What is an Internship?

Because the parties involved in the internship process—students, colleges and universities, and employers—have differing objectives, it is important to have a definition of “internship” upon which all parties can agree. To establish uniformity in the use and application of the term “internship,” the National Association of Colleges and Employers (NACE) recommends the following definition:

An Internship is a form of experiential learning that integrates knowledge and theory learned in the classroom with practical application and skills development in a professional setting. Internships give students the opportunity to gain valuable applied experience and make connections in professional fields they are considering for career paths; and give employers the opportunity to guide and evaluate talent.

To ensure that an experience—whether it is a traditional internship or one conducted remotely or virtually—is educational, and thus eligible to be considered a legitimate internship by the NACE definition, all the following criteria must be met:

  1. The experience must be an extension of the classroom: a learning experience that provides for applying the knowledge gained in the classroom. It must not be simply to advance the operations of the employer or be the work that a regular employee would routinely perform.
  2. The skills or knowledge learned must be transferable to other employment settings.
  3. The experience has a defined beginning and end, and a job description with desired qualifications.
  4. There are clearly defined learning objectives/goals related to the professional goals of the student’s academic coursework.
  5. There is supervision by a professional with expertise and educational and/or professional background in the field of the experience.
  6. There is routine feedback by the experienced supervisor.
  7. There are resources, equipment, and facilities provided by the host employer that support learning objectives/goals.

Guidelines for GWU Internships

More students pursue experiential learning, particularly internships, more colleges and universities promote student engagement in experiential learning such as internships, and a greater number and variety of employers offer these experiences in the form of internships. Significant national discussion has developed, particularly around the concept, purpose, structure, and function of internships, and the conditions under which internships can be accomplished on an unpaid basis.

A learning agenda in the form of specific learning objectives is established prior to the start of the internship. The internship also may include one or more forms of reflection integral to the experience to distinguish it from a volunteer position or job. Should a student choose not to earn academic credit for the internship experience, then the student should work with their internship site supervisor to assure appropriate learning goals are established and met upon completion of the internship experience.

To establish uniformity in the use and application of the term “internship,” the National Association of Colleges and employers (NACE) recommends the following definition: An Internship is a form of experiential learning that integrates knowledge and theory learned in the classroom with practical application and skills development in a professional setting. Internships give students the opportunity to gain valuable applied experience and make connections in professional fields they are considering for career paths; and give employers the opportunity to guide and evaluate talent.

To effectively implement this definition, it is necessary to develop criteria that Gardner-Webb students, faculty, staff, employer recruiters, and the Center for Career Development can use to identify workplace experiences that can legitimately be identified as “internships.” The discussion of these criteria is framed by several conditions.

The conditions are the legal definitions set by the Fair Labor Standards Act (FLSA) from the U.S. Department of Labor (DOL); the varying guidelines set by individual academic departments; employer perspectives on and objectives for internships; and the unique experiential learning objectives of students.

The legal considerations are addressed through six criteria for unpaid interns for the service they provide to “for-profit” private sector employers articulated in the Fair Labor Standards Act (see FLSA Fact Sheet #71). If criteria is met, the Department of Labor (DOL) considers there to be no employment relationship. The six criteria established by the DOL must be met in order to be an unpaid internship. For further information regarding unpaid internships, please see enclosed document provided by the DOL.

  • The internship, even though it includes actual operation of the employer’s facilities, is similar to training that would be given in a vocational school.
  • The internship experience is for the benefit of the student.
  • The intern does not displace regular employees, but works under the close observation of a regular employee.
  • The employer provides the training and derives no immediate advantage from the activities of the intern. Occasionally, the operations may actually be impeded.
  • The intern is not necessarily entitled to a job at the conclusion of the internship.
  • The employer and the intern understand that the intern is not entitled to wages for the time in the internship.

To ensure that an experience—whether it is a traditional internship or one conducted remotely or virtually—is educational, and thus eligible to be considered a legitimate internship by the outlined definition, all the following criteria must be met:

  • The experience must be an extension of the classroom: a learning experience that provides for applying the knowledge gained in the classroom. It must not be simply to advance the operations of the employer or be the work that a regular employee would routinely perform.
  • The skills or knowledge learned must be transferable to other employment settings.
  • The experience has a defined beginning and end, and a job description with desired qualifications.
  • Prior to the beginning of the internship there are clearly defined learning objectives/goals related to the professional goals of the student’s academic coursework. At the end of the internship, there is an established process for reflection on the learning objectives established earlier.
  • There is supervision by a professional with expertise and educational and/or professional background in the field of the experience.
  • There is routine feedback by the experienced supervisor.
  • There are resources, equipment, and facilities provided by the host employer that support learning objectives/goals.

While academic credit legitimizes an unpaid experience, in order to be identified as an internship, that experience must fit the criteria. For experiences that employers make available only if academic credit is awarded, the college or university’s requirements in combination with the criteria laid out in this document should be used to determine if the experience is a legitimate internship. The arrangement for academic credit is overseen by a faculty member designated from the academic department within the student’s declared major. The work/learning experience is usually the length of a semester, may be part-time or full-time, paid or unpaid.

  • Implications
    • These guidelines examine how to assess experiences often promoted as “internships” with the goal of determining the implications for compensation by exploring three components:
    • The experience’s legitimacy as an internship must be determined. To do so, the educational value of the experience must be considered of most importance.
    • Once the experience can be ethically identified as an internship, the implications for compensation can be determined. An experience that meets all the criteria may be offered unpaid.
    • Only an experience that meets the criteria presented in this paper should be labeled an internship.


Words/Terms Related to Internships Provided By NACE

Experiential learning is an umbrella term for student work and observation experiences: Internships, co-ops, externships, and practicums are all types of experiential learning.

Cooperative education (co-op) provides students with multiple periods of work in which the work is related to the student’s major or career goal. The typical program plan is for students to alternate terms of full-time classroom study with terms of full-time, discipline-related employment. Since program participation involves multiple work terms, the typical participant will work three or four work terms, thus gaining a year or more of career-related work experience before graduation. Virtually all co-op positions are paid and the vast majority involves some form of academic credit.

An externship or job shadowing experience allows a student to spend between a day and several weeks observing a professional on the job.

A practicum is generally a one-time work or service experience done by a student as part of an academic class. Some practicums offer pay, but many don’t. Almost all are done for academic credit. A relative of the internship, this form of experiential learning usually is a course or student exercise involving practical experience in a work setting(whether paid or unpaid) as well as theoretical study, including supervised experience as part of professional pre-service education.

This term is used to denote optional or required out-of-classroom community service experiences/projects attached to courses or a separate credit bearing experience. The location may be the broader community outside the university or one embedded in co-curricular activities. In these experiences, students participate in an organized service activity that meets identified community needs and reflect on the service activity to better understand course content and gain a broader appreciation of the discipline and an enhanced sense of civic responsibility.

Mostly a part of professional programs, students gain practical relevant work experience over a period of multiple terms that intersperse their coursework. Students alternate work and study, usually spending a number of weeks in study (typically full-time) and a number of weeks in employment away from campus (typically full-time). Alternatively, cooperative education may occur when students simultaneously attend classes part-time and work part-time during consecutive school terms in an intentionally planned and coordinated way. Students receive academic credit for cooperative education when the experiences meet the criteria for credit (i.e., faculty supervision, reflective components, evidence of learning). The purpose of these programs is to build student’s career skills and knowledge.

This is a more specifically defined internship experience in which students practice learned didactic and experiential skills, most frequently in health care and legal settings, under the supervision of a credentialed practitioner. It is often is a separate credit-bearing course tied to a related theoretical course or a culminating experience after a sequence of theoretical courses

This experience is specific to students in pre-professional and pre-service teacher education who are gaining required and evaluated experience in supervised teaching

Students function as research assistants and collaborators on faculty projects

Faculty and students cooperate with local organizations to conduct studies to meet the needs of a particular community. Students gain direct experience in the research process.

Supervised student research or practice carried out away from the institution and in direct contact with the people, natural phenomena, or other entities being studied. Field work is especially frequent in fields including anthropology, archaeology, sociology, social work, earth sciences, and environmental studies.

Students usually engage in courses at higher education institutions in another country. The experiential learning component is the cultural immersion which provides novel challenges for navigating living in a new place. The coursework connected to a study abroad can also include internships and service-learning experiences

U.S. Department of Labor: Wage and Hour Division

Fact Sheet #71: Internship Programs Under The Fair Labor Standards Act

This fact sheet provides general information to help determine whether interns must be paid the minimum wage and overtime under the Fair Labor Standards Act for the services that they provide to “for-profit” private sector employers. (April 2010)

The Fair Labor Standards Act (FLSA) defines the term “employ” very broadly as including to “suffer or permit to work.” Covered and non-exempt individuals who are “suffered or permitted” to work must be compensated under the law for the services they perform for an employer. Internships in the “for-profit” private sector will most often be viewed as employment, unless the test described below relating to trainees is met. Interns in the “for-profit” private sector who qualify as employees rather than trainees typically must be paid at least the minimum wage and overtime compensation for hours worked over forty in a workweek.

There are some circumstances under which individuals who participate in “for-profit” private sector internships or training programs may do so without compensation. The Supreme Court has held that the term “suffer or permit to work” cannot be interpreted so as to make a person whose work serves only his or her own interest an employee of another who provides aid or instruction. This may apply to interns who receive training for their own educational benefit if the training meets certain criteria. The determination of whether an internship or training program meets this exclusion depends upon all of the facts and circumstances of each such program.

The following six criteria must be applied when making this determination:

  1. The internship, even though it includes actual operation of the facilities of the employer, is similar to training which would be given in an educational environment;
  2. The internship experience is for the benefit of the intern;
  3. The intern does not displace regular employees, but works under close supervision of existing staff;
  4. The employer that provides the training derives no immediate advantage from the activities of the intern; and on occasion its operations may actually be impeded;
  5. The intern is not necessarily entitled to a job at the conclusion of the internship; and
  6. The employer and the intern understand that the intern is not entitled to wages for the time spent in the internship.

If all of the factors listed above are met, an employment relationship does not exist under the FLSA, and the Act’s minimum wage and overtime provisions do not apply to the intern. This exclusion from the definition of employment is necessarily quite narrow because the FLSA’s definition of “employ” is very broad. Some of the most commonly discussed factors for “for-profit” private sector internship programs are considered below.

Similar To An Education Environment And The Primary Beneficiary Of The Activity

In general, the more an internship program is structured around a classroom or academic experience as opposed to the employer’s actual operations, the more likely the internship will be viewed as an extension of the individual’s educational experience (this often occurs where a college or university exercises oversight over the internship program and provides educational credit). The more the internship provides the individual with skills that can be used in multiple employment settings, as opposed to skills particular to one employer’s operation, the more likely the intern would be viewed as receiving training. Under these circumstances the intern does not perform the routine work of the business on a regular and recurring basis, and the business is not dependent upon the work of the intern. On the other hand, if the interns are engaged in the operations of the employer or are performing productive work (for example, filing, performing other clerical work, or assisting customers), then the fact that they may be receiving some benefits in the form of a new skill or improved work habits will not exclude them from the FLSA’s minimum wage and overtime requirements because the employer benefits from the interns’ work.

If an employer uses interns as substitutes for regular workers or to augment its existing workforce during specific time periods, these interns should be paid at least the minimum wage and overtime compensation for hours worked over forty in a workweek. If the employer would have hired additional employees or required existing staff to work additional hours had the interns not performed the work, then the interns will be viewed as employees and entitled compensation under the FLSA. Conversely, if the employer is providing job shadowing opportunities that allow an intern to learn certain functions under the close and constant supervision of regular employees, but the intern performs no or minimal work, the activity is more likely to be viewed as a bona fide education experience. On the other hand, if the intern receives the same level of supervision as the employer’s regular workforce, this would suggest an employment relationship, rather than training.

The internship should be of a fixed duration, established prior to the outset of the internship. Further, unpaid internships generally should not be used by the employer as a trial period for individuals seeking employment at the conclusion of the internship period. If an intern is placed with the employer for a trial period with the expectation that he or she will then be hired on a permanent basis, that individual generally would be considered an employee under the FLSA.

For additional information, visit the Wage and Hour Division Website: http://www.wagehour.dol.gov and/or call our toll-free information and helpline, available 8 a.m. to 5 p.m. in your time zone, (866) 4USWAGE/(866) 487-9243.

Harassment Policy and Procedures

A workplace is a social environment. In some instances behaviors may be disguised as friendly or playful when, in fact, they are inappropriate or of a harassing nature.

Please keep the following points in mind:

  • You have the right to expect professional conduct from every person at your internship site. This includes your internship supervisor, peers and subordinates. The internship is not an initiation nor an opportunity for free labor. It is an organized learning experience in a professional work environment.
  • No one under any circumstance has the right to place you in personally uncomfortable situations.
  • Sexual harassment constitutes behavior that is perceived as annoying, aggressive, and/or threatening. If you feel that someone is targeting you as the object of sexual innuendo or inappropriate advances, it is possible you are being harassed. Sexual harassment is not just a matter of the actions of others; it is how the actions affect you.

Behaviors that may constitute sexual harassment include (but are not limited to) the following:

  • Unnecessary touching, pinching or patting
  • Obscene gestures
  • Disparaging remarks about one’s gender
  • Sexual innuendos or persistent use of sexually suggestive language which another person finds offensive, demeaning, or otherwise inappropriate
  • Remarks about a person’s clothing, body, or sexual activities
  • Conditioning an educational or employment decision or benefit on submission to sexual conduct

The Center for Career Development is committed to engaging students in professional and safe working/learning environments. Gardner-Webb University will not tolerate any form of harassment, intimidation or discrimination. This applies to internship supervisors and co-workers toward a student, and reversely students toward their internship supervisors and co-workers.

Misconduct of Internship Supervisors/Co-Workers Toward an Intern

The Center for Career Development encourages students to educate themselves on Gardner-Webb’s Title IX policies and procedures. The Center for Career Development asks students to report any incident as soon as possible, allowing Gardner-Webb faculty/staff and the internship site the opportunity to promptly intervene.

Misconduct of Student Intern Toward a Supervisor/Co-Workers

The Center for Career Development asks internship supervisors to report any incidents as soon as possible allow. In the event of an incident, internship supervisor should immediately contact the Internship Coordinator or a fellow staff member of the Center for Career Development at Gardner-Webb. Appropriate interventions will immediately be facilitated.

Please read the enclosed documents pertaining to Title IX and the Non-Harassment Policy for all students, faculty and employees. To view the complete Non-Harassment Policy for all students, faculty and employees, please see the current Gardner-Webb University Student Handbook.

FERPA Primer:

The Basics and Beyond Provided by NACE

Family Educational Rights and Privacy Act (FERPA) was enacted by Congress to protect the privacy of students and their parents. The act is designed to ensure that students and parents of students may obtain access to the student’s educational records and challenge the content or release of such records to third parties.

FERPA requires that federally funded institutions, under programs administered by the U.S. Department of Education, comply with certain procedures with regard to disclosing and maintaining educational records. FERPA was not enacted to preclude the disclosure of educational records simply because the records identify a student by name; rather, it was designed to protect the student’s educational information and status as a student.

To understand the scope of FERPA, it is necessary to define “student.” According to FERPA, a student is an individual who is enrolled in and actually attends an educational institution. The regulations provide that attendance includes, but is not limited to, attendance in person or by correspondence. Courts have held that individuals who merely audit classes or who are accepted to an educational institution but do not attend any classes are not “students” for purposes of FERPA. Individuals who “attend” classes but are not physically located on a campus are also students, thus including those who attend classes by videoconference, satellite, Internet, or other electronic information and telecommunications technologies.

FERPA prohibits the disclosure of a student’s “protected information” to a third party. This disclosure is prohibited whether it is made by hand delivery, verbally, fax, mail, or electronic transmission. Disclosure also includes the provision of access to the educational institution’s career center database of student resumes.

For purposes of FERPA, a “third party” includes any individual or organization other than the student or the student’s parent(s). With respect to third parties, even if the initial disclosure of protected information is permissible, FERPA limits the subsequent disclosure of the information by the third party. As such, once an educational institution discloses protected information to a third party, it must ensure that the third party does not itself improperly disclose the information in violation of FERPA.

FERPA classifies protected information into three categories: educational information, personally identifiable information, and directory information. The limitations imposed by FERPA vary with respect to each category.

Although personally identifiable and directory information are often similar or related, FERPA provides different levels of protection for each. Personally identifiable information can only be disclosed if the educational institution obtains the signature of the parent or student (if over 18 years of age) on a document specifically identifying the information to be disclosed, the reason for the disclosure, and the parties to whom the disclosure will be made. Failure to comply with these requirements will result in a violation of FERPA.

On the other hand, with respect to directory information, FERPA does not bar disclosure by the educational institution. Directory information is defined as “information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed.” This includes such items as a list of students’ names, addresses, and telephone numbers, and also includes a student ID number (which includes electronic identifiers) provided it cannot be used to gain access to education records. Directory information, however, does not include a student’s social security number nor can the social security number be used to confirm directory information. Directory information can be disclosed provided that the educational institution has given public notice of the type of information to be disclosed, the right of every student to forbid disclosure, and the time period within which the student or parent must act to forbid the disclosure. If a student decides to “opt out” of the disclosure of directory information, the “opt out” continues indefinitely. Therefore, an educational institution cannot release such information even after a student is no longer in attendance. However, the 2011 revisions to the act prohibit a student from opting out as a way to prevent schools from requiring students to wear an identification card or badge.

The 2011 revised regulations also reduced the burden on educational institutions of receiving consent prior to the disclosure of information for routine uses of student information. Educational institutions are now permitted to adopt a limited directory information policy that allows the schools to disclose designated information to designated parties. To create such a policy, however, educational institutions must provide notice to parents or eligible students.

FERPA precludes the disclosure of educational information without the prior approval of the student or parent. The issue of what constitutes “educational information” has been hotly contested and subject to much litigation since the inception of FERPA. FERPA defines “education records” as “records, files, documents, and other materials” that are “maintained by an educational agency or institution, or by a person acting for such agency or institution.” While it is clear that educational information includes a student’s transcripts, GPA, grades, social security number, and academic evaluations, courts have also included in this category certain psychological evaluations. “Education records” also include any record that pertains to an individual’s previous attendance as a student of an institution. In this regard, information pertaining to lawsuits or other claims that are related to a former student are covered under the definition of “education record” under FERPA and are precluded from disclosure absent prior approval.

FERPA has, however, excluded from the definition of “education record” the use of “peer grading.” In this regard, the 2008 revisions to FERPA implemented the U.S. Supreme Court decision in Owasso Independent School District v. Kristja Falvo, which held that peer grading was not educational information for purposes of FERPA. According to the court, “peer grading,” a practice whereby one student scores/grades the work of another student, is generally not encompassed by FERPA because the information is not created or “maintained” by the educational institution or an agent of the institution. Rather, the information is created and maintained by another student. This exception, however, stops at the time the test or assignment is collected and recorded by the teacher.

Courts have adopted similar reasoning with respect to teacher evaluations and negative letters of recommendation written by the teacher but not “maintained” by the educational institution in its files. Courts have been reluctant to find that these records are subject to FERPA because they do not meet the strict definition of an “educational record” according to FERPA.

Regarding reference letters and resumes, the key is whether these records include or incorporate the student’s “educational information” (i.e., GPA, grades, social security numbers, and so forth). If these documents contain “protected” educational information, they cannot be disclosed without satisfying FERPA’s pre-disclosure requirements. An educational institution may not provide an employer, headhunter, or other employment agency with a student’s resume or confidential letter of reference that contains protected educational information unless it first obtains approval from the student or the student’s parent.

Additional exceptions to the nondisclosure requirements of FERPA were established in the recent revisions. The 2008 revisions allow for the disclosure of educational records in connection with certain emergencies. An educational institution can release such records if it determines that there is an articulable and significant threat to the health and safety of a student or other individuals. Such information may be disclosed to appropriate parties—including the student’s parents— whose knowledge of the information is necessary to protect the health and safety of the student or others. The educational institution must maintain records of any such disclosures. Educational institutions are also now permitted to disclose, without consent, information concerning registered sex offenders. Further, FERPA now requires educational institutions to disclose to the alleged victim of any crime of violence or a sex offense the results of any disciplinary proceeding conducted by the institution against a student who is the alleged perpetrator of such a crime or offense.

Also, the 2008 revisions permit educational institutions to disclose educational information and personally identifiable information without prior consent to contractors, volunteers, or other nonemployees performing services for the educational institution. The request must be based upon a legitimate educational interest. An educational institution must apply “reasonable methods” to limit disclosure and restrict access to such information.

FERPA also allows the disclosure of information without consent if all personally identifiable information has been removed from the records. In order to disclose such information, a school has to remove all information that, alone, or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty.

The 2011 revisions further clarified how educational institutions could disclose information to audit the effectiveness of its programs. FERPA allows educational institutions to disclose information to third parties to audit or evaluate its programs. Previously, educational institutions could only disclose such information to entities or individuals under their direct control. Now, FERPA allows for the disclosure of information to “any entity or individual designated by a state or local educational authority to conduct any audit or evaluation, or any compliance or enforcement activity in connection with federal legal requirements that regulate programs.” This would include any audits of job placement, secondary education, or training programs. The institution must enter into a written agreement with any third party to which it discloses information. Such an agreement must contain provisions that protect against the re-disclosure of the information, provide plans to handle a data breach, and offer methods to record the data provided. According to the Department of Education, the revisions were done to “improve access to data that will facilitate states’ ability to evaluate education programs, to ensure limited resources are invested effectively, to build upon what works and discard what does not, and to contribute to a culture of innovation of continuous improvement in education.”

FERPA gives students the right to inspect their educational records (excluding information on other students, the financial records of parents, and confidential letters of recommendation if the student has waived the right to access) before giving consent to disclose information. If a student does request the right to inspect, the educational institution must comply within 45 days of the receipt of the request.

In many cases, students have seen, or are aware of, the contents of their files. For example, a student knows what courses he or she has taken and/or his or her GPA, both of which are included in the student’s “educational record.” Even if a student has waived the right to access his or her file, the school must provide a list of the file’s contents (including the names of all persons making confidential recommendations) upon the student’s request. If the student file has changed in any way, e.g., a letter of recommendation has been altered or replaced, career services should notify the student that there has been a change before disclosing the file’s contents to a potential employer or graduate school.

FERPA does not specify a time period for retaining credential/placement files or reference letters. The law merely provides that an education record may not be destroyed if there is an outstanding student request to inspect the file. The school has the discretion to develop a record retention policy and communicate that policy to its students. The policy should include a deadline by which students/alumni must respond if they do not wish to have their files destroyed. Once the deadline has passed, and there has been no request for retention, the records may be destroyed.

In order to ensure compliance with FERPA, educational institutions should adhere to the following:

Advise students annually of their rights under FERPA.

  • Obtain signed, written consent from a student before a school official, administrator, career services staff member, or faculty member releases personally identifiable information to an employer, third-party recruiter, or resume referral data base;
  • Train and retrain faculty members with respect to the requirements and prohibitions of FERPA;
  • Notify employers, employment agencies, contract recruiters, resume data bases, and other entities that student records are subject to FERPA, and that such entities cannot subsequently disclose these records without student consent; and
  • Notify third parties that improper disclosure will result in future denials of access to such records.
  • Determine, clearly define, and communicate to students what information will be considered directory information prior to disclosure and provide students with a reasonable time to notify the educational institution if they want to restrict access to directory information.
  • Obtain a new consent form if any student information is changed, such as revisions to a letter of recommendation, prior to fulfilling an information request.
  • Note that FERPA does not address the issue of placing amended letters of recommendation into students’ files: Each educational institution is responsible for establishing and consistently enforcing its own policies with respect to this issue.
  • Draft and maintain policies with regard to the retention of records that pertain to the disclosure of information for health and safety concerns.
  • Review and revise any and all third-party agreements to ensure such agreements comply with FERPA requirements.
  • Implement policies that include how an institution will respond to data breaches or unauthorized disclosures and conduct an investigation into how such a breach occurred.
  • Advise students with respect to the implications of waiving their right to inspect their files or letters of recommendation.

Courts have routinely held that FERPA does not create a private right of action against the educational institution. Complaints, however, may be filed with the Department of Education, which will investigate all issues. An educational institution that fails to comply with FERPA may forfeit its federal funding. It should be noted, however, that some states allow for monetary damages for the disclosure of private information.

Clearly, FERPA remains an important federally created protection for student privacy, but the act is ever changing. In May 2014, several U.S. senators introduced a bill that would modify FERPA to ensure that student data handled by private companies would be protected. The proposed bill would restrict federal money provided to schools that do not have information security policies and procedures in place. While this is only a proposed bill, it further indicates the heightened scrutiny educational institutions face when disclosing student information. Therefore, it is imperative that all educational institutions understand the existing restrictions and limitations imposed by FERPA.

Eight Principles of Good Practice for All Experiential Learning Activities

Regardless of the experiential learning activity, both the experience and the learning are fundamental. In the learning process and in the relationship between the learner and any facilitator(s) of learning, there is a mutual responsibility. All parties are empowered to achieve the principles which follow. Yet, at the same time, the facilitator(s) of learning are expected to take the lead in ensuring both the quality of the learning experience and of the work produced, and in supporting the learner to use the principles, which underlie the pedagogy of experiential education.

  1. Intention: All parties must be clear from the outset why experience is the chosen approach to the learning that is to take place and to the knowledge that will be demonstrated, applied or result from it. Intention represents the purposefulness that enables experience to become knowledge and, as such, is deeper than the goals, objectives, and activities that define the experience.
  2. Preparedness and Planning: Participants must ensure that they enter the experience with sufficient foundation to support a successful experience. They must also focus from the earliest stages of the experience/program on the identified intentions, adhering to them as goals, objectives and activities are defined. The resulting plan should include those intentions and be referred to on a regular basis by all parties. At the same time, it should be flexible enough to allow for adaptations as the experience unfolds.
  3. Authenticity: The experience must have a real world context and/or be useful and meaningful in reference to an applied setting or situation. This means that is should be designed in concert with those who will be affected by or use it, or in response to a real situation.
  4. Reflection: Reflection is the element that transforms simple experience to a learning experience. For knowledge to be discovered and internalized the learner must test assumptions and hypotheses about the outcomes of decisions and actions taken, then weigh the outcomes against past learning and future implications. This reflective process is integral to all phases of experiential learning, from identifying intention and choosing the experience, to considering preconceptions and observing how they change as the experience unfolds. Reflection is also an essential tool for adjusting the experience and measuring outcomes.
  5. Orientation and Training: For the full value of the experience to be accessible to both the learner and the learning facilitator(s), and to any involved organizational partners, it is essential that they be prepared with important background information about each other and about the context and environment in which the experience will operate. Once that baseline of knowledge is addressed, ongoing structured development opportunities should also be included to expand the learner’s appreciation of the context and skill requirements of her/his work.
  6. Monitoring and Continuous Improvement: Any learning activity will be dynamic and changing, and the parties involved all bear responsibility for ensuring that the experience, as it is in process, continues to provide the richest learning possible, while affirming the learner. It is important that there be a feedback loop related to learning intentions and quality objectives and that the structure of the experience be sufficiently flexible to permit change in response to what that feedback suggests. While reflection provides input for new hypotheses and knowledge based in documented experience, other strategies for observing progress against intentions and objectives should also be in place. Monitoring and continuous improvement represent the formative evaluation tools.
  7. Assessment and Evaluation: Outcomes and processes should be systematically documented with regard to initial intentions and quality outcomes. Assessment is a means to develop and refine the specific learning goals and quality objectives identified during the planning stages of the experience, while evaluation provides comprehensive data about the experiential process as a whole and whether it has met the intentions which suggested it.
  8. Acknowledgment: Recognition of learning and impact occur throughout the experience by way of the reflective and monitoring processes and through reporting, documentation and sharing of accomplishments. All parties to the experience should be included in the recognition of progress and accomplishment. Culminating documentation and celebration of learning and impact help provide closure and sustainability to the experience.

Designing Your Internship Program

Prior to hiring an intern, an employer must understand how interns will fit within the company’s goals and culture. Since organizations vary in age, size, industry, and product, so too will internship activities. Questions that may determine what kind of program will work best for you:

  • What does your organization hope to gain from the program?
  • Is your organization looking to fulfill a need on a specific project? Will this internship(s) encompass one major project, or entail a variety of small projects?
  • What are the tools and workspace necessary to provide the student?
  • What talents, academic background and experience do you want in an intern? Decide on qualifications early on to help you select the best candidate.
  • Who will be primarily responsible for the intern(s)? Will that person be a mentor, supervisor, or both?

Learn about prospective Interns. The best way to know what skills an intern is hoping to gain is to interview. It is important that employers realize that school and classes must remain a top priority for interns if they are a current student. The internship position should enhance their learning experience. Understand that for most interns this is a new experience and they may need support in balancing their schoolwork and internship. Agreeing on a set number of hours interns will work each week and offering flex‐time for freedom to plan their schedules on a weekly basis are two ways to support balance. Required hours/credit may vary. The student intern should meet with an academic or internship advisor for further direction. There are many ways to make the internship both memorable and engaging for both the intern and employer including the following:

Whether it is employees and interns going out to lunch, or employees taking interns to a local baseball game, engaging in these activities provides a great opportunity to get to know one another on a more personal level. They also provide interns a chance to get to know other interns and employees with whom they have not worked. Many Rhode Island employers with successful internship programs state that their social activities are rated by interns as one of the top highlights of their experience.

Allow interns to develop their professional skills by allowing them to sit in on meetings and work with employees in other departments for a day. Provide opportunities for interns to attend career development events/seminars in the community to learn new skills.

An internship can only be a true learning experience if constructive feedback is provided. An effective evaluation will focus on the interns’ initial learning objectives identified at the start of the internship. Supervisors should take time to evaluate both the student’s positive accomplishments and areas for improvement. Interns will look to their mentors and/or supervisors to help them transition from the classroom to the workplace. It is recommended that mentors and/or supervisors regularly meet with interns to receive and provide feedback concerning their performance. During these meetings the students may:

  • Report on a project’s status
  • Learn how their work is contributing to the organization
  • Participate in evaluating their strengths
  • Discuss areas needing growth and development
  • Get insight about what work lies ahead

It’s going to be important to identify a supervisor for your intern(s) who will familiarize them with the organization, provide assignments and serve as a “contact” person for questions. It’s recommended that the intern supervisor be an expert in the type of work the intern(s) will be performing to provide the appropriate guidance for the intern’s assignments. An intern supervisor’s responsibilities will include:

  • Taking part in an intern’s application, screening, and interview process
  • Conducting intern orientation
  • Developing learning goals
  • Meeting with an intern regularly to evaluate performance and if needs/goals are being met; and assessing the internship program’s success

In addition to the supervisor, a mentor may assist with transition into this new learning environment. This is done by answering general questions related to personal and professional growth, and sharing career knowledge leading to networking in the field.

15 Best Practices for Internship Programs

Provide interns with real assignments.

Providing interns with real work is number one to ensuring your program’s success. Interns should be doing work related to their major, that is challenging, that is recognized by the organization as valuable, and that fills the entire work term.

Hold orientations for all involved

It’s important that everyone “be on the same page,” so to speak. Make this happen by holding an orientation session. Orientations ensure that everyone starts with the same expectations and role definitions. This is time well spent—the effort you put into these sessions will pay off throughout the program.

Provide interns with a handbook and/or website.

Whether in paper booklet format, or presented as a special section on your website, a handbook serves as a guide for students, answering frequently asked questions and communicating the “rules” in a warm and welcoming way. A separate intern website serves many of the purposes of the handbook, but has the advantage of being easy to change. You can use your website as a communication tool, with announcements and/or internship postings.

Provide housing and relocation assistance.

Few employers can afford to provide fully paid housing for interns, but you’ll find that you get a lot of appreciation if you offer any kind of assistance toward housing expenses. If that’s not possible, provide assistance in locating affordable housing: For those relocating to the internship site, the prospect of finding affordable, short-term housing can be daunting. Easy availability of affordable housing will make your opportunity more attractive to students, broadening your pool of candidates.

If you can pay for all or some of your interns’ housing, be sure to design (and stick to) a clear policy detailing who is eligible. This will eliminate any perceptions of unequal treatment. In addition, be aware that employer-paid or employer-subsidized housing is considered a taxable benefit. Check with your internal tax department on exceptions to this.

You will also want to consider the issue of relocation, which is separate although related to housing. Many organizations pay some or all of their interns’ relocation expenses to and/or from the job site.

Offer scholarships

Pairing a scholarship with your internship is a great way to recruit for your internship program—and this is especially true if you are having difficulty attracting a particular type of student or student with a specific skill set to your program. Attaching a scholarship can increase your pool of candidates with the desired qualifications.

Offer flex-time and/or other unusual work arrangements.

Students mention flex-time as one of their most-desired features in a job. (A flexible time schedule during their internship eases their transition to the workplace.)

Other work arrangements that have been found successful with students include keeping them on as part-time, remote employees after they go back to school (depending on the type of work they do for you and whether they have a willing manager), and having them come back and work over school breaks for a couple of weeks. These are excellent ways to keep communications open and build a stronger bond.

Have an intern manager.

Having a dedicated manager for your intern program is the best way to ensure that it runs smoothly and stays focused on your criteria for success. Unfortunately, the size and resources available to most internship programs mean that this isn’t always possible. If your program isn’t big enough to warrant a dedicated full-time staff member, an excellent short-term solution is to hire a graduate student (look for a student working toward an advanced HR degree) to be your intern, and put this college relations intern in charge of the daily operation of the internship program. This gives the interns a “go-to” person, and gives you and your staff a break from the many daily tasks involved in running a program of any size. For this to work, you have to plan the program structure in advance (don’t expect your intern to do it), and be very accessible to your college relations intern.

Encourage team involvement.

Involve your organization’s college recruiting teams—whether they are “volunteers” who participate in college recruiting, staff members dedicated to college recruiting, or some combination of both—in your intern program. They can sponsor social or professional development events, and help to orient the interns to your company culture.

Invite career center staff and faculty to visit interns on site.

In general, career center staff and faculty members have relatively few opportunities to visit employer work sites to see firsthand the types of experiences their students are having. By inviting them to your site, you will build a better working relationship with these groups, which can lead to more student referrals, enhanced campus visibility, and increased flexibility on their parts when your business needs dictate it.

Hold new-hire panels.

New-hire panels are one of the best ways to showcase an organization to interns as a great place to work. These are panels of five or six people who were hired as new grads within the last three years. They act as panelists in a meeting of interns, giving a brief summary of their background and then answering questions from the intern audience. Your interns get insight about your organization from your new hires—people who they perceive are like themselves and who they consequently view as credible sources of information.

Bring in speakers from your company’s executive ranks.

One of the greatest advantages to students in having internships is the access they get to accomplished professionals in their field. Consequently, speakers from the executive ranks are very popular with students—it’s a great career development and role modeling experience for interns.

Having a CEO speak is especially impressive. Best scenario: Your CEO speaker is personable, willing to answer questions, and willing and able to spend a little informal time with the students after speaking—your interns will be quite impressed. For you, having your executives speak to interns is another way to “sell” your organization to the interns, and get your executives invested in (and supporting) your program.

Offer training/encourage outside classes.

Providing students with access to in-house training—both in work-skills-related areas, such as a computer language, and in general skills areas, such as time management—is a tangible way to show students you are interested in their development.

Conduct focus groups/surveys.

Conducting focus groups and feedback surveys with these representatives of your target group is a great way to see your organization as the students see it. Focus groups in particular can yield information about what your competitors are doing that students find appealing.

Showcase intern work through presentations/expo.

Students work very hard at completing their work and are generally proud of their accomplishments. Setting up a venue for them to do presentations (formal presentations or in a fair-type setting such as an expo) not only allows them to demonstrate their achievements, but also showcases the internship program to all employees.

Conduct exit interviews.

Whether face-to-face or over the telephone, a real-time exit interview is an excellent way to gather feedback on the student’s experience and to assess their interest in coming back. Having the students fill out an exit survey and bring it to the interview gives some structure to the conversation.

Excerpted from Building a Premier Internship Program: A Practical Guide for Employers, Courtesy of the National Association of Colleges and Employers.


“If exposure is essential, still more so is the reflection. Insight doesn’t happen often on the click of the moment like a lucky
snapshot, but comes in its own time and more slowly and from nowhere but within.”

– Eudora Welty

Reflection is the element that transforms simple experience to a learning experience. For knowledge to be discovered and internalized the learner must test assumptions and hypotheses about the outcomes of decisions and actions taken, then weigh the outcomes against past learning and future implications. This reflective process is integral to all phases of experiential learning, from identifying intention and choosing the experience, to considering preconceptions and observing how they change as the experience unfolds. Reflection is also an essential tool for adjusting the experience and measuring outcomes.

Although internships are supposed to help students apply what they have learned in the classroom to what they are doing in the workplace and vice versa, these connections are often not made without reflecting on the experience. Internship reflection “enhances a learner’s experience through a linkage of education, work, and personal development.” Through reflection, students gain an appreciation for the experience and self-confidence in their abilities.

Having a mentor or adviser to assist in internship reflection can help the student see his or her experiences from another perspective. Learners must have the opportunity to reflect on and observe experiences from many perspectives.” Encouraging students to examine issues that arose in the internship from a variety of different perspectives can help students better understand the actions, feelings, and reactions that occurred. In addition, this knowledge can help students reflect on better ways to handle future situations in the workplace. Allowing students to find their own answers and make their own discoveries is crucial, but advisers can play a pivotal role in sparking student reflection by asking reflective questions and providing encouragement.

The experiences of the internship can also cause students to become more reflective in other aspects of their lives, such as their duties as organizational leaders. Students are more likely to see reflection as a helpful tool once it assists them in their internship. If advisers are successful in their efforts to help students reflect, students will be encouraged by the results. It introduces them to a mindset of continuous learning and teaches them how to ask reflective.

This section will offer specific strategies that advisers can use to promote student reflection. Since students often get academic credit for participating in internships, students tend to express interest in participating in internships during meetings with their academic advisers. Advisers should note in students’ files when they are participating in internships so that they prepare for discussion and reflection when they return to campus. Although a faculty member usually serves as the instructor for internship courses, advisers still have a role to play. For example, advisers can help students establish goals and expectations about the internship. Chapel maintained that the adviser and the student should jointly develop the goals for the internship and state them clearly so that everyone understands individual responsibilities.

Once students have completed their internships, advisers should encourage them to make an appointment to discuss their experiences or be prepared to discuss the internship when the students comes in for their regular advising appointment. In planning for the meeting, the adviser can remember these three principles from the experiential learning literature:

Learning should be relearning where students’ ideas are brought out, examined, and mixed with new refined ideas.

Learning involves the whole person (thinking, feeling, perceiving, and behaving).

Learning is a process of combining new experiences with old experiences and vice versa. These principles can be implemented during reflection to encourage the student to examine certain situations and think outside the box. Advisers would benefit from using these ideas to help students realize the extent of the experiences they had and the potential impact on their futures.

Advisers can promote student reflection by creating a list of questions to ask them about their internship experience. These questions should make students take the time to think about and deeply consider their experience. Examples of effective questions include: What were your first thoughts and observations when starting the internship? How was your internship experience different from what you expected? What did you learn in your internship that you can now apply to the classroom setting or to your daily life? What connections have you made between theory and practice? How have your career plans changed due to your internship experience? What skills did you acquire during your internship that you will be able to highlight in your resume, cover letters, and/or interviews? Advisers should discuss with students how they can use what they learned from their internship to help accomplish their future life and career goals.

Advisers should point out overlooked interpretations to the student but avoid offering their own interpretations. Students will often brush off something as being insignificant when there may be more to the matter that needs to be discussed. For example, a student may view criticism from a supervisor as evidence that their work or project is a failure. In reality, the supervisor liked the overall idea of the project but can see that the student needs to work on time management to improve the overall outcome. Advisers should resist offering their interpretation of the event and instead ask questions that allow students to explore it further without bias. This allows the students to make discoveries themselves without limiting their scope or point of view.

Advisers should encourage students to be aware of feelings and how those feelings have affected the internship experience, as emotional sharing is positively related to both learning and mentoring. Students need to be open and honest in terms of their emotional experiences with others, so encouraging emotional awareness will benefit reflection and understanding. Advisers can encourage awareness by prompting students to recall their initial thoughts and feelings during
certain times in the internship. An event may have occurred that sparked an emotional reaction beyond what the student realized. This type of reflection will help the student to provide the necessary information for the adviser to respond appropriately and give positive and constructive feedback.

Edgar Schon, an influential writer on reflection, described reflection in two main ways: reflection in action and reflection on action. Reflection on action is looking back after the event whilst reflection in action is happening during the event. To complicate matters there are different interpretations of reflection on action. Let’s now explore these terms.

To think about what one is doing whilst one is doing it; it is typically stimulated by surprise, by something which puzzled the practitioner concerned.

The retrospective contemplation of practice undertaken in order to uncover the knowledge used in practical situations, by analyzing and interpreting the information recalled. Reflection on action involves turning information into knowledge, by conducting a cognitive post mortem. The process of creating and clarifying the meanings of experiences in terms of self in relation to both self and world. The outcome of this process is changed conceptual perspectives.

Other reflective practices can focus more on self-development. Here refection does not only add to one’s knowledge but challenges the concepts and theories previously held. As a result students don’t necessarily see more, they see differently. The faults with these views of reflection on action are that they do not take account of the importance of reflection before action. This is when we plan out before we act what we want to do.

Reflection can best be seen as:

  • Reflection before action
  • Reflection in action
  • Reflection after action

Reflective practice is a way of studying one’s own experiences to improve the way one works. It is very useful for professionals who want to carry on learning throughout their lives. The act of reflection is a great way to increase confidence and become a more proactive and qualified professional. Engaging in reflective practice should help to improve the quality of one’s work and close the gap between theory and practice. The following examples of reflective practice will give you some idea of the various methods you can choose from.

Gibbs’ reflective cycle is a process involving six steps. It is considered a ‘cycle’ because the action you take in the final stage will feed back into the first stage, beginning the process again.

  1. Description – What happened?
  2. Feelings – What did you think and feel about it?
  3. Evaluation – What were the positives and negatives?
  4. Analysis – What sense can you make of it?
  5. Conclusion – What else could you have done?
  6. Action Plan – What will you do next time?

This is a series of questions to help you think through what has happened. This can be used as a guide for analyzing a critical incident or for general reflection on experiences. John’s model supports the need for the learner to work with a supervisor throughout the experience. It also recommends that the student use a structured diary. This model suggests the student should ‘look in on the situation’, which would include focusing on oneself and paying attention to thoughts and emotions. The model then advises to ‘look out of the situation’ and write a description of the situation around thoughts and feelings, what they are trying to achieve, why they responded in the way you did, how others were feeling, did they act in the best way, ethical concepts, etc.

Rolfe uses three simple questions to reflect on a situation: What? So what? Now what? He considers the final question as the one that can make the greatest contribution to practice.

What …is the problem? …was my role? …happened? …were the consequences?

So what …was going through my mind? …should I have done? …do I know about what happened now?

Now what …do I need to do? …broader issues have been raised? …might happen now?

Place students in contexts in which they have direct contact with people who are different from themselves. Students in internship settings experience organizational and professional cultures that are new to them. Interpersonally, students work day to day with coworkers representing various ages, races, cultural backgrounds, professional roles, stages of career development, and more. Research on internships suggests that from these experiences students increase their multicultural skills, improve their skills in getting along with others in the workplace, and improve their communication skills

Provide students with frequent feedback about their performance. High quality internships are rich in feedback for students. The very structure of internships engages students with both a supervisor in the workplace and a faculty mentor, both of whom provide guidance, support, and feedback throughout the experience. Research supports the idea that internships that offer extensive feedback are perceived most positively by students and that strong mentoring and
feedback from the workplace supervisor and from the faculty mentor are important components of internship effectiveness. More finely-grained research further begins to clarify the effects of specific characteristics of internship supervisors, such as their understanding of the relationship between theory and practice and their preferred learning styles on the supervision that they provide.

Provide opportunities for students to see how what they are learning works in different settings. One of the most common assertions in the internship literature is the central importance of linking theory and practice and engaging in transfer of learning in these experiences. Scholars note this as a particularly complex aspect of the internship experience and one that requires careful course design, close mentoring, and on-going feedback and support from. Studies have found that through internships students can achieve deeper understanding of pertinent subject matter and disciplinary concepts and grow in their ability to select, access, and apply relevant knowledge to ambiguous problems and circumstances.

Help students gain a better understanding of self in relation to others. Internships place students in complex social situations in the workplace where they can experience themselves in new contexts and types of relationships. It is not surprising then that research suggests that internships can help students grow in self-understanding and self-confidence. Among these findings are that students increase in self-concept crystallization and career choice clarification, report enhanced self-esteem and positive self-perceptions, gain an increased sense of self-efficacy, improve their interpersonal and communication skills, feel better prepared to enter the workforce and/or graduate school, grow in their confidence in their own skills and knowledge and develop a more mature and realistic understanding of the world of work and how to work with others in the workplace.

Internship Program Schedule

Tips for Developing an Internship Program Schedule

To ensure your interns get valuable exposure to the different areas of your organization, consider developing an internship program schedule populated with activities for interns to connect more deeply with the company, build skills, and bond with one another.

One of the keys to developing an effective internship program schedule is to start early. It takes time to develop a comprehensive schedule, and to enlist the people and obtain the resources you need. A reasonable allotment of time is five to six months so you will be ready when your interns arrive. Following are more tips for developing and implementing an internship program schedule:

This could include a welcome from your CEO, a team-building activity for interns, time with managers to review specific objectives and see the work area, sessions such as an assessment focused on communication styles and time management, and more.

If you do a group project, be sure to include on the schedule the weekly meetings and the final presentation to senior management. Send invitations to all attendees as early as possible to ensure strong attendance.

Be sensitive to any days the interns may be tied up with normal work events, e.g., interns may have work assignments every Wednesday and Thursday, so schedule intern events for Mondays, Tuesdays, or Fridays.

Be sure to plan at least one big social event. Invite the interns’ assigned mentors or buddies when appropriate.

Don’t just develop the skills they need for their internships, but for the long-term as well. Provide interns with skills they can use in the real world or if they join the organization full time. For example, offer weekly leadership skills training, which could include sessions on personal accountability, communication skills, and presentation skills.

Ask your training and development team what training it has that would be beneficial for the interns—If they don’t have anything that fits, see if they can build it. This is one of the reasons why you should start early. Doing so gives your training and development team the time to develop training if needed.

See what training, presentations, or other events the organization as a whole is offering during the intern program— Incorporate into your internship program schedule organization-wide events, such as company picnics and “lunch-and-learns.”

Invite your president, CEO, and senior management team to participate in intern orientation and events. They may be available to host an executive reception during the first week. Book these dates as early as possible to ensure a good turnout.

Set dates for interns’ mid-term and final evaluations—Set goals and expectations, and provide interns with honest assessments of their performance. Send reminders the week before meetings so the evaluations are completed.

Giving your interns an opportunity to shadow an employee gives interns exposure to another potential career path within your organization.

Regina Waters and Christina Gilstrap. NACE Journal, April 2012 National Association of Colleges and Employers