Use of student photographs for identification purposes on class rosters is restricted to the use of the individual course instructor even though student photos have been classified as "directory information" as defined by the Family Educational Rights and Privacy Act of 1974 (FERPA). In situations where there is a legitimate educational purpose such as collaboration with faculty who share teaching responsibilities, faculty can share photo information. Directory information is not generally considered harmful or an invasion of privacy if disclosed.
Making photo rosters public will be considered a violation of University policy and may have serious consequences for faculty, students and the University. Faculty will not be able to print photo rosters due to programming restraints.
Faculty should use photo rosters to support teaching (e.g., confirm attendance, match names and faces, etc.), but must make sure students' photos remain confidential at all times. This means that faculty CANNOT:
- Publicly share these photo rosters
- Attempt to post these photos to a blog, public web site, or even a secure learning management system (e.g., Blackboard).
Teaching Assistants fall under this guideline for use of photos on class rosters.
Faculty should be aware that current FERPA guidelines were revised in December 2008. A point of clarification states that while a student may have a "withhold information" (confidential indicator) on the record, this level of confidentiality does not permit the student to be anonymous in class. The confidential requirement is an administrative tool that allows the student to withhold University-defined directory information to the public outside the University (primarily affecting verification of attendance and degree). Photos of students who have opted for a confidential indicator will appear on the class roster along with the confidential indicator flag.