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User Directory and Personal Information Disclosure

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Data contained in a student's educational record that is not generally considered harmful or an invasion of privacy can be disclosed as "directory information." Typical directory information might include a student's name, telephone number, grade level, expected graduation date, major field of study, and email address. Fields of data included in directory information vary from institution to institution.

The institution is required to give the student or student's parents (if the student is under 18 years old), an annual opportunity to opt-out of being listed in the directory. Furthermore, students have the right to review their own educational records and request corrections to any records they believe to be inaccurate or misleading.

Institutions disclosing directory information

Educational institutions or their agents may disclose directory information under the following conditions under the FERPA statute Authority: 20 U.S.C 1232g (a)(5) (A) and (B):

(a) An educational agency or institution may disclose directory information if it has given public notice to parents of students in attendance and eligible students in attendance at the agency or institution of:

(1) The types of personally identifiable information that the agency or institution has designated as directory information;

(2) A parent’s or eligible student’s right to refuse to let the agency or institution designate any or all of those types of information about the student as directory information; and

(3) The period of time within which a parent or eligible student has to notify the agency or institution in writing that he or she does not want any or all of those types of information about the student designated as directory information.

(b) An educational agency or institution may disclose directory information about former students without meeting the conditions in paragraph (a) of this section.

Although many institutions choose to publish in various forms most or all of the directory information about students listed under FERPA, the institution must comply with the conditions stated above at all times. Notification to students of the types of directory information published and the student’s right to opt out is generally done by a student handbook or some other reference manual, not by personal communication to the students. The notification part of the process generally does not have an impact on the Blackboard system.

For alumni of institutions that use Blackboard, note clause (b) above, which states that institutions can disclose directory information about alumni without giving alumni an opt-out notification. In general, FERPA provides fewer rights for those who formerly attended the institution than it does for those who currently attend.

Administrators disclosing personal and directory information within Blackboard Learn

Institutions have several ways to control what personal information is collected and disclosed within the Blackboard User Directory. Personal information is collected on a form called User Profile. This form can be customized by administrators. Administrators can include or exclude any of the fields on the form as well as allow or disallow users to edit their data in those fields. Customize the user profile form from the Administration Panel > Customize User Profile.

Institutions that have a process for handling privacy requests and personal information updates outside of the Blackboard system can turn off access to the Personal Information pages by using flexible privileges management or by turning off the Personal Information tool under Administrator Panel > Tool Panel. Turning off the tool prevents users from making any changes to their user profile information.

Institutions can disable the User Directory altogether and not disclose any directory information using Blackboard Learn. The User Directory can be turned off system-wide under Administrator Panel > Tabs and Modules > Tools.

Users disclosing personal and directory information within Blackboard Learn

If the Personal Information tool is available, users can make their own privacy choices on the Personal Information page, accessible from any tab in the Tools panel or under Tools in any course or organization in Blackboard Learn. On this page, the user can choose whether to be listed in the User Directory. The user can also choose whether to display their email address, address (street, city, state, zip, country), work information (company, job title, work phone, work fax), and any other additional contact information (home phone, mobile phone, website).

These fields and the user’s name are the only personal information that is ever displayed in the User Directory, and by default they are not included in the User Directory. Users must deliberately opt-in to disclose their information in the directory. In this light, the Blackboard System is more conservative in protecting privacy than FERPA regulations. FERPA calls for an opt-out option for directory information, but Blackboard provides an opt-in option. Blackboard also allows the user to exercise this option at any time, not just during a period of time specified by the institution.

When users choose to make their email addresses available, whether or not they have chosen to be listed in the User Directory, their email addresses will be displayed in the Roster and Group pages for all of the Courses and Organizations in which they are enrolled (see Privacy and Personal Information for Course Students and Organization Participants).

If the user has opted to include their personal information in the User Directory, those fields the user has selected will display in the User Directory to other users who are logged on to the system.

Users also have the right to confirm that their personal information is correct. They can review and modify their information on the Personal Information page if it has been made available.