Explaining Personally Identifiable Information to Education Stakeholders
The following description was developed by the West Virginia Department of Education to help educators and other stakeholders, including the public, understand personally identifiable information (PII). Personally identifiable information (referred to as “PII”) includes any information that can be used, either alone or in combination with other information, to directly determine or find the identity of an individual person. PII can include a person’s name, Social Security number (SSN), other individual identification number, address, and so on. It can also include distinct pieces of information that, when combined, can identify an individual. In the case of student education records, that might include a student’s grade level, date of birth, and/or other personal information (e.g., gender, race, or ethnicity). PII stored in students’ education records is protected by federal and state law.
Although all PII is protected, some PII is considered sensitive information because if it is lost, exposed to unauthorized parties, or misused, there could be an adverse impact for the individual. The combination of two or more pieces of non-sensitive PII may result in sensitive information, as when a person’s full name is associated with their date of birth and mother’s maiden name—information often used to verify a person’s identity for credit purposes. Both the potential for harm and the context in which the information is used are important determinants of what constitutes “sensitive” PII. For instance, a list of students attending a particular school may include PII (students’ names) but would not be considered sensitive, given that revealing only student names would not likely result in harm to the individual students.
A list of students receiving specific services at the school, such as academic tutoring or counseling, would be considered sensitive, given that exposing such information may open those student to harm such as ridicule from their peers or others based on the nature of the services they receive.