Using Turn It In at UCLA

Jack Bishop, Ph.D. UCLA, Office of Instructional Development

December 2006

Technologically-assisted academic dishonesty has rightfully attracted much attention among educators over the past decade as new technologies emerge that enable students to “get over” by using them to short-cut the effort normally associated with passing courses. Technologies such as the Internet, cell phones, programmable calculators, pagers and Ipods are luring students away from often arduous academic work and toward the “easy path” to success. One of the most serious problems is student plagiarism on term papers. Plagarism detection was the impetus behind the creation of Turnitin.com, just one of the many technologies designed to counteract this phenomenon. Turnitin was designed as a brake against the rising incidents of technologically-enhanced academic dishonesty such as buying papers outright on “cheat sites,” “essay mills,” copying and pasting the majority of a paper’s content from online sources, or simply re-using papers previously submitted (either by themselves or by other students). Without the aid of an electronic database with which professors could compare papers, challenging the originality of a paper could be a very difficult endeavor. Below, I first present an overview of using Turnitin.com, and then I present an argument that examines the implications of using such a system. During the fall quarters at UCLA, I instruct a lower division course in the Department of Ethnomusicology called “Global Pop.” The course draws between 80 and 90 students. In the previous fall quarter I assigned a rather lengthy research paper and at the end of the quarter I sat down to read all of them one by one. Receiving eighty 16-20 page papers meant that I had the pleasure of reading through 1,200-1,600 pages, and making corrections, before I could turn in the grades. Now, I love to read student papers, but as I read, I felt the eerie feeling that I had previously read some of the ideas elsewhere. As an ethnomusicologist, I have read an incredible amount of writings about music, and although the exact original sources may have escaped me, I knew I had read similar words elsewhere. Since my students were not music majors, and in many cases my course was the first music course they had taken, the sophistication of the analyses seemed disjointed from the sources. But, alas, not having utilized the Turnitin feature on the MyUCLA website, checking the originality of the papers became a very daunting task. During the current fall session, learning from my mistake, and having assigned a paper based upon internet research, I decided to give Turnitin a try. Part One: What Turnitin Does Turnitin allows students to submit their written assignments online. On the students’ MyUCLA web page, there is a link to Turnitin under each course in which the student is enrolled. Upon clicking that link the student is taken to the Turnitin “homepage” for that class (if the instructor has set one up). There, the assignment(s) are listed with a submit icon for each. When the student clicks the “submit” icon she is taken to a page where she

chooses her name from a drop-down menu. Once she selects her name she is then asked to enter the paper title. Finally, she is asked to click on the “Browse” button which then allows her to point to the file on her computer. Once the correct file has been located, the student clicks the “submit” button and the file is uploaded to the Turnitin database. That’s all there is to it. The submissions go into the Turnitin database and are compared to the existing papers in its database and returns to the instructor an “originality report” which highlights strings of text that match other documents. The originality reports “are based on exhaustive searches of billions of pages from both current and archived instances of the internet, millions of student papers previously submitted to Turnitin and commercial databases of journal articles and periodicals” (Turnitin.com 2006). For each paper submitted Turnitin generates an “originality report” that rates the amount of text matching source files in the database on a scale from 0 to 100 percent. The report is presented in a very intuitive and detailed manner which allows the instructor to spend valuable time addressing the causes of the plagiarism rather than searching for the plagiarized sources.

Figure 1

Turnitin Originality Report When the instructor enters the homepage for the course, he will see the assignment(s) and an icon beside each named “inbox.” Clicking that icon reveals the roster of enrolled students and the status of their submissions. It will either say “no submission” or it will

2

have the title of the students’ paper. To the right of the paper title is a color-coded report icon that reports the percentage of material in the students’ papers that matches other sources. By clicking on that report icon, the instructor can then see the entire originality report. (Please see Figure 1 above). After clicking on the originality report icon in the student roster, the instructor is presented with a new window which displays the originality report. The report is divided into essentially three areas: the header, the student paper and the list of matched sources. Let’s begin with the header.

Figure 2 Turnitin Originality Report Header

The header contains a great deal of information such as the paper title, the student’s name, the date and time the paper was processed, the paper identification number and the word count. There are also links to “print,” “save” and “refresh” the reports, “prefs” (display preference settings for the originality report), and a link for “help.” (The image in Figure 2 does not show the “prefs” link). Additionally, there are links to move to the originality reports for the “previous” or the “next” paper according to the list in the student roster. In the gray bar that separates the header from the rest of the report you will find the “Overall Similarity Index,” which displays the percentage of similarities between the students’ papers and outside sources, including its accompanying color code. To the right of this similarity index are two links that allow the instructor to exclude quoted materials and the bibliographic information. The instructor should only click on these links after reviewing the paper to determine that the quotes are properly cited and the bibliography is correct. Once these things are determined, the instructor can eliminate the quoted materials and bibliographies from the comparison. (Once these links are engaged expect the “Overall Similarity Index” to drop, often significantly). To the right of those links is a drop down “mode” menu that allows the instructor to investigate the suspect sources one at a time or all together. There is also an option to view the paper in what is known as a “quick view” or “classic” report. I have found that the “show highest matches together” option presents the instructor with the most efficient means of verifying the paper’s content and checking suspect sources. Below the header and the gray bar are two windows, or the body of the report. The window on the left displays the student paper and the window on the right displays the matched sources. When Turnitin detects similarities between the student paper and an outside source, it bolds the text, turns the text to red, places it in a highlighted box and assigns it a number. That number corresponds to an entry in the window on the right side, which is where Turnitin displays suspect outside sources. The sources are listed

3

according to the percentage of the match with the highest percentage coming first. When the instructor mouses over the highlighted text in the student’s paper the corresponding source on the right illuminates letting the instructor have a quick view of the suspect source. When the instructor clicks on the numbered text box in the student’s paper a “Direct Source Comparison” window appears displaying the matching text within the context of the suspect source. The matching text is blocked out and highlighted as in the student’s paper for easy comparison.

Figure 3 Turnitin Originality Report Body with Direct Source Comparison Window

The “Direct Source Comparison” window offers a link to the source as it appears on its original web page and “up” and “down” scroll arrows to see the previous or next matching text. (In Figure 3 above, you will find an image of the body of the Originality Report, including the “Direct Source Comparison” window). If the matching text is not from the web, but is from a student paper previously submitted through Turnitin, the instructor is presented with the following message: “Because submitted papers remain the intellectual property of their authors, instructors, and respective institutions, we are unable to show you the content of this paper at this time.” If the instructor stills wants to view the paper he may click on the button “Send a Request to View This Paper.” Upon clicking the button a request is sent to the student’s school and the instructor who handle such requests on a case-by-case basis. (Usually, they give their permission and within two days or so the instructor receives an email with the entire contents of the student’s paper). By checking the suspect sources an instructor can decide whether the matching text is used in properly cited passages within the text. If this is the case, then it is safe to click on the “exclude quoted” link in the gray bar of the header that will then re-access

4

the paper and return a new originality report. If the student papers’ “references” or “bibliography” sections are causing matches, the instructor may choose to remove them from the comparison by clicking the “exclude bibliography” link which will also re-access the paper and return a fresh originality report. As mentioned, if the instructor chooses one, or both, of these links the “Overall Similarity Index” should drop significantly. The new report will more accurately reflect the amount of plagiarized material in the students’ papers. At UCLA, we have access to two of Turnitin’s five main functions, plagiarism detection and the discussion board. (The others, “Peer Review,” “GradeMark” and “GradeBook” are presented briefly below). The discussion board is a very useful tool that allows students to submit and respond to topic postings. In my course, the discussion board was utilized to engage students in online dialogues about complicated issues pertaining to the global dissemination of music such as, issues of copyright, appropriation, adaptation, transculturation, cross-cultural use of sound, and globalization. For the purposes of this course, the discussion board was a mandatory weekly activity. The discussion board was not moderated, which meant that when the student posted a comment, it did not need the approval of a moderator and was immediately viewable on the web. However, if there is a posting that the instructor deems inappropriate he has the ability to delete it from the thread. Using the discussion board feature helped create a sense of community among the students of my class and gave them the opportunity to share interesting information with their peers (and me). It also provided an extremely useful format for discussing the weekly required readings, which alleviated much of the time spent doing so in class, allowing me to better concentrate on delivering the lessons. While UCLA Humanities and Social Sciences have their own course management systems (CMS), which include discussion boards, the School of Arts and Architecture has no such support. With the availability of the Turnitin discussion board, this problem is solved without the school having to invest in the IT equipment and support personnel to offer this service to its departments. What Else Does It Do? As mentioned, aside from their plagiarism check function, Turnitin.com offers a host of other tools, that, when used properly can significantly enhance student learning and help build a sense of community among students, especially in larger classes. However, due to the licensing agreement, these services are currently unavailable to the UCLA community. Below, I offer a brief overview of these functions and their usefulness. Peer Review is another feature of the Turnitin service by which the instructor can create assignments that incorporate a collaborative learning environment through which students “are encouraged to evaluate the writing decisions made by others” which allows students to “develop the critical thinking and editorial skills that translate into increased effectiveness in their own writing” (Turnitin.com 2006a). Additionally, having the students edit one another’s papers lends an air of openness and community to the course, which can promote real-life friendships.

5

GradeMark is Turnitin’s Digital Markup Solution for correcting and making revision suggestions to students’ papers. Unlike the current method of marking comments directly on the student’s paper with a pen, GradeMark allows the instructor to make comments of any length at any point in the paper. “Gone are the days of scrawled red ink in tiny margins, arrows leading to notes on other pages, and incomprehensible typographical marks” (Turnitin.com 2006b). By creating “rubrics” Turnitin categorizes and stores the comments for the instructor to use on other papers. For example, if the instructor creates a rubric for “Incomplete sentence, please revise,” every time the instructor encounters such a problem in other papers the instructor can apply the rubric rather than re-type the comments. After organizing the rubrics, the time spent correcting papers is reduced dramatically. Once the instructor has marked up the paper, the student can then see the comments on the Turnitin web site. They can then retrieve the paper make the corrections and resubmit it for final grading. GradeMark is a paperless grading system that, aside from providing increased efficiency and flexibility, the instructor is able to identify problems that might be common to the entire class, allowing future lessons to be tailored toward the elimination of such problems. GradeBook is Turnitin’s new online grading system. Although this service is unavailable to the UCLA community, I will provide a very brief overview of its functions. Any assignments completed through Turnitin such as peer reviews or submitting essays are automatically entered in the Turnitin GradeBook. The GradeBook can also serve as a convenient place to keep track of student absences and tardiness. GradeBook is entirely customizable to fit any existing grading format and it is easy to adjust base percentage values to match those used in the instructor’s institution. Differently weighted assignments are no problem. Additionally, GradeBook can display result graphs for a quick view of class progress and can be downloaded in an Excel spreadsheet for archiving or administrative purposes. Overall, the usefulness of GradeBook to UCLA instructors is questionable since the Registrar requires grades be submitted through the Gradebook on the instructor’s MyUCLA web page. The entire suite of Turnitin tools integrates seamlessly with the class the management systems Blackboard, WebCT, Angel and Moodle. Limitations to Turnitin Turnitin has some very serious limitations to its ability to fully detect plagiarism. For one thing, Turnitin can only detect the most blatantly copied text. It cannot detect cleverly paraphrased passages, or copied text that has been vastly altered by the student’s use of a thesaurus. It is also ineffective for detecting works that have been written by another student, person or a “ghost writer,” unless more than one student submits the paper. Turnitin cannot distinguish between text that has been properly quoted and cited and text that has not. Subsequently, it returns an inaccurate originality report. Turnitin often returns a report of unoriginality for paper headers, and bibliographies. Therefore, the initial plagiarism percentage rating cannot be used as a trustworthy indication of the degree of plagiarism. Using an example from my course: one student posted a paper that received an initial score of 64% plagiarized, but upon inspecting the paper I saw the majority of the matches came from properly quoted material and the references cited

6

section. After checking the accuracy of the citations and references, I excluded them from the match and the paper returned a score of two percent. Additionally, many students participate in online forums that store the comments in a database and display them in a thread. Often, Turnitin will incorrectly match disparate and disjointed sections of that thread to the students’ papers, or will return a plagiarism report for students who are actually quoting themselves. Further, there are several web sites that offer effective methods of circumventing the plagiarism detection of Turnitin. One site described how to use the macros function in Microsoft Word to “fool” the service. For example, the student could submit a plagiarized paper in which every letter ‘a’ is accompanied by a tilde, i.e., ‘a~.’ The Turnitin service would fail to detect the plagiarism since the original documents do not contain the tildes. Then the student could submit the same paper to the professor with the macros enabled that would instantly switch the ‘a~’ to an ‘a’ upon opening the document. In such an instance, the instructor would never see the tildes and relying upon the originality report returned by Turnitin, would accept the paper as an original. Further, knowing that there are many anti-plagiarism robots crawling the web, so-called “cheat sites” or “essay mills” that sell term papers outright do not keep the essays in a searchable database. Therefore, papers purchased from such sites could return false reports of originality. Along these same lines, a webmaster could post a “robots.txt” file in the root folder of their websites, which would prevent the “TurnitinBot” from crawling and caching the contents of their web site(s). Another less-pressing concern is that since it is entirely web-based, if your network experiences connectivity problems, the service would not be available until such issues are resolved. More importantly, the use of Turnitin could compromise the instructor’s own grading criteria. Upon reading a paper, an instructor might judge it to be original and give it a high mark. However, after submitting the paper to Turnitin and viewing the originality report, the instructor would most likely lower the grade and even confront the student. Additionally, using the service places an emphasis on policing student behavior and has the ability to shift the instructor’s attention away from teaching good writing skills and ways to avoid plagiarism. Although I am certain that there are numerous other pitfalls to using Turnitin, one of the most serious problems may be found in the way instructors use it. It is a very dangerous practice to judge a paper by the originality report alone, although that is how many instructors have utilized the service. By reading a hard copy of the paper (on which they make their corrections and edits) and relying on the originality report alone to assure the absence of plagiarism the instructor treads on very thin ice. Finally, I found Turnitin to be a very contentious service which walks a balancing beam between fair and legal use of student papers and infringements on the students’ right. I will explore the implications of this in part two of this report. Part Two: Exploring the Controversy Surrounding the Use of Turnitin Some of the controversy surrounding the use of Turnitin lies in the very nature of the service. By storing the uploaded papers in order to expand its database for comparison to new submissions, Turnitin is potentially violating the students’ copyrights and right to privacy. By enlarging the database Turnitin can offer a more comprehensive search of documents, making their service more valuable, without offering compensation to the

7

students whose intellectual properties make up that database. This practice presents some rather interesting legal and ethical issues. First, the Family Education Rights and Privacy Act of 1974, (FERPA), is a federal law that protects the privacy of student education records. Under FERPA, student records include: written documents, computer media, microfilm and microfiche, video or audio tapes or CDs, film, and photographs (Van Dusen 2004). “Any record that contains personally identifiable information that is directly related to the student is an educational record under FERPA” (Ibid.). FERPA prohibits the dissemination, or use, of student records without the express written consent of the student. When Turnitin copies, or makes a “digital fingerprint” (as they call it), of the student paper in its entirety to its database it potentially violates student rights under FERPA. Often, instructors submit the students’ papers for plagiarism checks without the knowledge or consent of the students, which is potentially a violation of the students’ privacy. Many instructors sidestep this potential violation by having their students upload their own papers, which can be seen as the student giving tacit permission to the service to copy and use their intellectual property. However, when an instructor makes submitting the papers directly to Turnitin a mandatory requirement of the class the student has no choice but to comply. Under such circumstances the students are being coerced into giving up their intellectual property to a third-party vendor who then uses it to generate private profits. According to Kenneth D. Crews, a professor at the Indiana University School of Law, instructors should, “Let them [the students] know what you’re doing and give them a chance to opt out. In fact, some professors may feel more secure using the service only after obtaining a definitive go-ahead from students” (Foster 2002). Similarly, the University of California at Berkeley has decided to not subscribe to the service. Assistant Chancellor for Legal Affairs Mike R. Smith cites, “We take student intellectual-property rights seriously, and that became one of the trouble spots for us in moving ahead with this proposal” (Ibid.). Turnitin, of course, denies these legal claims and asserts that the service operates legally under the current copyright laws and does not violate FERPA. By removing identifiable information that links the student to the paper in its database, Turnitin has technically circumvented the statutes of FERPA. However, it cannot get around the very simple issues of copyright and intellectual property infringement that easily. Let’s recall Turnitin’s previously stated policy of not displaying student papers: “Because submitted papers remain the intellectual property of their authors, instructors, and respective institutions, we are unable to show you the content of this paper at this time.” However, a simple click on the “Send Request to view this Paper” button and within days the entire text is sent to the requesting instructor by the originating instructor. The student information is expunged, but every word of the original paper is in the body of the email that the requesting instructor receives. Turnitin claims that the intellectual property of student papers belongs to the “authors, instructors, and respective institutions,” which is technically untrue. When a student writes an assigned essay, the intellectual property of that work belongs to the student. However, when an instructor sends a request to view a student paper, it is the instructor, or institution, not the student, who typically approves the request. The instructor or institution has no legal authority to grant license to anyone else to view, copy or transmit this paper. And to the best of my knowledge, the result of quite exhaustive research, the student is never consulted.

8

Dan L. Burk, a professor at the University of Minnesota Law School specializing in intellectual property says, “To run a database, you've got to make a copy, and if the student hasn’t authorized that, then that’s potentially an infringing copy” (Ibid.). Therein lies the hypocrisy of Turnitin, which violates authorial integrity in order to teach students that violating authorial integrity is wrong. Second, from a pedagogical perspective, I inherently trust my students and do not instantly suspect them all of potentially cheating on written assignments without some evidence that they have engaged in such practices in the past. I have found through experience that the vast majority of students do not engage in cheating, and, therefore, automatically requiring all students to submit their papers to Turnitin sends the message that the instructor sees the students as “guilty until proven innocent.” Needless to say, this is contradictory to the values and rights upon which this nation was founded. Students should not lose their constitutional rights simply because they have enrolled in an institution of higher learning. In my courses, I do everything in my power to foster an open, community atmosphere based on trust and mutual respect. Assigning the students to use Turnitin presented a contradiction in my own classroom philosophies. When I announced to the class that I wanted to use the service, since the assigned project was internet-based research, I was met with the most demoralized look on my students’ faces. Finally, someone chirped out, “Why, don’t you trust us?” While I skated around the question fumbling for a positive response, the only honest answer I could offer was, “Apparently not.” Finally, in today’s litigious environment where students (and universities) are being sued by the music industry for illegally using the intellectual property of others without consent and compensation, it seems very hypocritical to expect students to relinquish their intellectual properties for others to use, in this case for profit, without their consent or without the students receiving some form of compensation. This absolutely contradictory message tells the student that their rights are not as important as those of big business. They are being told that they are forbidden to download and use the IPs of the entertainment industry for their personal, not-for-profit use, but that it is acceptable for a big company to take and use their IPs for private gains. From time to time we have to stop and consider what lessons we are actually teaching our students. Toward a Less Controversial Use of Turnitin At UCLA, the Registrar has issued an official notice endorsing an instructor’s use of anti-plagiarism services such as Turnitin to maintain academic integrity (UCLA Registrar). According to that notice, “Turnitin is just one tool instructors can use to promote academic integrity. It works best as a preventative measure, when announced to students at the beginning of a term and made a required part of the course. The idea is to take away the temptation to cheat” (Ibid.). Working from this model the instructor is put in the position of policing, and attempting to control, student behavior by “threatening” them with the required use of the Turnitin service. To date, there is no data available that supports this method as an effective deterrent.

9

A much more effective way of achieving the same goal might be to develop an atmosphere of respect, honesty and academic integrity in the classroom. By bestowing their trust upon students, the instructors stimulate the students’ sense of self-esteem, which in turn stimulates the students’ sense of well-being that they often work hard to maintain. If there are a few “bad apples” in the bunch, they will make themselves known. In my experience this has had a far more positive effect on the students in the class than treating them all as “guilty until proven innocent” plagiarists. In addition, instructors could easily cover the concepts of research and citation methods that they expect to be used, including some rules and examples of how and when to cite sources. Finally, there is no substitute for good, hands-on, teaching methods like being available and approachable when students need help with written assignments. I have heard more than a fair share of students complain that their other instructors are inattentive and unapproachable. For detached instructors, using Turnitin to verify the originality of their students’ papers can present a nightmare since Turnitin’s initial originality report is rarely accurate. After using Turnitin as an instructor, I came away with the feeling that it was a somewhat unnecessary and nearly useless service, especially since the full suite of tools is not available to the UCLA community. If it were, then Turnitin could be a suite of tools to enhance education rather than a service primarily directed at catching “cheaters.” With the full suite, instructors could use them to foster a stronger feeling of community among the students through the use of Peer Review and the Discussion Board. The plagiarism detection aspect of Turnitin could also be utilized as an effective Self Review for students to check their own work before handing it in for a grade. Using Turnitin in this way would most likely yield a higher quality of paper, and a more positive learning environment than the method that uses the threat of Turnitin as a deterrent. From an ethical, if not legal, point of view I also find something intrinsically wrong about using the uncompensated intellectual properties of students to build a database with which a private corporation makes tens of millions of dollars per year. The Turnitin plagiarism service would be far less controversial and far fairer to the students if it were possible to configure the service to not store the students’ papers in its database for comparison. At the very least, since it is the intellectual property of the students we are discussing, they should have the final approval on how their material is used after submission. Ideally, they should be given the opportunity to opt-out of the service. To protect themselves, students who opt-out could attach a copyright notice to their papers that would prevent instructors and institutions from submitting their papers to Turnitin’s database.1 If the copyright notice is ignored, the student can file suit against her school and against Turnitin.com for up to $150,000 per incident under the provisions of the Digital Millennium Copyright Act (DMCA). “Academic integrity is a commitment, even in the face of adversity, to five fundamental values: honesty, trust, fairness, respect, and responsibility. From these values flow principles of behavior that enable academic communities to translate ideals into action”

10

(UCLA Library 2006). In the ideal academic environment these values flow in both directions: from the students to the instructors, and from the instructors to the students. By making Turnitin a mandatory requirement for students, instructors instantly violate the first four, and possibly all five of these values. It is important to remember that while we are striving to maintain academic integrity among the vast minority of students who engage in unscrupulous practices we must not sacrifice the quality of the educational environment for the majority who do not. Notes

1. The following is an example of a copyright notice that is offered to students online at www.essayfraud.org: Copyright 2006 [STUDENT NAME]. All Rights Reserved. Aside from my professor’s sole, personal review as part of his/her private, single-human, software-free grading process (checking for plagiarism with Google is acceptable), neither my professor nor my academic institution may otherwise copy, transfer, distribute, reproduce, publicly/privately perform, publicly/privately claim, publicly/privately display, or create derivative works (including “digital fingerprints”) of my copyrighted document (intellectual property). The same restrictions apply to Turnitin.com and all similar services if my document should somehow come into their possession. Neither my professor nor my academic institution may submit my copyrighted document, in whole or in part, to be copied, transformed, manipulated, altered, or otherwise used by or stored at Turnitin.com (iParadigms, LLC) or any other physical or electronic database or retrieval system without my personal, explicit, voluntary, uncoerced, written permission. Regardless of supposed intent (e.g., “to create a digital fingerprint”), no part of my copyrighted document may be temporarily or permanently transferred, by any party, to Turnitin.com or any other service, program, database, or system for analysis, comparison, storage, or any other purpose whatsoever. Violators will be monetarily punished to the fullest extent allowed by the DMCA (Digital Millennium Copyright Act) and/or international law.

11

References Cited Essayfraud.org. 2006. “Guilty Until Proven Innocent: The Well-Known Secret About

Turnitin.com.” <http://www.essayfraud.org/turnitin_john_barrie.html#1> Accessed December 13, 2006.

Foster, Andrea L. 2002. “Plagiarism-Detection Tool Creates Legal Quandary.” Chronicle

of Higher Education, Section: Information Technology, p A37, March 17. Turnitin.com. 2006. “Plagarism Prevention”

<http://www.turnitin.com/static/plagiarism.html> Accessed November 20, 2006. Turnitin.com. 2006a. “Peer Review” <http://www.turnitin.com/static/peerreview.html>

Accessed November 20, 2006. Turnitin.com. 2006b. “GradeMark” <http://www.turnitin.com/static/grademark.html>

Accessed November 20, 2006. UCLA Library. 2006. “Academic Integrity and UCLA Policies.”

<http://unitproj1.library.ucla.edu/col/bruinsuccess/05/03.cfm> Accessed December 12, 2006.

UCLA Registrar. 2006. “Offical Notices.” <http://www.registrar.ucla.edu/soc/notices.htm#AnchorPlag> Accessed December 13, 2006.

Van Dusen, William R., Jr. 2004. “FERPA: Basic guidelines for faculty and staff a

simple step-by-step approach for compliance.” Retrieved December 7, 2006 from the NACADA Clearinghouse of Academic Advising Resources Web site: <http://www.nacada.ksu.edu/Resources/FERPA-Overview.htm>.

12