Student Data Use at the University

Below are examples of how student data is used at the University of Colorado Boulder:

  • Spreadsheets and other attachments that clearly identify a student - even if just a last name or an SID - and contains other protected student data (GPA's, courses, probation information, suspension information, etc.) AND ARE NOT PASSWORD PROTECTED! If there is any Personally Identifiable Information (PII) that clearly links a student with non-directory FERPA data, and it falls into the hands of someone who does not have a legitimate educational interest in receiving this data, it is a FERPA violation.
    NOTE: you might be very careful in addressing the e-mail to a recipient who also has a legitimate educational interest in this data, but e-mail is not a secured method of communication. (APS Use of Electronic Mail and Student e-mail policy). Never send an unprotected file of protected data via e-mail unless it is password protected. In addition, we have seen on occasion unsecured attachments that may have legitimately been sent to someone on campus, but then forwarded on to others who have no legitimate educational interest (as defined by FERPA) in having access to this data. Always password protect a file.You might now be wondering if it is OK to send a spreadsheet of names with directory information (college, major, etc.) This would be fine UNLESS it contains information about a student who has full privacy protection. Then again, you must password protect the file. The best practice - always protect the file - even if it only contains SIDs.
  • What if the body of the e-mail contains SID, full name and protected data? Is this OK to send? Same problem as above - but we understand the need to communicate with others on campus about sensitive student matters. Best practice is to use the last four digits of the student ID if you are communicating about a small number of students. Not as good but acceptable is using the SID with last name/initial only. But in the event you are communicating about a number of students, put it in an attachment and password protect it.
  • Do you know that if you have documents that have FERPA protected data about students, you need to dispose of them in confidential disposal? Just putting them in your desk-side trash or recycle can expose this data to individuals who do not have a legitimate educational interest in seeing this data. Always dispose of this in a confidential disposal bin or shred the document.
  • Never send SSN's via e-mail. Identify theft is on the rise. CBS This Morning did a report on identity theft tax fraud "spreading like wildfire." This report cited employees of schools and hospitals with access to personal data were as primary sources for scammers to obtain data needed for perpetrating this fraud. Sadly, as stewards of significant amounts of personal data on students, faculty and staff in our university community we need to have a heightened awareness of this and the vulnerabilities it presents. Data breaches are costly for everyone. Protect data from our systems like you would your own personal data.

We have seen a number of ISIS screenshots sent via e-mail lately that clearly identify the student (or the student is identified in the body of the e-mail) and contains a great deal of sensitive data, or data the recipient may not have a legitimate educational interest in receiving. Please use your knowledge of FERPA and university policies before sending this much information out about a student, and if still needed - send the screenshot as a password protected document.

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