1. FERPA HEA Privacy Act: Protecting Students Data
Presenter: Sharon J. Oliver, North Carolina Central University
SASFAA President
Fall Conference November 6 - 8, 2017

2. Fall Conference November 6 - 8, 2017
Agenda
Protecting the Release of Student Data
Privacy and Security Responsibilities
Authenticating Students
In Person
Telephone
Communication
Prior to Releasing Data
Fall Conference November 6 - 8, 2017

3. Statutory and Regulatory Restrictions
DOE’s Privacy and Technical Assistance Center (PTAC)
Laws Governing the Release of Student Data
Higher Education Act:
Section 483 (a)(3)(E) & Section 485B(d)(2)
Restricts the Release of Personally-Identifiable FAFSA information
FERPA
Privacy Act
Fall Conference November 6 - 8, 2017

4. Statutory and Regulatory Restrictions
FAFSA data… “shall be used only for the application, award, and administration of aid awarded under federal student aid programs, state aid, or aid awarded by eligible institutions or such entities as the Department may designate”
Spring Conference April , 2017

5. Financial Aid Professionals
“Collect, manage, and have access to a vast amount of confidential student and parent data”
Spring Conference April , 2017

6. Spring Conference April 9 - 12, 2017
Data Sources
Financial Student Data
FAFSA Data/ISIR
NSLDS (Financial Aid History)
COD Data
Tax Returns
PJ Documents
Student Progress Data
Spring Conference April , 2017

7. Statutory and Regulatory Restrictions
FAFSA Data
Expected Family Contribution (EFC)
Adjusted Gross Income
First Generation
Unmet Financial Need
Pell Grant Eligible
Part-time Employment (Federal Work-Study)
Awards
Fall Conference November 6 - 8, 2017

8. Fall Conference November 6 - 8, 2017
DOE New Requirements
Restricts Release of Student Information
Personally-Identified Information (PII)
Protect Student Information
External Entities
Internal Partners
Written Consent Unacceptable
De-identified, Aggregate, Descriptive Statistics about Program Participants is Permitted
Remove all PIIs (name, SSN, Banner ID#s, Direct and Indirect identifiers)
Fall Conference November 6 - 8, 2017

9. Spring Conference April 9 - 12, 2017
Data Partners
Disrupt Longstanding Practices
Schools
Outside Entities
Third Party Vendors
Institutional Offices/Departments
Private Scholarship Providers
Research Groups
External Entities
Spring Conference April , 2017

10. Spring Conference April 9 - 12, 2017
Funding Partners
Spring Conference April , 2017

11. Spring Conference April 9 - 12, 2017
Funding Partners
Spring Conference April , 2017

12. Data Partners/School Certifications
Scholarships
Alumni
Say Yes
Rental Agreements
Social Services
Gates Millennium
Spring Conference April , 2017

13. Release Student Records
FAFSA Data & Award Information
Written Consent Not Required
Independent Auditor
DOE
Accrediting Agencies
Other State and Local Education Agencies
Spring Conference April , 2017

14. Data Partners - State Agencies
NCSEAA
DCTAG
Veterans Affairs - ?
Vocational Rehabilitation - ?
WIA -?
Housing Authority - ?
Spring Conference April , 2017

15. Spring Conference April 9 - 12, 2017
Exceptions
Data Collected by the Institution
CSS Profile
Student Surveys
Spring Conference April , 2017

16. Properly Handling Confidential Data
Protect the Release of Private Student Data
School Provide Data to the Student
Letterhead
Student Portal
Student Provide Data to the Requesting Party
Campus Partners Submit a Data Request Form
GRE Fee Waiver Feedback
Attach Business Card in lieu of School Seal
School Representative Sign GRE Fee Waiver
Spring Conference April , 2017

17. Spring Conference April 9 - 12, 2017

18. Sample Letter – Third Party Entities
Spring Conference April , 2017

19. Spring Conference April 9 - 12, 2017
Campus Communication
Business Office
Bursar Office
Student Accounting
One-Stop Shop
Athletics
Departmental Scholarship Representatives
Admissions
Spring Conference April , 2017

20. Spring Conference April 9 - 12, 2017
Campus Communication
Meetings
Departmental
Deans
Faculty Senate
Campaign
Flyer
Conduct on campus “INFO” Sessions
Signage
Website
Campus TV Station
Spring Conference April , 2017

21. Authentication of Applicant’s
Secure Method
In Person FAFSA Applicant
Present Unexpired Valid Government Photo ID
Driver’s License
Non-Driver’s Identification Card
Other State Issued ID
U. S. Passport
Strengthen Internal Controls
Provide Training to Staff
Ensure Confidential Information is not Disclosed
Telephone Enhancement (ID & PIN)
College/University Only
Spring Conference April , 2017

22. Office Visitors Sample Notification
Spring Conference April , 2017

23. Spring Conference April 9 - 12, 2017
RESOURCES
McCarthy, Karen. (2017, August 15). Ed Revisiting Prior Guidance on Release of FAFSA Information. Retrieved from item/12905/ED_Revisiting_Prior_Guidance_on_Release_of_FAFSA_Information. McCarthy, Karen. (2017, September 6). Ed Reminds Schools of Privacy and Security Responsibilities. Retrieved from item/13073/ED_Reminds_Schools_of_Privacy_and_Security_Responsibilities. NASFAA and Cooley Higher Education. (June, 2017). Financial Aid Data Sharing. Retrieved from
Spring Conference April , 2017

24. Please visit them and let them know how much you appreciate it.
NCASFAA would like to thank our Professional Affiliates for their support.
Please visit them and let them know how much you appreciate it.
Fall Conference November 6 - 8, 2017