Beginning in November students may be able to examine all school records kept on them within 45 days of making a formal request.

The Administration is now discussing the implementation of federal legislation enacted in August requiring schools to make available students' files--on pain of losing federal funds--to parents of students under the age of eighteen and students over the age of eighteen or in post-secondary school.

Questions raised by the legislation include what procedures to use in providing access to files, whether any items in current files should be removed, and whether any items are exemptible. Faculties, departments and offices are also considering whether they will modify their record-keeping procedures.

The legislation, part of an amendment to the education bill signed by President Ford last month, also forbids schools to release information from the files, except to designated school officials, without the student's written consent.

Schools receiving federal funds are required to inform students of their right to see their records, as well as to provide opportunities for the correction of inaccurate or misleading data and for hearings to challenge the content of records.

Daniel Steiner '54, general counsel to the University, said last week that he will write Harvard's guidelines for compliance after he has received comments from the deans of all the faculties. He has asked each faculty to report this month what records it has that may be subject to the law and what problems of interpretation may arise.

The Department of Health, Education and Welfare, charged with enforcing the law, will issue specific regulations in a few months.

Steiner criticized the lack of debate the amendment received in Congress and called the law "a mistake." The amendment is aimed primarily at elementary and secondary schools and is attached to the hotly debated education bill.

Harvard administrators last spring lobbied against similar legislation subsequently killed in the Massachusetts legislature.

Steiner said he foresees three principle problems resulting from the law. He said that student advising will be adversely affected by a lack of candid comments in student files.

Second, he cited the widespread worry that letters of recommendation may cease to be candid, thus losing their crucial role in college and graduate and professional school admissions and forcing schools to rely more heavily on objective criteria.

He also expressed concern that prospective employers may pressure students to release their complete records. Though Harvard's present policy on the oral release of information varies from office to office, a student's complete folder may never be released to an outside agency.

A "serious moral question" and a legal question is raised, Steiner said, by changing the rules of the game after recommendations have been written with a prior confidentiality agreement. Admissions files have in the past been designated confidential with the written agreement of the applicant. And whether such past agreements may be sustained under the new law remains unanswered.

Dean Whitlock said last week that the same question extends to other letters on file which were solicited by students with an agreement of confidentiality.

Several offices which will be affected by the legislation expressed uncertainty last week about the ramifications of the measure. L. Fred Jewett '57, dean of admissions and financial aid, said that his office is "just not sure what it means."

Mary Anne Schwalbe, director of Radcliffe admissions, said she feels recommendations may become bland and that secondary school teachers may make similar comments about all students.

The current practice of transferring each student's entire admission file to his permanent college folder could be changed, Whitlock said. Schwalbe suggested that interview reports and comments on applications might be removed, leaving only secondary school transcripts and application forms.

The law does not forbid the alternation or destruction of items in student files. The University then has the option, Steiner said, to excise material from student folders. Steiner said that since a moral question is raised by the presence of materials written with the assumption of confidentiality, the matter of altering files is one under discussion.

Under the specific section of the law granting students the right to inspect their records it is possible that the University could establish conditions for access which would discourage students from requesting to see their files. But Steiner said he thought Harvard would not consider setting any such terms because they would probably constitute an evasion of the law.

Individual departments must also make available to undergraduate concentrators and graduate students the files they have compiled on them. Prospective employers and departments have traditionally relied on the confidentiality of graduate students' files for job placement.

The new law concerning the rights and privacy of parents and students will be implemented at Harvard. But what form implementation will take and what its ramifications will be are questions under discussion throughout the University.

Under current Harvard record-keeping practices, your record begins when you submit your application. It quickly grows to include score reports, secondary school reports, teacher reports, interview reports and comments made by admissions officers.

If you live in the Yard freshman year, your admissions file is forwarded to your folder in the freshmen dean's office. If you live in a Quadrangle House, it goes directly to the House office.

Picking up information on its way--such as the letter about you solicited from your parents, notes on interviews between you and members of the dean's staff, a report made by your proctor or freshmen advisor, dockets relating to Ad Board actions and grade reports--each folder moves on to your House office.

In the House office the folder continues to gain academic and disciplinary records. Departmental tutorial reports, copies of letters of recommendation and other material at the discretion of individual House masters are added to the file. The House office keeps the folder when a student is on leave and for five years after he graduates at which time it is sent to Widener Library for permanent storage in the archives.

In the archives the complete folders are kept in acid-free, nearly airtight boxes, safe from dust and pollution though prey to heat and humidity.

While in the freshmen dean's office, folders are available only to the freshmen dean, the dean of the college, and the student's proctor and advisor. Once in the House office, they are available only to House masters, senior tutors and the dean of the college. Only the dean may retrieve undergraduate records stored in Widener.

Pre-law and pre-medical advisors and faculty members in rare cases may seek information through the individuals granted access.

These strict regulations were instituted two years ago when procedures were also outlined for transporting folders between offices. They may only be moved when accompanied by a member of a dean's staff, a house secretary or, in emergency cases, a university policeman.

Records on undergraduates are also kept by their departments. Though policy varies widely, most departments keep files on concentrators including items such as grade reports, tutorial reports, thesis-related material and recommendations.

The registrar's office keeps grade records on file for about 20 to 25 years after a student leaves Harvard depending upon the space available in the transcript room. The registrar's original copies, unlike the shielded versions released by the office, includes test scores and notations of Ad Board actions. These records eventually find their way to Widener, joining student folders in the archives, to be preserved in perpetuity.