Response to Charge S-9802: Investigate and report on the implications of the use of Social Security numbers as student identification numbers as the practice relates to privacy, confidentiality, and security, and to consult with University Counsel re legal aspects.
Background - Reasons for Concern
The widespread availability of personal information on the Internet has created national concern about issues of privacy, and in particular about identity theft. Identity theft occurs when someone obtains sufficient personal information about another individual to obtain loans or credit cards, or to incur other debts, in the victimís name. Identity theft nearly always requires that the perpetrator obtain another individualís Social Security number. Such fraudulent use of Social Security numbers is increasing. For example, in the period 1997-1999, the Social Security Administration Hot Line reported 16,375 calls alleging misuse of Social Security numbers, 81.5 percent of which involved identity theft (see the Social Security Administration web site). The Social Security Administration and other consumer groups recommend that consumers protect themselves by limiting unnecessary use of their Social Security numbers.
Although the Social Security number was originally intended to be used only in conjunction with the Social Security system, the existence of a unique identifying number assigned to each individual has made it an attractive means of uniquely identifying individuals in a variety of contexts. Universities, in particular, have made use of these numbers as unique identifiers for their students. Use of the Social Security number as a student number presents numerous opportunities where the numbers may be accessible and linked with a name. Printed rosters contain both name and student ID number, and potentially make this information available to many individuals, both authorized and non-authorized. The inherent danger in this was recognized by Congress in its passage of the Family Education Rights and Privacy Act (FERPA), which prohibits release of certain directory information without the studentís consent (e.g., information related to a student's academic transcript or grades, schedule of classes and/or class location, number of hours for which the student is enrolled, Social Security number, deficiencies in graduation requirements or race/ethnicity).
Rutgers is among those universities which uses the Social Security number as a student ID number. Until 1987, Rutgers assigned a six-digit student number; by 1988, only Social Security numbers were being used. Although the University has been responsible in following the guidelines set down in FERPA, it is impossible in a large University to ensure that all faculty follow the guidelines, and that all rosters are kept secure even after the end of the semester. Moreover, linked names and Social Security numbers are made available in many other ways: students must give both pieces of information when participating in intramural sports, must present their ID cards when using computer equipment, borrowing equipment or reserve materials, are asked to put their ID numbers on checks or credit-card receipts at cashiersí offices or bookstores (in which case Social Security numbers are being linked to existing financial or credit-card information, increasing the risk of identity or credit theft), etc. Although there are many instances in which students need to be uniquely identified, the wide range of opportunities presented within the University for obtaining personal information that should be kept secure makes the continued use of Social Security numbers as student numbers undesirable and potentially dangerous.
The University should take immediate steps to identify and eliminate unnecessary use of student identification numbers; for example, on sign-in sheets for intramural sports.
The University should intensify efforts to ensure that rosters are kept confidential.
The University should make a commitment to use unique student identification numbers as soon as it is possible to do so, and, toward that end, should undertake a cost-benefit analysis which addresses the following questions:
What patches would be necessary to accommodate the shift to new numbers?
What would be the approximate cost of converting to student identification numbers that are not Social Security numbers?
What would be the timeframe for implementing the change?
What is the minimum number of digits required for non-Social Security number student ID numbers, if that number has increased from the previously used six digits? How is it possible that a number larger than nine digits would be required?
Could the numbers currently assigned to the Knight Express/ID cards be used?
Whereas, identity theft is an increasingly serious problem which is linked to inappropriate access to personal information, including Social Security numbers; and,
Whereas, limiting the availability of Social Security numbers is seen as an effective method of reducing identity theft; and,
Whereas, the Rutgers University Senate Student Affairs and Executive Committees have considered this issue, and developed a report and recommendations, based on their findings, aimed at reducing the use and availability of studentsí and othersí Social Security numbers at Rutgers;
THEREFORE, Be It Resolved, that the Rutgers University Senate accepts and endorses the Report on "Use of Social Security Numbers as Student Identification Numbers," and urges the administration to implements its recommendations.
Student Affairs Committee Membership Senate Executive Committee Membership