Education Record and Personal Identifiers
An education record is any file, document, or record which contain information related to an identifiable student. Education records include but are not limited to grades, transcripts, class lists, student papers, student exams, student databases, student class schedules, financial records, correspondence, email, handwritten notations, and student discipline files. The information may be recorded in any way, including, but not limited to, handwriting, print, computer media, videotape, audiotape, film, microfilm, microfiche, and e-mail. Student health records are not considered education records at a postsecondary institution.
Personal Identifiers are Social Security numbers, credit or debit card numbers, driver’s license (or non-driver identification) numbers, bank account numbers, visa or passport numbers, protected health information subject to the Health Insurance Portability and Accountability Act (HIPAA), and personal financial information subject to the Gramm-Leach-Bliley Act (GLBA). These are considered high-risk data when they appear in conjunction with an individual’s legal name or other identifier.