Ask the FERPA Professor

LeRoy Rooker |
October 2, 2018
  • FERPA
  • Identity Management
  • Recordkeeping Compliance
  • Records and Academic Services
  • Student Academic Records and Academic Policy
  • FERPA Professor
  • student
deuc4dqdrbqwifk27ppv_shutterstock_26355862 Dear FERPA Professor:

A university officers has asked us to have student ID added to our list of directory information. I looked in the FERPA Guide (p. 3) and found the following, which is ambiguous since there’s not a period after the first phrase and there is an exception:
“Clarifying that student identification numbers cannot be designated as directory information, except when they are only used to identify a student in an electronic system of records and cannot be used alone to gain access to education records."

Are there additional places I can look to find more supporting evidence of why student ID should not be part of directory information?

Thank you,
Sally Forth

________________________________________________________________

Dear Sally:

Generally, institutions are prohibited from including student ID's as a "directory information" item. 

See  99.3 "Directory Information" (b)(2) and (c)(1) of the FERPA regulations. The regulatory language can be found on page 153 of the 2012 Guide. In addition, see page 212 of the 2012 AACRAO FERPA Guide for the letter that was the basis for this regulatory change, added in the 2009 regulations. This letter does, however, permit the inclusion of the ID under very limited circumstances. 

I hope this is helpful in answering your inquiry

The FERPA Professor

AACRAO members, send your questions to the FERPA Professor at connect@aacrao.org.