State Law Prohibits Use of SSNs

(This article first appeared in the Fall 1999 issue of In Brief.)

Recent action by the Arizona legislature has all but eliminated a once common method of posting grades. College and university instructors have long posted examination and final grades of their students by associating such grades with all or part of the students' social security numbers. Such practice, however, is now illegal. Under A.R.S. Section 15-1823, officials of a university or community college in Arizona may not publicly display any four or more numbers of a student's social security number. This prohibition extends beyond the traditional practice of posting grades on an instructor's office door.

The new act also prohibits displaying part or all of a student's social security number "on any Internet site maintained by the community college or community college district or any other publicly accessible document for any purpose."

The Family Educational Rights and Privacy Act-the Federal statute that protects the confidentiality of education records-has long prohibited the public display of a student's grades in such a manner as to allow the student to be identified.

Faculty have typically-in deference to FERPA-used several digits of their students' social security numbers as a way of posting grades without revealing those students' identities. The practice has long been ill advised, however, chiefly because of the possibility that social security numbers might be discovered through other means. The preferred practice has been to assign internal identifying numbers to students, or simply cease the practice of posting altogether.

Now, with the enactment of A.R.S. Section 15-1823, faculty at Arizona community colleges should refrain from using any portion of a student's social security number to display information about the student-whether it be on an office door or a Web site.

Published in the Winter 2003 Edition of In Brief