Student Privacy and Posting of Grades

November 18, 2003

MEMORANDUM

To: Instructional Faculty

From: Carla W. Montgomery, Associate Dean of the Graduate School; Earl J. Seaver, Vice Provost

Re: Student Privacy and the Posting of Grades

Each term, instructors face issues of how to make grades available to students in a timely and convenient manner. While this is certainly a good thing to do, we need to remind you that under state and Federal law, the students' privacy must be respected. This applies to posting grades both on sheets of paper in public places and on course/class Web sites. Likewise, it is not appropriate to leave a pile of student-identifiable papers or tests in a public place for students to pick up. The key point is that one cannot reveal personally identifiable academic information about a student, without a written release.

Thus, it is obviously inappropriate (indeed, illegal) to post student grades in public places (including electronic ones) with names attached. Use of Social Security numbers or Z-ID numbers for posting grades is also improper. Some instructors have sought to use a portion of the Social Security number as identifier, having students in the class sign a waiver of their usual rights to privacy to make this possible.

Ken Davidson, the university's General Counsel and designated Privacy Officer, has offered his guidance: Those who post grades should use a system that ensures a student's identity is not recognizable by unauthorized people. Using code words or randomly assigned numbers that only the instructor and individual students know can do this.

In addition, a recent ruling from the U.S. Department of Education prohibits the posting of any portion of a student's Social Security number. Thus, using (for example) the last four digits of the SSN is a violation of the privacy laws.

Given the foregoing, what are reasonable ways of posting grades in a manner which preserves the students' privacy? Options include:

  1. Give students randomly generated numbers or words as identifiers, and post grades according to those numbers or words (not arranged according to the alphabetized names of the students!). Or, let students choose their own identifiers (numeric or verbal) -- again, just don't list in the equivalent of alphabetical-order-by-name.
  2. Web course management systems such as Blackboard have features for posting grades on course websites in a secure manner so that students enrolled in a particular course made available through Blackboard can view their individual grades using their login id and password. If you already use Blackboard, you may wish to consider posting course grades in this way. If you currently do not use Blackboard and would like to learn more about this system and its features for teaching purposes, please contact the Faculty Development and Instructional Design Center or your college computing staff.

We appreciate your cooperation in protecting students' privacy in accordance with the law. If you have questions about a proposed practice, feel free to contact us.

cc: College Deans
Provost's Staff
Kenneth L. Davidson
Murali Krishnamurthi
Donald Larson