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2.3 Making Information Available through Directories

Policy

Any application that provides public access to directory information collected by Harvard about individuals and any process that creates printed lists of people for public display or distribution must adhere to any privacy preferences established by the individuals.

Discussion

Harvard maintains a lot of information about its faculty, staff and students. Much of this information is considered to be confidential either by Harvard policy or by government regulations. A subset of the information is considered to be directory information and is subject to public disclosure. This information includes name, email address, office location, phone number and other information of this type. Under the federal Family Educational Rights and Privacy Act (FERPA) only specific information about students can be considered directory information.  (See Section 3.1 [1]: FERPA Directory Information.)

Schools, departments and the University produce printed directories of people and some of their directory information. Directories can cover many different scopes from almost everyone at Harvard to the list of students in a particular course. Schools, departments and the University also provide electronic directories.

In some cases people have requested that they not be included in directories or that particular types of information about them not be included in public directories. FERPA gives students or former students the right to request that none of their directory information be displayed. In addition, Harvard faculty and staff can, subject to school or department policies, request that they not be included in directories or that particular information about them not be included. People creating printed or electronic directories must take into account must take into account such requests.

Harvard Directory Services maintains a core ID management database that includes information about people who have active Harvard University ID cards. This database includes privacy flags that can be set to indicate that a person has requested that some or all of their directory information not be publicly displayed. The ID management database also includes a flag that is used to indicate that the individual has made a request to not display any any information about them under the rights granted by FERPA. (Students or former students should see Section 3.2 [2] FERPA Blocks to find out more about requesting a FERPA block and the effects of FERPA blocks.)

People creating printed directories can check the Harvard on-line directory or public LDAP service (which check in real time to see what can be displayed about individuals) to find out what information they can include in their directory. Applications that provide directly services can use the University non-public LDAP service to access the privacy and FERPA flags directly. (Contact Harvard Directory Services for information about the LDAP service.)

Note that this policy concerns public directories. A public directory is one that can be accessed by the general public or by the general Harvard community (with or without authentication). This policy does not cover private directories that are not generally accessible or distributed outside of a defined and limited audience. For example, a list of the students in a class that is distributed just to the class instructor and TAs is not considered to be a public directory as long as it is clear to the instructor and TAs that the list is only for their private use and can not be posted in any way. But a list of students in a particular concentration or a list of employees in a department that is distributed to the people on the list or posted on a department bulletin board should be considered a public directory.

Additional References: 

Directory Services [3]

© 2009 President and Fellows of Harvard College.
 
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Source URL (retrieved on 11/25/2009 - 02:38): http://www.security.harvard.edu/enterprise-security-policy/2-confidential-info/policies-2_3

Links:
[1] http://www.security.harvard.edu/enterprise-security-policy/3-student-info/policies-3_1
[2] http://www.security.harvard.edu/enterprise-security-policy/3-student-info/policies-3_2
[3] mailto:directory_services@harvard.edu