Requestor
anonymous parent
Requested Information
### I. Records Related to Counselor / Student Services Training on December 18, 2025
Please produce any and all records related to training provided on or about **December 18, 2025**, to **school counselors and/or student services staff members** employed by the Howard County Public School System (“HCPSS”), including but not limited to:
1. Agendas, outlines, schedules, or session descriptions;
2. Presentation materials, slides, handouts, talking points, scripts, or reference documents;
3. Notes taken by presenters, facilitators, or attendees;
4. Written guidance, memoranda, or follow-up communications summarizing or clarifying the content of the training;
5. Emails or other communications planning, approving, organizing, or discussing the training, whether before or after December 18, 2025.
This request includes records maintained in any format, including email, electronic documents, shared drives, learning management systems, or messaging platforms.
### II. Records Concerning Direction or Guidance to Use Student ID Numbers in Place of Student Names
Please produce any and all records reflecting **direction, guidance, instruction, or training** provided to school counselors, student services staff, or other HCPSS employees regarding the practice of **using student identification numbers instead of student names in internal email communications or other written communications**, including but not limited to:
1. Policies, procedures, guidance documents, or memoranda (formal or informal);
2. Training materials or presentations addressing this practice;
3. Emails or internal communications announcing, explaining, or reinforcing this practice;
4. Drafts of such documents;
5. Communications discussing compliance with FERPA, the MPIA, or other privacy or records-access considerations in connection with this practice.
### III. Records Reflecting Authorization, Decision-Making, and Rationale
Please produce records sufficient to identify:
1. **Who authorized, approved, or directed** the implementation of the practice described above, including names, titles, and offices;
2. **When** the decision was made and **whether it was implemented system-wide or limited to certain schools or departments**;
3. The **reason(s), justification(s), or rationale(s)** for adopting this practice, including any discussion of:
* Student privacy;
* Internal email security;
* Public records requests;
* Parental access to student-related records;
* Administrative burden or record retrieval considerations.
### IV. Records Addressing Parental Access and Public Records Implications
Please produce any records that discuss, analyze, or reference how the use of student ID numbers rather than student names in internal communications may affect:
1. A parent’s or guardian’s ability to identify and request records relating to their own child under the MPIA;
2. HCPSS’s obligations to conduct reasonable searches for records responsive to MPIA requests;
3. Transparency, accountability, or record-keeping practices involving student-specific communications.
This request specifically seeks records that go beyond generalized statements and reflect actual consideration, analysis, or discussion of these issues.
### V. No Board Policy
If this practice was implemented **without formal Board of Education policy**, please produce records explaining why no Board policy was sought or adopted, and identifying the authority relied upon to implement the practice administratively.
Please produce any and all records related to training provided on or about **December 18, 2025**, to **school counselors and/or student services staff members** employed by the Howard County Public School System (“HCPSS”), including but not limited to:
1. Agendas, outlines, schedules, or session descriptions;
2. Presentation materials, slides, handouts, talking points, scripts, or reference documents;
3. Notes taken by presenters, facilitators, or attendees;
4. Written guidance, memoranda, or follow-up communications summarizing or clarifying the content of the training;
5. Emails or other communications planning, approving, organizing, or discussing the training, whether before or after December 18, 2025.
This request includes records maintained in any format, including email, electronic documents, shared drives, learning management systems, or messaging platforms.
### II. Records Concerning Direction or Guidance to Use Student ID Numbers in Place of Student Names
Please produce any and all records reflecting **direction, guidance, instruction, or training** provided to school counselors, student services staff, or other HCPSS employees regarding the practice of **using student identification numbers instead of student names in internal email communications or other written communications**, including but not limited to:
1. Policies, procedures, guidance documents, or memoranda (formal or informal);
2. Training materials or presentations addressing this practice;
3. Emails or internal communications announcing, explaining, or reinforcing this practice;
4. Drafts of such documents;
5. Communications discussing compliance with FERPA, the MPIA, or other privacy or records-access considerations in connection with this practice.
### III. Records Reflecting Authorization, Decision-Making, and Rationale
Please produce records sufficient to identify:
1. **Who authorized, approved, or directed** the implementation of the practice described above, including names, titles, and offices;
2. **When** the decision was made and **whether it was implemented system-wide or limited to certain schools or departments**;
3. The **reason(s), justification(s), or rationale(s)** for adopting this practice, including any discussion of:
* Student privacy;
* Internal email security;
* Public records requests;
* Parental access to student-related records;
* Administrative burden or record retrieval considerations.
### IV. Records Addressing Parental Access and Public Records Implications
Please produce any records that discuss, analyze, or reference how the use of student ID numbers rather than student names in internal communications may affect:
1. A parent’s or guardian’s ability to identify and request records relating to their own child under the MPIA;
2. HCPSS’s obligations to conduct reasonable searches for records responsive to MPIA requests;
3. Transparency, accountability, or record-keeping practices involving student-specific communications.
This request specifically seeks records that go beyond generalized statements and reflect actual consideration, analysis, or discussion of these issues.
### V. No Board Policy
If this practice was implemented **without formal Board of Education policy**, please produce records explaining why no Board policy was sought or adopted, and identifying the authority relied upon to implement the practice administratively.
Date Received
Status
Complete
Response Notes
Responsive to this request, and per clarification “I want the records from the meeting where Counselors were specifically told not to use student names but to use their student ID numbers. December of 2025 is when this new ‘policy’ was started. I definitely want the records involved in this decision and training specifically mentioned in ‘II’, ‘III’ and ‘IV’ of the request,” as well as clarification on communications sought, we have provided the records below.
Responsive Documents
This meeting was identified by Office of Student Well-being staff as including a discussion of email privacy with school system middle school counselors. Please note, a meeting held December 18, 2025, between school counselors and psychologists included no mention of/documentation related to use of student ID numbers.
This communication to middle school counselors explained the above mention of “email privacy” in the November counselors session.
To address follow-up seeking “the name who created the slides for the 11_12 11_13 Middle school counselor meeting. I would like a copy of all emails to and from this person's HCPSS email address for the dates between 10/01/25 and 11/12/25 that address any of the follow Topics/subtopics,” we initially conducted the following search using the key phrases provided:
• Date Range
o Between October 1, 2025 and November 12, 2025.
• Mailbox Locations
o Kami Wagner
o Andrea Portnoy
o Liz O'Connor
• Keywords
o “Student privacy”
o “Student data privacy and confidentiality”
o “Protection of student personally identifiable information (PII)”
o “FERPA compliance and student records privacy”
o “Policies or discussions regarding student privacy rights”
o “Handling, disclosure, or safeguarding of student information”
o “Internal email security”
o “Email system security and access controls”
o “Internal communications security”
o “Protection of agency email systems”
o “Email retention, monitoring, or access policies”
o “Cybersecurity or information security relating to email”
o “Public records requests”
o “Public records / FOIA / MPIA (added as the state open records act) request handling”
o “Open records compliance”
o “Processing, responding to, or managing public records requests”
o “Records disclosure obligations”
o “Freedom of Information Act or state open records law requests
o “Parental access to student-related records”
o “Parent or guardian access to student records”
o “Release of student records to parents”
o “Parental rights regarding educational records”
o “Requests by parents for student information”
o “Disclosure of student records to parents or guardians”
o “Disclosure of staff emails to parents or guardians”
Which resulted in the attached results. Please note, further review would be needed to determine releasability of all links and/or external records noted within the responsive email content itself.
• Date Range
o Between October 1, 2025 and November 12, 2025.
• Mailbox Locations
o Kami Wagner
o Andrea Portnoy
o Liz O'Connor
• Keywords
o “Student privacy”
o “Student data privacy and confidentiality”
o “Protection of student personally identifiable information (PII)”
o “FERPA compliance and student records privacy”
o “Policies or discussions regarding student privacy rights”
o “Handling, disclosure, or safeguarding of student information”
o “Internal email security”
o “Email system security and access controls”
o “Internal communications security”
o “Protection of agency email systems”
o “Email retention, monitoring, or access policies”
o “Cybersecurity or information security relating to email”
o “Public records requests”
o “Public records / FOIA / MPIA (added as the state open records act) request handling”
o “Open records compliance”
o “Processing, responding to, or managing public records requests”
o “Records disclosure obligations”
o “Freedom of Information Act or state open records law requests
o “Parental access to student-related records”
o “Parent or guardian access to student records”
o “Release of student records to parents”
o “Parental rights regarding educational records”
o “Requests by parents for student information”
o “Disclosure of student records to parents or guardians”
o “Disclosure of staff emails to parents or guardians”
Which resulted in the attached results. Please note, further review would be needed to determine releasability of all links and/or external records noted within the responsive email content itself.