Re: FERPA Notice of Proposed Rulemaking Addresses Changes in IT

[Kevin Shalla <kshalla () UIC EDU>]

Thanks Rodney,

It seems that the legislators here are confusing identification with
authentication.  I hope that universities learned from the social
security number problem (a number, stored in thousands if not
millions of IT systems around the country, properly used for
identification and improperly used (because it's convenient) as
authentication) and are not allowing knowledge of a student ID number
to gain access to anything.  I'm pushing to define student ID as
directory information so that it cannot ever be used for
authentication, but some on campus are afraid of doing this.

What do others think?

Kevin

At 12:58 PM 3/31/2008, Rodney Petersen wrote:

> The U.S. Department of Education has issued a Notice of Proposed
> Rulemaking
> (<http://edocket.access.gpo.gov/2008/pdf/E8-5790.pdf>http://edocket.access.gpo.gov/2008/pdf/E8-5790.pdf)
> with proposed regulations pertaining to the Family Education Rights
> and Privacy (FERPA).   Among other things, "the proposed regulations
> respond to changes in information technology and address other
> issues identified through the Department's experience administering
> FERPA," according to the Notice. Additionally, the regulations are
> needed to implement amendments to FERPA contained in the USA Patriot
> Act and the Campus Sex Crimes Prevention Act, to implement two U.S.
> Supreme Court decisions interpreting FERPA, and to make other
> necessary changes.
>
> Among the IT-related changes are:
>    * Clarification of what can be included as directory
> information, addressing Social Security Number (SSN), other student
> ID numbers, and email addresses
>    * Requiring the use of reasonable methods to identify and
> authenticate the identity of students, parents, school officials,
> and any other parties to whom personally identifiable information is disclosed
>    * Recommendations to assist institutions in safeguarding
> educational records (Note:  this is covered on page 15598 of
> Federal Register Notice or page 26 of PDF document.)
>
> The deadline for comments is May 8, 2008.
>
> The EDUCAUSE Washington Office
> (<http://www.educause.edu/policy>http://www.educause.edu/policy) is
> reviewing the proposed changes and welcome your comments or
> questions (send comments to rpetersen () educause edu). We will provide
> a more detailed analysis of the proposed rules and any further
> updates at a later date.
>
> -Rodney
>
> --------------------------------------------------
> Rodney J. Petersen, J.D.
> Government Relations Officer & Security Task Force Coordinator
>
> EDUCAUSE
> 1150 18th Street, N.W., Suite 1010
> Washington, D.C. 20036
> (202) 331-5368 / (202) 872-4200
> (202) 872-4318 (FAX)
> EDUCAUSE/Internet2 Security Task Force
> <http://www.educause.edu/security>www.educause.edu/security
> --------------------------------------------------