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This Week in Student Privacy: 8/11

De-Identifying Student Data

This week, Future of Privacy Forum releaseda new paper on the ‘de-identification’ of sensitive student information,” which discusses the value of student data, the types of personal information, strategies for de-identifying it, and regulations governing its use. De-identification would mean “purging student records of any information that is directly linked to an individual student, as well as removing or obscuring any indirect information that could allow others to figure out who an individual student is.” According to Future of Privacy Forum, three common strategies are “Blurring / Reducing the precision of disclosed data”, “Perturbation / Making small changes to the data”, and “Suppression / Removing data.”

Additionally, “in an era in which students generate massive amounts of digital information,” “educational agencies and institutions [...] must make a ‘reasonable determination that the student’s identity is not personally identifiable because of unique patterns of information about the student whether through single or multiple releases, and taking into account other reasonably available information.’”

The paper says that although “the release of education records that have been appropriately de-identified — purged of direct and all necessary indirect identifiers in a given context — is not considered ‘disclosure’ under FERPA,” “neither FERPA, nor the U.S. Department of Education’s FERPA regulation, provide a ‘safe harbor’ listing specific steps that lead to appropriate de-identification.”

Read more about de-identifying data: “‘De-Identifying’ Student Data: Next Front in the Privacy Wars?” (Education Week), “De-Identification & Student Data” (Future of Privacy Forum, 2015), and, for a discussion of the challenges of true anonymization, “Broken promises of Privacy: Responding to the Surprising Failure of Anonymization” (Paul Ohm, UCLA Law Review, 2009).




This update was compiled by Jeremiah Milbauer, with help from Paulina Haduong. Jeremiah is a rising freshman at the University of Chicago and an intern for the Student Privacy Initiative at the Berkman Center for Internet and Society.

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