Elimination of Social Security Numbers as Primary Identifiers and Identity Management

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:

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.