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Forum Guide to Protecting the Privacy of Student Information: State and Local Education Agencies

3.D. Protecting Unique Identification Codes

Using unique identification codes would:

  • allow the records to follow the correct students when they move within the state; and
  • provide the flexibility of merging data from different files to promote efficiency without threatening privacy.

Some state education agencies assign a set of sequential identification numbers for schools or school districts to use so that the identification number of a student is unique within the state. It is a good practice that school districts provide to each student a system-generated number that contains no imbedded information.

Many educators and social service providers inquire about the use of social security numbers. The social security number has the advantage of being unique to students and does not change when they move to another city or state. Using the social security number can make it easier for schools to locate the appropriate transcript or student information when they receive a request. The numbers can be used to share information or conduct studies across agencies only with prior written consent, as required by FERPA. Some states exchange information about families across agencies to determine eligibility for services. For example, with prior consent from parents several states use social security numbers and other family information to link across Temporary Assistance for Needy Families and other public assistance files to establish a studentís eligibility for the additional support and services, to count the number of economically disadvantaged students that qualify a campus for Title I funding, and to establish a studentís eligibility for vocational and job training programs.

In general, schools, school districts, and state education agencies cannot release the social security numbers of students because this is considered personal information and is part of the education records under FERPA. While federal law limits the use and release of social security numbers, it does not prohibit schools from asking for the number. Specifically, schools can ask for a childís social security number but cannot require it, and schools must inform parents that they do not have to provide the social security number. Schools also cannot deny any right, privilege, or benefit to students or their parents who refuse to disclose a social security number. Schools that use social security numbers should be prepared to issue an alternative code in case of such refusal. In addition, it is important for school officials to be aware that it is difficult and time consuming to check the accuracy of the social security numbers given. For example, some parents may not recall the social security number for their child or may give a wrong number. For these reasons, social security numbers would mostly be used as an attribute for checking against duplicate records, rather than as an identification code.

More thorough discussions of the use of social security numbers versus other identifiers can be found in papers prepared for several state education agencies (e.g., New York, Massachusetts, and California) (Clements and Ligon 2001; Ligon 1997).4 Since social security numbers are used to maintain confidential information by other agencies outside the education system, it is crucial to ensure that no one gets illegal access to the numbers. Security is far more important with social security numbers than locally assigned identifiers, because the identity of a person is easily revealed with his or her social security number. For example, the printing or display of social security numbers on education documents demands a higher degree of diligence from everyone handling those documents. In fact, some state laws prevent the display of social security numbers on student records. Many state and local education agencies establishing a unique student identifier system rely not on social security numbers, but on an alternate, system-generated number using, without exposing, such personal characteristics as name and date of birth. Social security numbers, if maintained, are thus kept as an additional item for accuracy checks, but not as an identifier. Their uses are restricted to very limited purposes. In states using social security numbers, an attorney generalís opinion, legislative authority, or state board of education authority is typically secured first.

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4 Clements, Barbara, and Glynn Ligon, Designing and Implementing a System for Assigning Student Identifiers in New York, Evaluation Software Publishing, Inc., Austin, Texas, April 2001. This paper and similar studies for Massachusetts and California can be found at the website: [http://www.evalsoft.com].

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National Center for Education Statistics - http://nces.ed.gov
U.S. Department of Education