This work proposes a procedure to implement a Data Access Policy to ensure the protection of privacy rights of students’ records within higher educational systems. First it reviews the general legal constraints applicable to higher Institutional Data management. Second it reviews the principles of a Coordinated Model. The procedure is based on an Access Right Matrix that assigns data access privileges to Data Users. The first purpose is to handle the common and regular access by rightful users to data needed in their daily routine job through operational interface. The main purpose of the procedure is to handle ad-hoc requests that come from outside the university or from some services which do not have formal access to the data. Data access right matrix is used to grant or reject ad hoc requests based on the following criteria: the degree of sensitivity of the data requested, the number of records requested the purpose of the usage, and finally the privileges and trustworthiness of the requester.
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