GRAMA Policy and Procedures - Administrative Policy and Procedures

  1. Back to Policies and Procedures Page
  1. Purpose
    1. The Davis Technical College (College) complies with the provisions of federal and state law relating to the retention and disclosure of records as defined in the Utah Government Records and Access Management Act. This policy identifiesthe individuals responsible for administering the College records program and provides guidance for determining the appropriate release of records.
  2. References
    1. Utah Code 63G-2 et. al. – Government Record Access and Management Act
    2. Utah Code 63A-12 et. al. – Public Record Management Act
    3. Utah Code 63A-19 et. al. – Government Data Privacy Act (GDPA)
    4. 20 U.S.C. § 1232g and 34 C.F.R. Part 99 – Family Educational Rights and Privacy Act (FERPA)
  3. Definitions
    1. Record – As defined in the Utah Governments Records and Access Management Act (GRAMA) section 63G-2-103 a record is recorded information such as a book, letter, document, paper, map, plan, photograph, film, card, tape, recording, electronic data, or other documentary material, regardless of medium, characteristic, or location: (i) that is prepared, owned, received, or retained by a governmental entity or political subdivision; and (ii) where all of the information in the original is reproducible by photocopy or other mechanical or electronic means.
    2. Classification – “Classification,” “classify” and their derivative forms mean determining whether a record series, record, or information within a record is public, private, controlled, protected, or exempt from disclosure under GRAMA section 63G-2-3.
    3. Designation – The primary classification for the majority of records in a given record series (e.g., administrative records, personnel records, student records, fiscal records).
    4. Formal Request – A written or electronic request for specific record(s) which are not considered unquestionably public (i.e., private, controlled, protected, or exempt).
    5. Chief Administrative Officer (CAO) – An individual designated by the President of the College to fulfill the responsibilities of a Chief Administrative Officer under Utah Code § 63A‑12‑103 for records management and access.
    6. Records Officer – An individual appointed by the Chief Administrative Officer to coordinate records management and records access activities and to serve as a liaison with the Utah Division of Archives and Records Services and the Office of Data Privacy.
  4. Policy
    1. As an entity of the State of Utah, the College complies with providing public records for information as covered by and provided through the GRAMA.
    2. Student education records are governed by FERPA and are generally excluded from disclosure under GRAMA
  5. Procedures
    1. The College will appoint one Records Officer to provide for the care, maintenance, scheduling, disposal, classification, designation, access, and preservation of the institution’s records.
      1. The Records Officer shall maintain certification through the State Archives and complete annual GRAMA training as required by Utah Code § 63A-12-110. Documentation of certification shall be reviewed annually by the Chief Administrative Officer.
    2. The Records Officer will be responsible for working with College employees to determine a designation for all record series routinely used at the College. Records are public by default unless otherwise classified in accordance with GRAMA § 63G-2-201.
    3. The Records Officer will be responsible for establishing and maintaining a schedule of fees for records access/duplication under Utah Code 63G-2-203(3).
      1. When the College designates a record as private or controlled, the institution must also file a statement with state archives explaining the purposes for which the records are collected and used by the institution (Utah Code 63G-2-601).
        1. The College may use the record only for the purposes listed in thatstatement.
        2. Sharing records with other governmental entities is allowed, subject to the restrictions of Utah Code 63G-2-201.
    4. Formal requests for access to records must be submitted through the College’s designated GRAMA email address: publicrecords@davistech.edu. Requests received by other means (paper, forms, or other electronic communication) must be forwarded to this inbox for processing and tracking.
      1. Requests must include the requester’s name, mailing address, daytime telephone number, email address (optional), date of request, and a detailed description of the record with reasonable specificity, consistent with Utah Code § 63G-2-204.
      2. Employees who receive requests, which may be GRAMA requests, are required to forward such requests to the Records Officer, via publicrecords@davistech.edu, for centralized action and tracking.
      3. All formal requests for access to records will be assessed by the Records Officer and Chief Administrative Officer to determine a) if the request is permissible under GRAMA rules, and b) to refer the request to the appropriate member of the College staff for resolution.
      4. The designation for the record will be used as the primary determinant for responding to the request. If the designation is unclear or absent, the Records Officer will coordinate with counsel to determine how to handle the request.
      5. When a record contains both public and nonpublic information, the College will segregate and release the public portions, consistent with Utah Code § 63G‑2‑308.
      6. All responses to GRAMA requests will be issued through the publicrecords@davistech.edu inbox, regardless of the original method of submission to ensure consistency, transparency, and alignment with the College’s Privacy Program Policy.
      7. The College will respond as soon as reasonably possible but no later than 10 business days, or 5 business days if the requester demonstrates that expedited processing benefits the public, in accordance with Utah Code § 63G-2-204.
      8. f a request is presented as a GRAMA request but is determined to be a different kind of request (e.g., transcript request, subpoena, individual student request for records, request for access to information available through state transparency processes) it will be no longer considered a GRAMA request, and the requester will be directed to the appropriate avenue for fulfilling the request.
      9. All GRAMA request records, including correspondence and related documentation, shall be retained in accordance with the approved retention schedule for GRAMA-related records as maintained by the Utah Division of Archives and Records Service under General Retention Schedule #1711 (2 years after final action).
    5. If a formal records request is denied, a dissatisfied requester has the right to appeal to the Chief Administrative Officer within 30 days under Utah Code § 63G-2-401. An individual may contest the accuracy or completeness of records concerning him or her. Appeals from such decisions are governed by Utah Code 63G-2-603.
      1. A requester may seek mediation at any point from the Government Records Ombudsperson under Utah Code § 63A-12-111.
    6. Donors and prospective donors may request anonymity by making such requests in writing through the Director of the Davis Technical College Foundation.
    7. At-risk employees, as defined in § 63G-2-303, may request that personal information be classified as private by submitting the At-Risk Employee Application form. The Records Officer will assist in identifying specific records that contain personal information.
  6. Related Documentation
    1. Privacy Program Policy
    2. Privacy Notice and Policy
    3. At-Risk Employee Application Form
    4. GRAMA Fee Schedule
    5. Student Records Policy and Procedures
Policy migration in progress

Davis Tech is in the process of migrating our policies from PDF to HTML format to conform to Title II (ADA) requirements. During this transition period, the latest approved version of the policy is available (below) in pdf format, but may contain ADA Compliance errors.

Printable PDF

Effective Date: 12 March 2026

  • Approvals and Notes
  • Revised Board of Trustees Approval: 12 March 2026
  • Revised President’sCouncil Approval: 26 January 2026
  • College Board of Directors Approval: 7 August 2024
  • Board of Trustees Approval: 7 August 2024
  • President’s Council Approved: 5 August 2024
  • President’s Council Approved: 9 December 2017
  • College Board of Directors Approval: 7 December 2017