It is critical that schools ensure compliance with all applicable laws and regulations. Of particular importance is protecting student privacy and protecting them from identity theft. Of particular concern is the use of Social Security Numbers (SSNs) to track students. While SSNs can be extremely useful to have a common identifier to track students over time, it also is a common identifier, that if stolen, can lead to identity theft.
Highlands Community Charter School was placed in the difficult situation of having the California Department of Education ask it to collect student SSNs, while also being aware of the recently passed Assembly Bill 2097, which forbids schools from collecting SSNs from students. I was asked to solve this conundrum.
I first contacted the Data Privacy folks at the Educational Data Management Division/Education Data Office, to confirm the issue. Due to the localized nature of school district decisions, they were not able to give a definitive answer, but highly suggested to not collect Socials Security Numbers. So I then dived into legal research, ultimately drafting a short report: Collecting Social Security Numbers for WIOA Title II in California – A Legal Research Paper, which showed fairly clearly that any California public school that collects SSNs would be in violation of the law.
Highlands Community Charter School prudently followed the recommendation of the report. This report was then also shared with the California Department of Education’s division in charge of administering the WIOA Title II grant, and hopefully they are working on a better solution than inadvertently asking schools to violate privacy laws.
I have also done other work protecting student data privacy and security, including helping Grant Adult Education change their data system to not use Social Security Numbers as the students’ student ID. More information about that work can be found here.