The Secure Transcript: Survey of U.S. Universities' Use of the SSN on Academic Transcripts (Titus)

Contributed by Aaron Titus

Summary

Most universities have moved away from using students' Social Security Numbers as their Student ID, but because the SSN continues to be a convenient identification number, ancillary higher education organizations, such as lending institutions, continue to use the SSN as a universal identification number.  As a result, some universities which have otherwise discontinued using the SSN as a student ID, continue to print the student's SSN on academic transcripts and official documentation.

Though academic transcripts should be treated as secure documents, students are often required to disseminate dozens of transcripts to entities with which they will have only one-time contact, most of whom have no need for the SSN.  Despite the dangers, the national registrar association, American Association of Collegiate Registrars and Admissions Officers (AACRAO), recommends printing the SSN on transcript, and says that 79% of American colleges did so, in 2003.  However, this 2007 survey indicates that now only 26% of US News and World Report's top 126 colleges and universities mandatorily print the SSN on academic transcripts.

Background

The 2000 US Census reports that 52% of the population over 25, or 94 million people, have attended some college, and therefore potentially have an academic transcript. (http://www.censusscope.org/us/chart_education.html, accessed 5 May 2007).  Universities use transcripts to transfer credit.  Potential employers use them to verify class standing.  Financial institutions, private study abroad corporations, organizations awarding scholarships, and a wide range of other public and private institutions require academic transcripts for a variety of reasons.  Before and after graduation, a single student may send dozens of transcripts to organizations with which he may have only passing contact.

Very few of these organizations, including potential employers, have a legitimate need for students' Social Security Numbers. But each time a student sends a transcript to an organization or prospective employer, the transcript information is usually captured digitally, logged in a database, and stored indefinitely.  Since names, birthdates and SSNs are often printed on academic transcripts, these documents pose a potential risk to students and former students, if the information is misused or mishandled.  Risk of data breach or identity theft increases proportionally as the student's personal information is stored in more databases and paper files.

Most of the time, students can easily provide their Social Security Numbers to organizations with a legitimate need, using other methods than an academic transcript.  Though employers need the SSN in order to report taxes, most potential employers don't have a legitimate need for the information.  The Washington, D.C. Attorney General warns, "avoid providing your social security number or other personal information to prospective employers until you have verified the legitimacy of the organization and their need to verify your background." (http://occ.dc.gov/occ/lib/occ/id_theft_tips.pdf, accessed 5 May 2007).  Countless other Attorneys General, state agencies, and experts across the country publish similar warnings.  A few states have even outlawed placing the Social Security Number on transcripts and other academic documents altogether.

Survey Results & National Trends

Despite the potential risks posed to students and former students, the American Association of Collegiate Registrars and Admissions Officers (AACRAO) currently recommends that universities print SSNs on academic transcripts for convenience and universality.  In fact, their most recent publication addressing this issue, the AACRAO 2003 Academic Record and Transcript Guide, reports that 79% of national colleges and universities print the SSN on transcripts. AACRAO is the recognized national authority in the University Registrar field.

I conducted a new survey of US News & World Report's top 126 national universities in mid-January, 2007, to complement AACRAO's four-year-old data.  The purpose of the survey was to determine the current practices of leading national colleges and universities, with respect to printing students' Social Security Numbers on official academic transcripts.  Representatives from all 126 registrar offices responded to the following questions:

• Question 1: Is a student's Social Security Number printed on official transcripts?
• Question 2: If so, may students request that their social security number be withheld from the transcript?

The responses varied from "No," to categorically "Yes."  Of the many universities that answered no, several indicated that they withheld the SSN for privacy reasons, and one representative mistakenly explained that the privacy provisions of the Family Educational Rights and Privacy Act (FERPA) prohibited them from printing Social Security Numbers on transcripts.  Other registrars were more direct.  The UC Davis registrar replied simply, "the answer is 'no'."  Others, like Boston University, include only "the last four digits of your SSN."  Several university registrars explained that the SSN would appear on older university transcripts because they are stored on microfilm, which are not editable.  One or two colleges, such as Colorado State University, indicated that they planned to discontinue printing the SSN on transcripts in the near future.

A few, like Texas Christian defended their practice of mandatorily printing the SSN on transcripts by appealing to AACRAO's recommendations: "Following AACRAO... recommendations we print the SSN on the transcript… as one step in reducing fraudulent use of academic records.  AACRAO states the official transcript is a secure document that contains a large amount of confidential data all of which should be kept secure.  In addition, in most cases, the transcript will be provided to those (schools and employers) who already have the SSN.  We do not accept requests to withhold the SSN from the transcript."

The responses were divided into four groups:

Category A: Colleges and Universities which did not print the SSN on academic transcripts.  Most of these colleges print the Student ID Number, instead.
Category B: Colleges and Universities which print only a partial SSN on academic transcripts.
Category C: Colleges and Universities which print the full SSN on academic transcripts by default, but allow students to withhold it upon request.
Category D: Colleges and Universities which mandatorily print the SSN on academic transcripts.

Six colleges indicated that they include the full SSN on transcripts, but did not specify whether students could withhold it upon request.  For purposes of this study, those six were placed in category D.  The survey ignores indications of imminent policy changes—it represents a snapshot of practices during the month of January, 2007.

The results of the 2007 survey contrast sharply with AACRAO's 2003 data:
 

AACRAO 2003 Survey
of National Colleges & Universities

January 2007 Survey
of US News & World Report's Top 126
Colleges & Universities

In 2003, more than ¾ of national colleges & universities reported using the SSN on transcripts, according to AACRAO. In January 2007, only ¼ of top national universities mandatorily printed the full SSN on transcripts.

Category A: Colleges and Universities which did not print the SSN on academic transcripts.  Most print the Student ID Number, instead.

Category B: Colleges and Universities which print only a partial SSN on academic transcripts.

Category C: Colleges and Universities which print the full SSN on academic transcripts by default, but allow students to withhold it upon request.

Category D: Colleges and Universities which mandatorily print the SSN on academic transcripts.

Findings

As of January 2007, roughly 2/3 of nationally ranked universities printed a Student ID or only a partial SSN (such as the last 4 digits) on official transcripts.  For instance, Harvard, Yale, Stanford, Princeton, and Duke do not use students' SSNs on transcripts at all, while Georgetown and Berkeley print only the last four digits.  14 nationally ranked schools print the SSN on transcripts, but allow students to withhold it upon request.

Several possible explanations for the contrast between the two surveys may exist.  First, the 2007 survey sampled only nationally ranked colleges and universities.  Presumably, the 2003 AACRAO data includes a much broader sample of colleges.  The absence of local community colleges on the 2007 survey may account for some of the difference, since smaller schools may not have as much funding to overhaul record-keeping systems.  However, if nationally ranked colleges serve as a bellwether for national trends in this area, the 2007 survey may also indicate a sea change in how universities treat students' SSNs.  Regardless, only a small minority of nationally ranked colleges and universities now mandatorily print the SSN on academic transcripts.

I presented these findings to AACRAO in a February 2007 letter, and requested that they review their 2003 data and resulting recommendations.  As of the date of this article, AACRAO has not responded to my letter.

I also presented the results to the George Washington University administration in Washington, DC.  Presently, the university mandatorily prints the SSN on all academic transcripts.  However, as a result of this survey, GW University has committed to change their transcript policy, and will allow students to withhold the SSN from transcripts upon request in the near future.

Conclusion

Students and former students should be aware of the risks associated with disseminating academic transcripts, and check their university's transcript policy.  If the policy does not provide sufficient protection, students should push registrars to meet their privacy needs.  With persistence, many registrar offices will work with students to come up with creative solutions, on an individual basis.

In the current atmosphere of rising identity theft, students and former students need the ability to control how and to whom their personal information is transmitted. Even among universities that have ceased using the Social Security Number as a student ID, University Registrars should become more aware of this issue, and the trend away from printing Social Security Numbers on transcripts.

About Aaron Titus

Aaron Titus works as a Program Manager at an Alexandria, VA non-profit association.  He is also attending the George Washington University Law School, specializing in Information Privacy Law.  When he's not busy being a proud father of two, he writes about privacy, and hosts several podcasts.  These include The Privacy Podcast (www.aarontitus.net/privacy), and Free Space (www.libertycoalition.net/liberty-coalition-podcast).

A summary of this article is available at http://www.aarontitus.net/privacy/index.php?id=13.

DATA

I have included a table of results.  Question 1 was, "Is a student's Social Security Number printed on official transcripts?" Question 2 was, "If so, may students request that their social security number be withheld from the transcript?"

Answers in the column labeled "Question 2 Answer" reference the question 1 answer.  Thus, if the question 1 answer was "Student ID," and question 2 answer is "Yes: Optional," it means: "Academic transcripts print the student ID, but the student ID may be omitted at the option of the student."

Where the answer to question 1 was "Student ID," the registrar indicated that the Student ID was not the SSN. "Category" references the descriptions and graphs below:

Category A: Colleges and Universities which did not print the SSN on academic transcripts.  Most of these colleges print the Student ID Number, instead.
Category B: Colleges and Universities which print only a partial SSN on academic transcripts.
Category C: Colleges and Universities which print the full SSN on academic transcripts by default, but allow students to withhold it upon request.
Category D: Colleges and Universities which mandatorily print the SSN on academic transcripts.