Data Privacy FAQs

Frequently Asked Questions

The Frequently Asked Questions (FAQs) below are based on inquiries to the Adult Education Office regarding student records and data privacy related to the Family Educational Rights and Privacy Act (FERPA) and the Workforce Innovation and Opportunity Act (WIOA), Title II: Adult Education and Family Literacy Act (AEFLA) Program.

1. Is it now a requirement for agencies to ask students for their social security numbers (SSNs)?  Could we proceed without collecting SSNs?

   Agencies are required to provide each student an opportunity to voluntarily disclose SSNs.  This is achieved by providing students with the Voluntary Authorization to Share Personally Identifiable Information and Records Form (Consent Form). 

2. Are students required to complete the Voluntary Authorization to Share Personally Identifiable Information and Records Form (Consent Form)?
   
   
   • Students can choose to provide their SSNs by checking the "I consent" box and signing the form.
   • Students can also choose not to provide their SSNs by checking the "I do not consent" box and signing the form.
     
     Note: Grantees must document all responses in the Entry Record
     
     
3. Can a student decline to provide a SSN and also decline to fill out the Consent Form?
   
   

   Yes; however, grantees are still required to document the student’s response in the Entry Record.   

4. Will the Voluntary Authorization to Share Personally Identifiable Information and Records Form be available in other languages?

   Yes, the form will be available in eight other languages: Spanish, Mandarin, Cantonese, Vietnamese, Arabic, East Armenian, Hmong, and Russian.

5. How should grantees proceed in the event that they are directed by local policy to not collect SSNs?

   Grantees are advised to record “no” in the Entry Record.

6. Does it impact our payment points if a student elects not to provide a SSN?
   
   

   No; however, it can affect the grantee’s ability to demonstrate that program offerings result in successful employment outcomes, which could also impact California’s ability to meet federal goals.

7. What are the procedures for storing and retaining Consent Forms?

   As with other student-sensitive information, Consent Forms should be stored in a secured area and retained for a period of three years from the date of submission of the final expenditure claim report (2 CFR §200.333).

   See additional information regarding Student Privacy Frequently Asked Questions