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Protecting Privacy
Protecting Privacy
What Is Personally Identifiable Information (PII)?
What Is Personally Identifiable Information (PII)?
Personally Identifiable Information
Under FERPA, personally-identifiable information includes, but is not limited to, the following:
Student's name
Family members names
Addresses
Indirect identifiers
Information that could be used to identify a student when combined with other data or based on context
Direct Identifiers
Direct Identifiers
(always PII)
(always PII)
Details that immediately and clearly identify a specific student on their own
Student’s full name
Email address
Phone number
Student ID number
Social Security number
Indirect Identifiers
Indirect Identifiers
(becomes PII when combined)
(becomes PII when combined)
Details that don’t identify a student on their own, but could identify them when combined with other information or when context is known (like in a small class)
Date or place of birth
Mother's maiden name
Grades or GPA
Attendance records
Course or section enrollment
Where does the data go?
Where does the data go?
From North Carolina State University's AI Guidance and Best Practices:
AI tools like ChatGPT store every piece of info you share – don’t include anything you don’t want in the cloud! (e.g. Personal ID details, client / stakeholder info, proprietary research, accounts, discriminatory language, etc.)
ChatGPT keeps the data you give it- including the information you put into prompts! Very hard to opt out of sharing data and it impacts your experience with AI (O'Flaherty, 2024).
Almost impossible to delete data once you've entered it into the large language model (O'Flaherty, 2024).
Why shouldn't I give AI personal information?
Why shouldn't I give AI personal information?
The only tools teachers can legally input student data into are FERPA-compliant platforms that have an active contract with the institution.
AI tools often process and store data externally, putting that data at a higher risk of unauthorized access or misuse.
When you use external AI tools, you're relying on another company’s security and policies, not your institution’s.
What about "opting out" of model training?
What about "opting out" of model training?
⚠️ Opting Out of Model Training ≠ Opting Out of Data Collection ⚠️
⚠️ Opting Out of Model Training ≠ Opting Out of Data Collection ⚠️
Even if you disable “training,” your data may still be collected, stored, and reviewed.
ChatGPT may share any sensitive information or intellectual property . They say that they aren't using the data to train models or profile people.
There is no "opt out" of data collection.
How do I turn off model training (ie. “Improve the model for everyone”)?
Settings > Data Controls, and disable “Improve the model for everyone."
While this is disabled, new conversations won’t be used to train our models.
(OpenAI, 2023)
Protecting Student Data
Protecting Student Data
How can I make sure that I'm following FERPA laws when using AI tools?
Remove student data before pasting anything into ChatGPT, Claude, or any other AI tool.
Only use AI tools that let you opt out of future model training.
Important!
Cropping PDFs does not remove data, it just hides it!
ChatGPT is still able to see the entire uncropped document if you upload it.
Anonymizing Emails
Anonymizing Emails
Q: Am I being FERPA compliant if I copy and paste a student email into ChatGPT as long as I remove the student's name?
Q: Am I being FERPA compliant if I copy and paste a student email into ChatGPT as long as I remove the student's name?
Not necessarily.
Removing a student’s name is a good first step, but FERPA protects all personally identifiable information, not just names. If the content includes details like grades, specific circumstances, or anything that could reasonably identify the student, the content is still protected by FERPA and should not be input directly into an AI tool.
Always generalize, rephrase, and remove identifying details before putting any student-related information into an AI tool.
FERPA-Safe Editing Rules for AI Use
FERPA-Safe Editing Rules for AI Use
1. Generalize relationships
Use: “relative” instead of “mom,” “grandpa,” or “sister”
2. Remove diagnoses
Use: “an illness” or “a health issue” instead of “cancer,” “depression,” or “ADHD”
3. Avoid exact numbers or timelines
Use: “recently” or “a while ago” instead of “last month,” “two weeks ago,” or “62%”
4. Use neutral pronouns
Use: “they/them” instead of “he/him” or “she/her”
5. Drop course identifiers
Use: “a class I teach” instead of “MATH 120, Section 1001”
6. Omit geographic or institutional details
Use: “a community college” instead of “CSN” or “UNLV”
Original Email
Original Email
(NOT SAFE to put into AI)
Hi Professor,
I’m really struggling to keep up with class. My mom was diagnosed with cancer last month and I’ve been taking her to chemo appointments. I missed the last exam and my current grade is a 62%. Is there any way I can make up the test or get some extra credit?
Thanks,
John Doe, MATH 120, Section 1001
Anonymized Email
Anonymized Email
(SAFE to put into AI)
EDITS:
I’m really struggling to keep up with class. My mom RELATIVE was diagnosed with cancer AN ILLNESS last month and I’ve been taking her THEM to chemo appointments. I missed the last AN exam and I'M CURRENTLY FAILING my current grade is a 62%. Is there any way I can make up the test or get some extra credit?
ANONYMIZED VERSION (can be put into AI):
I’m really struggling to keep up with class. My RELATIVE was diagnosed with AN ILLNESS and I’ve been taking THEM to appointments. I missed AN exam and I'M CURRENTLY FAILING. Is there any way I can make up the test or get some extra credit?
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