Regarding the Use of SSNs in Education and Related Data Systems

1. Regarding the Use of SSNs in Education and Related Data Systems

2. Related Laws • Family Educational Rights and Privacy Act (FERPA) – Public Law 93-380 • The Social Security Act of 1935 • The Privacy Act of 1974 – Public Law 93-579 • The Computer Matching and Privacy Protection Act of 1988 – Public Law 100-503 • The No Child Left Behind Act- Public Law 107-110 • The Workforce Investment Act of 1998 – Public Law 105-220 • The Carl D. Perkins Career and Technical Education Act Amendments of 2006 - Public Law 105-332 • The Individuals with Disabilities Education Act- Public Law 94-142 • The Higher Education Act- Public Law 105-244 • The Chafee Foster Care Independence Act of 1999- Public Law 106-169

3. Key Uses of the SSNs in Florida • Embedded in the ID systems of public PK12, Workforce Education, Adult Education, Community Colleges, and Universities: • Helps assure relational integrity of formats that comprise the reporting systems • Helped facilitate interstate transfers of K12 and postsecondary data such as between Louisiana and Florida following Katrina/Rita • Helps with state/local administrative requirements such as pre-certification for free and reduced lunch (food stamps linkages); driver’s license suspensions caused by non-attendance; migrant student education program data bases • Facilitates transcript exchanges

4. Key Uses of the SSNs…more • Used to link students with their teachers, counselors, coaches and others in K12 • Used to link teachers to certification information, retirement information • Used to link K12 students to Bright Futures financial aid data base, the FASFA, and SAT student questionnaires as well as other financial aid programs • Facilitates creating postsecondary feedback reports, linking K12 student data to placement tests, enrollment, and persistence information • Facilitates postsecondary degree audit procedure for postsecondary students (tracks across programs and sectors)

5. Key Uses of the SSNs…more • Used to verify postsecondary enrollments associated with payments on federally-insured student loans • Used to track the performance of community college students in the upper division of state universities • Underpins the operation of the Florida Education and Training Placement Information Program (FETPIP) as required in state law (this system tracks employment, military enlistment, postsecondary enrollments – including the National Student Loan Clearinghouse • Is an important part of the identity management matching processes in the PK20 Education Data Warehouse (EDW)

6. “Clearly Permissible Sharing” • Directory Information • Anonymous data that does not disclose personally identifiable information • Personally identifiable data for limited purposes: • Evaluating/auditing state and local education programs • Establishing system accountability • Monitoring and analyzing assessment, enrollment, and graduation data • Performing studies to improve instruction • Sharing records among schools • Maintaining a process to link teachers/instructors and students

7. Cautions • The public is rightfully skittish about the use of SSNs, especially for children • SSN provision should never be a condition of enrollment in public education, alternatives should be available • SSN reporting is subject to several sources of significant error including applicability, validity, and accuracy • SSNs should not be integral to the assignment of identification numbers • The use of SSNs in education data systems should be limited to “must do situations” involving such things as transcript transfers out-of-state, financial aid processes, linkages to postsecondary and the workforce