The University of North Carolina at Greensboro collects photographs of students, faculty and staff for its business and academic functions. Therefore, it is incumbent upon the University to have a policy protecting this information from misuse or unauthorized access.

This policy relates only to student identification (I.D.) photos. It does not extend to student photographs taken for other purposes (athletic events, campus events, public relations photos). These identification (I.D.) photos, collected and stored digitally may be accessed or shared for business and/or academic operations. Unauthorized access or misuse of this information may have negative consequences. In addition, the use and dissemination of student photographs falls under the Family Educational Rights to Privacy Act (FERPA).

At the University, electronic student I.D. photos are considered educational records and classified as personally-identifiable or non-directory information under the Family Educational Rights and Privacy Act of 1974. Only University officials who have been determined to have legitimate educational interest (See Definitions) will have access to these records without the student’s written consent.

Specifically, it is the policy of the University to release personally identifiable information from the education records of a student, without written consent, to appropriate university officials. These would be faculty, staff or agents of the University working with that student in admission, registration, advisement, counseling, teaching, financial aid, student conduct, safety, security, payment of fees or any other activity directly related to the student’s academic program and pursuant to law or governmental regulation. Faculty access is limited to the student I.D. photos for classes in which that faculty member is the instructor of record.

Attempts by other individuals or organizations to access the records without the written consent of the student are considered a violation of University policy/federal law. Examples of violations include, but are not limited to: 1) illegally accessing information from student, faculty, or university computers; 2) misrepresenting themselves to obtain another student’s personally identifiable information; 3) using a student’s ID number without his/her permission to gain access to University services.

The recipient (including the officers, employees, and agents of the party of the recipient) may use the photos only for the express purposes for which the disclosure was made. These requirements do not apply to disclosures made pursuant to court orders or to lawfully issued subpoenas.

Legitimate Educational Interest  – A legitimate educational interest is one that enhances the student’s development through teaching, data gathering and record keeping, academic advising, counseling, placement, testing, financial aids, housing, remedial and co-curricular activities or related educational goals.

Within the context of this policy, Legitimate Educational Interest (LEI) means: – The photo is relevant and necessary to the accomplishment of some task or determination that is in support of the student’s education; or the photo is required to assist with the personal safety of the individual or the campus community.

Campus Official or University Official – Any individual designated by the University of North Carolina at Greensboro to perform an assigned function on behalf of the University. A campus or University official may be a person employed by the University in an administrative, supervisory, academic, research, or support staff position.

A campus official is deemed to have Legitimate Educational Interest in a particular photo if the information requested is relevant and necessary for that official to:

• Perform a task or determination that is an employment responsibility or is a properly assigned subject matter for the inquirer and is in support of the student’s education;
• Perform a task that is related specifically to the official’s participation in the student’s education; or
• Perform a task that is related specifically to the discipline of the student; or
• Perform a task that is related specifically to a safety concern on behalf of the student or the campus community.

Any disclosure or re-disclosure of student I.D. photos under this policy must meet the following requirements:

• As in all receipt of any personally-identifiable or non-directory information, the recipient of the photos shall be conversant with the Family Educational Rights and Privacy Act regulations, including an understanding that the photos may not be released to a third party.
• University personnel receiving or utilizing student I.D. photos shall be responsible for any subsequent disclosure pursuant to the provisions of this policy.

Usage and access is permitted for legitimate business purposes only. Use and access for personal reasons is not permitted.

Use and access shall be consistent with all other applicable UNCG policies, including but not limited to the current versions of the UNCG Information Security Policy (http://policy.uncg.edu/university-policies/information_security/).

Misuse or abuse of these policies may result in revocation of this access, without notice and may be subject to legal action.

Viewing electronic photographs shall be done in a manner that is discreet, reasonably viewable only by authorized personnel.

Abuse or misuse of these policies shall be reported to the UNCG ID Center.