Statement of Rationale for Judgment of Compliance

Palo Alto College offers distance education and documents each of the following requirements under Federal Requirement 4.8:

1. Demonstrates that the student who registers in a distance or correspondence education course or program is the same student who participates in and completes the course or program and receives the credit by verifying the identity of a student who participates in class or coursework by using, at the option of the institution, methods such as (a) a secure login and pass code, (b) proctored examinations, or (c) new or other technologies and practices that are effective in verifying student identification. (FR 4.8.1)
2. Has a written procedure for protecting the privacy of students enrolled in distance and correspondence education courses or programs. (FR 4.8.2)
3. Has a written procedure distributed at the time of registration or enrollment that notifies students of any projected additional student charges associated with verification of student identity. (FR 4.8.3)

Identify Vertification

Palo Alto College (PAC) verifies the identity of students in distance education classes in various ways including a secure login and password, biometric signatures and proctored examinations.  The College does not conduct correspondence courses.

Palo Alto College uses the Alamo Colleges Educational Services (ACES) portal (See Login and Password documentation[1]), a secure environment which is based on the Banner by Ellucian Luminis Platform (Banner). The ACES portal provides a single login to web services, which provides access to, among other functions, all online courses.  All online courses use the Instructure Canvas Learning Management System (Canvas). At the time of registration, students are assigned a unique ACES username and a secure password which is required to access their online courses (See ACES Login Instructions[2]). The student is then prompted to change the password at first login.

In addition to the secure login necessary for access to online courses, all instructors of online courses are required to use Biometric Signature ID (BioSig-ID), an identity verification software. BioSig-ID is a web-based software that uses gesture biometrics to identify students in online courses.  BioSig-ID is integrated into Canvas, and the student’s identity must be verified at least three times per course (See Biometric Signature documentation[3]).

In addition, faculty may require their online students to take proctored exams.  Proctored exams for online students may be taken on campus or online. The exams taken on campus are conducted in the Palo Alto College Testing Center, free of charge to Palo Alto College students. Students must provide a valid form of identification at the time of the exam and testing instructions are visibly posted at the Testing site (See Distance Exam process[4]). If the student is unable to visit the campus, they may have the option to take the assessment online from home, free of charge, using Respondus Monitor (See Respondus Monitor[5]), a proctoring software platform. Respondus Monitor uses webcam and video technology to record students during an exam and tracks instances of irregular movements. Students verify their identity by displaying a valid form of identification to the camera before taking the exam. When the exam is complete, the instructor has access to the video and a report of any suspicious behavior for evaluation (See Respondus Monitor Instuctor Sample[6]). In addition to Respondus, instructors may work with assessment centers at other locations to provide proctored exams for online students who have access to that site.

Protecting the Privacy of Students

Palo Alto College protects the privacy of all students, including distance learning students, through strict adherence to the rules of the Family Educational Rights and Privacy Act of 1974 (FERPA). The FERPA statement is available for student and public view through the Palo Alto College catalog (See Catalog FERPA statement[7]).  Palo Alto College board procedures are in place to protect the privacy of all students, including those enrolled in distance education.  These procedures define appropriate access to particular data and proper use of information technology resources (See F.4.1.1 Procedure[8], Board Policy C.1.9[9] and Procedure C.1.9.1[10]).

Palo Alto College uses Banner, a secure student information management system, to view, store, secure, and manage critical student and employee information. Access is restricted to employees that have direct job responsibilities that necessitate access to student information, ranging from human resources to student registration and financial aid processes. Employees in these positions gain access only after the employee has received the appropriate Banner training and has completed the Banner user access process (See INB Banner User Access Management V1.6[11]).

Notification of Additional Charges

Palo Alto College does not charge additional fees for verification of student identity; therefore, there is no written procedure to notify students.

As articulated in Board Policy A.1.1[12], the College District is known by the assumed names of “Alamo Colleges” and “Alamo Colleges District” or the “Alamo Community College District.” References to these assumed names in the narrative and any supporting documentation are equivalent.