Elimination of Social Security Numbers as Primary Identifiers and FERPA

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: