This policy applies to CCLS Houston personnel and student recordkeeping, maintenance, confidentiality, retention, and right of access. 

1. Recordkeeping system and maintenance. 

• CCLS Houston maintains accurate and up-to-date records on its personnel and students, which are stored and secured to prevent unauthorized access. 
• CCLS Houston management audits these records annually to ensure compliance. 
• Access to electronic database (CRM) and physical files is limited to management and authorized administrative members only. 

Personnel files 

• CCLS Houston creates a file for each faculty and staff member at hiring. 
• All personnel are required to report any changes to the Academic Coordinator, who will update the file and inform the President. 
• All personnel are required to inform the Academic Coordinator of participation in professional development events to be included in each file. 
• Personnel files are kept in hardcopy in the Academic Coordinator’s office in a locked cabinet, and a digital encrypted copy is maintained in a cloud storage account accessed only by the President/CEO. 
• Personnel’s contact information is registered in the Customer Relation Management (CRM) system with restricted access by management and the Administrative Operation Specialist. 
• CCLS Houston maintains an updated list of substitute instructors’ contact information. 

Student records 

• Student records policy equally applies to both modalities: in-person students and IDL students. 
• CCLS Houston creates a record for each student who enrolls in our Customer Relation Management (CRM) system with restricted access by management and the Administrative Operation Specialist. 
• Student records include: name and contact information as received in the registration form, placement test (if applicable), attendance logs, score sheets, and student services. 
• Student’s payment records are kept in our bookkeeping and invoice system (Quickbooks). 
• All the information is maintained electronically and backed up daily. 

Provisional clause for F1 students: when granted authorization for enrolling international students: International student records include visa information and Houston address, as required by the Department of Homeland Security. 

2. Privacy and confidentiality 

• All information stored on CCLS Houston’s CRM (Customer Relationship Management) is password protected and for internal use only. 
• Unauthorized reproduction of personnel and students’ records, data, or information is strictly prohibited. 

3. Retention of records 

Personnel files 

• CCLS Houston retains its personnel records for no less than three (3) years after employment ends. 

Student records 

• CCLS Houston retains its students' records (non-international students) for at least three (3) years after the last day of attendance recorded. 

Provisional clause for F1 students: when granted authorization for enrolling international students: CCLS Houston will retain its international students' records for at least three (3) years after the last day of attendance, as required by the Department of Homeland Security. 

4. Access to record information: 

CCLS Houston guarantees personnel and students the right to review their records. 

Personnel files 

• CCLS Houston personnel can request access to review their files with the President/CEO. 
• The President/CEO will authorize the release of this information to current personnel within (5) five business days. 
• Former personnel can request access to their records up to 2 years after their employment ends. The President/CEO will authorize the release of this information within 10 business days from the date of request. 

Student records 

• CCLS Houston students can request access to review their records to the Academic Coordinator. 
• The Academic Coordinator will authorize the release of this information within 5 business days to current students. 
• Former students (except international students) can request access to their records up to 3 years after the last day of attendance. The Academic Coordinator will authorize the release of this information within 10 business days from the date of the request. 

Provisional clause for F1 students: when granted authorization for enrolling international students: Former international students can request access to their records up to 3 years after their last day of attendance. The Academic Coordinator will authorize the release of this information within 10 business days from the date of the request. 

This policy, while previously implemented in practice, becomes officially effective during the second semester of 2025. 

This policy is subject to periodic review and may be updated as necessary. Any updates must be approved by the President as specified in CCLS Houston’s Policy for Institutional Policy Development. 

Updated/ Approved: CT 04/15/25