Optional Data Element and Functionality Allows Institutions to Satisfy Changing Data Privacy Requirements
The regulatory environment surrounding data privacy is changing rapidly. The European Union’s General Data Privacy Regulation (GDPR) and California’s Consumer Privacy Act (CCPA) are only two of many examples where regions, countries, and states are taking a more direct approach towards protecting consumer privacy. As data privacy continues to evolve, institutions require a solution that is dynamic and able to support student requests for record level blocks separate from what the Family Educational Rights and Privacy Act (FERPA) currently offers. The Clearinghouse has developed functionality that fits these needs, will support schools in meeting current regulatory obligations, and that we consider will support needs as they continue to evolve over time.
The Privacy Block Setting
On July 19, 2020, the Clearinghouse released a new “Privacy Block Setting” (PBS) drop-down field on our secure site web applications for enrollment and degree reporting. This optional field will allow schools that have signed the appropriate Privacy Block Setting Addendum the option to select from the following PBS values depending upon the type of data usage restriction requested by the student, and perform an individual update on the student’s record.
|Blank (default)||Default value for Privacy Block Setting. A blank PBS means that the student has no Privacy Block Setting and/or your institution has not programmed the Privacy Block Setting for all students. NOTE: Once you populate the privacy block with another value (00-03), it cannot go back to being blank again.|
|00 (no PBS)||Student has no Privacy Block Setting. This is used whenever your institution programs for the Privacy Block Setting values and/or changes from a higher value to no block.|
|01||Student detail containing Personally Identifiable Information (PII) for which the consent to use has not been received is blocked from use for research purposes. Student data can be used in de-identified and aggregate reports as well as research reports with student consent.|
|02||Student data blocked from use in non-consented verifications.|
|03||Student detail containing Personally Identifiable Information (PII) for which the consent to use has not been received is blocked from use for research purposes and in non-consented verifications. Student data can be used in de-identified and aggregate reports as well as both research and verifications with student consent.|
The Clearinghouse Solution and Data Integrity
The Clearinghouse’s solution enables schools to submit individual student updates on these privacy blocks through our secure site. The institution can review, remove, add, or update a block that was previously reported through our individual update process.
We also programmed these Privacy Block Setting to be ingested via the enrollment file intake process for those institutions that would like to include PBS values in their standard enrollment reporting transmissions.
If you wish to include the PBS values in your enrollment files to the Clearinghouse, we highly encourage you to reach out to your Student Information System (SIS) vendor to ensure that they update the file extract to include the appropriate field and options. If your institution uses a homegrown Student Information System, please work internally with your IT team to report these values in your enrollment files to the Clearinghouse. In the meantime, the Clearinghouse will continue to offer our individual update solution for schools that are unable to incorporate these values into their file extract process.
For more detailed information on how the Privacy Block Settings impact each of the Clearinghouse Services, please refer to the Directory Block and Privacy Block FAQs (the link is also available on our secure site).
If you are interested in submitting the Privacy Block Setting for students at your institution, please contact our Implementations team at firstname.lastname@example.org for a copy of the required Privacy Block Setting Addendum.
For additional questions related to your enrollment and compliance reporting, please contact our Compliance and Data Operations team at email@example.com or 703.742.4200 (select options #7, #2).
- Enrollment Reporting Programming and Testing guide
- Enrollment Reporting: An Introduction (please watch the tutorial on “Privacy Block Setting”)
- Enrollment Reporting: Error resolution (please watch the tutorial on “Error 215 – Privacy Block Setting Previously Reported”)
- Directory Block and Privacy Block FAQs