separate policy.

(2) An institution-specific requirement shall not automatically apply to another EducateONE institution, school, program, service, activity, or operation.

(3) If an institution-specific requirement conflicts with this policy, the more specific binding requirement shall control for the institution, school, program, participant, record, or activity to which it applies.

(n) Interpretation.

(1) This policy shall be interpreted broadly to permit EducateONE to maintain a flexible, person-centered participant-record system that reflects changing roles, nontraditional educational pathways, and qualifications arising from any source.

(2) Nothing in this policy requires EducateONE or any controlled institution to use conventional grade levels, job classifications, personnel structures, student-information systems, or other status-quo educational record models except when a specific binding requirement applies.

(3) EducateONE may establish forms, databases, profile systems, transcript formats, verification methods, and administrative procedures consistent with this policy.

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Source Note

This policy was developed for EducateONE to establish an organization-wide, person-centered participant-record framework recognizing that each participant may function in different roles at different times across EducateONE and its controlled institutions. The qualification categories are modeled in part on professional-profile categories available through LinkedIn and are expanded to include a full EducateONE transcript and qualifications earned, developed, demonstrated, awarded, verified, or recognized through any source.

References

Revenue Procedure 75-50, 1975-2 C.B. 587.

EducateONE Organizational Policy § 11.6.00. Records Retention and Destruction.

EducateONE Organizational Policy § 11.9.00. Demographic Information Collection and Confidentiality.

EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide.