As noted in the Family Educational Rights and Privacy Act (FERPA), personally identifiable information (FERPA Data) includes, but is not limited to:
- Student’s name
- Student’s parent or other family member
- Address of the student or student’s family
- A personal identifier, such as the student’s social security number or student generated number, or biometric record
- Other information that, alone or in combination, is linkable to a specific student that would allow identification of the student with reasonable certainty
Authority: 20 U.S.C. I232g
University communication of issues related to student efforts (academic, conduct, and/or employment) may necessitate utilization of electronic communication such as email(s). However, misdirected email(s) may result in exposure of student personally identifiable information to those without a legitimate educational interest in the information. Federal regulations require we establish “reasonable methods” to ensure that school officials only obtain records in which they have a legitimate educational interest. To obviate the potential FERPA violation caused by a misdirected email, the university guidelines as follows are established:
- Do not include personally identifiable FERPA data in totality in an email: no full name and full generated student ID.
- Do not list name and ID in the subject line
- Communicate using either the student ID with the full initials of the student [999999999 (ANW)] or use the full name with the last four of the ID [Alice N. Wonderland (1234)]
- Do not attach spreadsheets or scanned documents with full identifiers or non-directory information via email. Communicate spreadsheets or scanned documents via a secure link or SCHOLAR or shared electronic files requiring a log in
- Do not store FERPA data on a flash drive.
If forwarding items with personally identifiable FERPA data, use a cover sheet directing the recipient to contact you if it is misdirected. For example, the cover sheet may state:
- Academic Record Disclosure: You are receiving this information as determined by the educational right to know disclosure guidelines of the Family Educational Rights and Privacy Act (FERPA). If you are not the intended recipient, please do not disclose, copy or distribute this information.
- Please notify the sender immediately by return electronic e-mail or by telephone at [insert phone number]. Thank you.
Contact the University Registrar if you have questions relative to compliance with these guidelines.