Student Privacy Issues

Sailing away the winter blues with ISFAA …

2015 Winter Conference

Topics

• The Challenges of Protecting Privacy

• Policy and Procedure

• Marrying Customer Service with Managing Security

Inquiry Methods• Telephone• Email• Postal mail• Fax• In person• Social Media• Subpoena

Directory Information• Institutions may disclose information on a student

without violating FERPA if it has designated that information as directory information– Name, email address, address, telephone number– college/school and curriculum, enrollment status and credit

hour load– enrollment status and credit hour load– dates of attendance, classification– receipt or non-receipt of a degree– academic awards received (dean’s list, honors students)– participation in officially recognized activities– sports photograph, position, weight, and height of athletes

Personally Identifiable Information• PII is information that can be used to

distinguish a person’s identify– name, social security number, biometric data, etc.,

alone, or when combined with other personal data, linked or linkable to a specific person, such as date and place of birth, mother’s maiden name, etc.”

The Challenges of Data Security

• Determining identity and right to information

• Fraud and abuse

• Disinclination and disregard

• Policy and regulations

• System and physical limitations

Setting Policy• Put controls in place to minimize fraud and

abuse before they can occur• NASFAA’s Statement of Ethical Principles– Manifest the highest level of integrity• Protect the privacy of individual student

financial records.

Insuring Policy Compliance• Train and frequently reinforce• Model behavior • Insure staff buy-in• Consistently verify ID

Identity Confirmation Policy for Student Specific Information

Person Method of Communication

In Person Email On Phone

StudentPresent their photo ID OR name, DOB and last 4 of their SSN

Send email from their purdue.edu email address and include the PUID

Provide PUID, full name and DOB OR full name, DOB and last 4 of SSN

Parent on FAFSAPresent their photo ID OR name, DOB and last 4 of their SSN

Send email from the address that they used on the FAFSA application and the student's name and PUID

Provide student's PUID, and DOB, their name, DOB and the last 4 numbers of their SSN

Parent not on FAFSA

General information only unless they are a PLUS borrower, then present photo ID OR name, DOB and last 4 of their SSN

General information only unless they are a PLUS borrower, then student's full name and DOB, their full name, DOB and address used on their PLUS application

General information only unless they are a PLUS borrower, then student's name, and DOB, their name, DOB, the address used on the PLUS application and the last 4 numbers of their SSN

Spouse of Independent

Student General information only General information only General information only

Parent of Independent

Student General information only General information only General information only

Marrying Customer Service & Security

• Explain why you need to verify ID • Emphasize what you can provide• Give suggestions on how individuals can get

information you cannot provide them• Explain why you cannot provide the

information they seek• Provide empathy

Email Inquiry Forms• https://www.purdue.edu/dfa/email.php• https://

contact.scu.indiana.edu/contact/index.shtml• http://

cms.bsu.edu/admissions/scholarshipsandfinancialaid/aboutouroffice/contactus

Case Study• Listen to the scenario• Discuss it with your neighbor and decide how

you would respond• Share your ideas with the group

Questions or Comments?

Thank you for your attendance and participation.

Marcia Osman, Assistant Director of Client Services and State Aid ProgramsPurdue University, Division of Financial Aidmlosman@purdue.edu