Elimination of Social Security Numbers as Primary Identifiers

EDUCAUSE joined the American Council on Education (ACE) in comments to respond to a Notice of Proposed Rulemaking regarding the Family Educational Rights and Privacy Act (FERPA). The EDUCAUSE contribution addressed the proposed rules treatment of Social Security Numbers (SSN's), Student ID Numbers, and Student User ID's in the context of "directory information." The comments state:

The U.S. Department of Education has issued a Notice of Proposed Rulemaking with proposed regulations pertaining to the Family Education Rights and Privacy (FERPA). Among other things, "the proposed regulations respond to changes in information technology and address other issues identified through the Department's experience administering FERPA," according to the Notice. Additionally, the regulations are needed to implement amendments to FERPA contained in the USA Patriot Act and the Campus Sex Crimes Prevention Act, to implement two U.S. Supreme Court decisions interpreting FERPA, and to make other necessary changes.

Among the IT-related changes are:

On December 10 and 11, 2007, the Federal Trade Commission will host a public workshop, “Security in Numbers: SSNs and ID Theft,” to explore the uses of Social Security numbers in the private sector and the role of SSNs in identity theft.  This workshop continues the work of the President’s Identity Theft Task Force, and, in particular, its recommendation to explore ways to reduce unnecessary uses of the SSN. 

The workshop will provide a forum for public-sector, private-sector, and consumer representatives to discuss the various uses of SSNs by the private sector, the necessity of those uses, alternatives available, the challenges faced by the private sector in moving away from using SSNs, and how SSNs are obtained and used by identity thieves.  The workshop will be free and open to the public.

For more information, visit http://www.ftc.gov/bcp/workshops/ssn/index.shtml

The Federal Trade Commission (FTC) has announced that it is seeking comments on the use of Social Security Numbers (SSNs) in the private sector. This inquiry is in response to a recommendation in the President’s Identity Theft Task Force Strategic Plan that called for the development of a comprehensive record on the uses of the SSN in the private sector and evaluate the necessity of those uses.