Re: Last 4 digits of SSN and birthdate

[Brian Reilly <reillyb () GEORGETOWN EDU>]

Elizabeth,

There's a FERPA policy interpretation letter from the Department of
Education that addresses posting student grades along with 4 digits of
an SSN here: http://www.ed.gov/policy/gen/guid/fpco/doc/hunter.doc

While it's not quite the same situation, of note in the letter is the
Department of Education's indication that "...a social security
number, or portions thereof, are by definition 'personally
identifiable information' under FERPA...".  If pledge cards were
determined to be _public disclosure_ (and I don't know if they would
be), one could reason that they should not contain a portion of an
individual's SSN.  I have no idea if this interpretation has since
been challenged or changed, but it may be at least worth considering.

Regards,

Brian


On 10/26/05, Elizabeth Shannon <eshannon () pittstate edu> wrote:
> A representative of University Advancement contacted me and wanted to
> know if printing a person's birthday (MM/DD/YYYY) and the last 4 digits
> of the person's SSN on pledge cards was acceptable.  The reason for
> "needing" this info is it allows staff to search the alumni database
> much faster.  Other info printed on the card: first name, middle
> initial, last name, phone number, and address.
>
> I can not find any sources prohibiting their request, but I am not
> comfortable with displaying this info. I am concerned with the
> precedence this  may set with other departments.  Any suggestions or
> links to info would be appreciated.
>
> Elizabeth Shannon
> Pittsburg State University - Kansas