2020 Census & Student Privacy

The 2020 Census count is critical for determining representation and the allocations of federally funded programs, including those in higher education. Historically, certain groups of people have been disproportionately undercounted by the Census. The U.S. Census Bureau identifies all college students as a hard-to-count population because they are highly mobile, may live off-campus as renters, and often difficult to persuade to participate.

The shift to distance learning due to the COVID-19 outbreak forced students living both on- and off-campus to return home, complicating this year's Census operations. Bureau representatives have begun their outreach to campuses and will continue over the next few months to verify and collect certain directory information on students in group living quarters, including college residence halls, as well as students living in non-college/university-owned housing.

FERPA generally permits such disclosures and we strongly urge all of our members to work with the Census Bureau to provide them with the particular directory information items it is seeking: name, address, and date of birth. However, because directory information must be limited to information that is not generally considered harmful or an invasion of privacy, it cannot include items such as social security numbers, race, gender, or ethnicity.

​AACRAO ​is engaged in conversations with the U.S. Census Bureau and the Student Privacy Office of the Department of Education to ​ensure that colleges and universities can assist in the collection and distribution of information related to students while also complying with long-standing student privacy requirements.

Executive Director Updates

AACRAO Takes the Lead for Higher Education to Ensure that the Census Does Not Overstep FERPA Regulations for Off-Campus Student Count

Michael V. Reilly |
June 18, 2020
  • Advocacy
  • FERPA
  • census
  • covid-19
  • Federal relations

In a continued effort to ensure an accurate Census count during these difficult times, AACRAO remains engaged in conversations with the U.S. Census Bureau. The shift to distance learning due to the COVID-19 outbreak forced students living both on- and off-campus to return home, complicating this year's Census operations.

The Bureau has begun to reach out to institutions this week to discuss the collection of basic demographic information about students who live off-campus, a particularly hard-to-count population as a result of the pandemic. However, AACRAO has concerns about what information institutions will be asked to provide as directory information. While FERPA generally permits such disclosures, directory information must be limited to information that is not generally considered harmful or an invasion of privacy. It cannot include items such as social security numbers, race, gender, or ethnicity.

AACRAO, in conjunction, with other higher education associations, sent a letter to Census Bureau officials this week urging the agency to review and revise its request to institutions and to provide formal guidance, in writing, articulating the request for off-campus enumeration collection. We hope that doing so will minimize confusion and ensure that institutions comply with long-standing student privacy requirements. For those institutions that may be limited on what information to provide due to self-imposed directory information limitation, AACRAO has also recently provided guidance.

AACRAO also requested that the Census Bureau reconsider the deadline date for institutions to provide off-campus information to align with its group housing deadline in August. Doing so will provide institutions with additional time to comply with information requests, particularly those that may need to reclassify what they deem to be directory information, which will require student notification and the ability for students to opt-out. We all want to ensure an accurate Census, but we must adhere to long-standing student information request processes that have been in place for over 45 years.

Mike

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2020 Census and FERPA FAQs

Sample of Census Bureau responses to questions related to "Group Quarters Operations"
  • If a student has opted out of directory information, should that student's name appear on the roster?

    No, if a student has opted out of directory information, then that student’s name should not appear on the roster. The Census Bureau will request the room number for that student so that a package can still be prepared for that student.

  • What about international students?

    College students who are foreign citizens living in the United States while attending college in the United States (living either on-campus or off-campus)—Counted at the on-campus or off-campus U.S. residence where they live and sleep most of the time. If they are living in college/university student housing (such as dormitories or residence halls) on Census Day, they are counted at the college/university student housing. Therefore, these student should be included in the group quarters enumeration process.

    The goal of the U.S. Census Bureau is to conduct an enumeration of every person residing in the 50 states, the District of Columbia, Puerto Rico, and the Island Areas (the Commonwealth of the Northern Mariana Islands, Guam, American Samoa, and the U.S. Virgin Islands). The U.S. Constitution requires that the Census Bureau not just attempt to offer information or a service to the population (as is the case with other federal government programs like voter registration, Social Security enrollment, and the use of national parks), but that the Census Bureau actually reach and count every person living in the United States and its territories—of all ages, residence statuses, and locations—whether or not they desire to participate, and regardless of whether they are difficult to find, reach, and count.

  • How does this pertain to commuter campuses, i.e., campuses that do NOT have on-campus housing?

    These campuses have no obligation for the 2020 Census if they do not have student living in on campus or off campus housing. The students will be counted at their residence.

  • How will you determine which residence is correct for a student that is reported on campus and in their home state?

    The 2020 Census residence criteria are used to determine the correct residence for various residence situations such as described above. This is why it is important that the Census Bureau receive complete data to be able to perform critical matching. The more complete the information, e.g. legal first and last names or complete DOB (month, day, and year), the more confident Census can be that two records that are linked together are the same person.

  • If using e-response and race/ethnicity and gender information is not included, will the information be considered complete for upload?

    The information will be considered complete if you provide complete “directory information.” Information required to help with non-duplication include Name, DOB or Age, Address of usual home elsewhere (where they live while not at campus housing). The more complete the information, e.g. legal first and last names or complete DOB (month, day, and year), the more confident Census can be that two records that are linked together are the same person.

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