Update on FERPA and the 2020 Census for college/university student housing administrators

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During a census, college students are generally counted where they live and sleep most of the time. That means that students who are living away from their parents’ address while they attend college should be counted at their on-or off-campus addresses. In order to accomplish this, the Census Bureau asks Institutions of Higher Education (IHEs) to choose one of several methods of supplying data to ensure an accurate count. Previously, the U.S. Department of Education’s Student Privacy Policy Office (SPPO) issued a letter to Institutions of Higher Education to address FERPA issues that may arise as a result of the 2020 Census.

On March 16, 2020, the Census Bureau and SPPO posted an update on FERPA and the 2020 Census for college and university student housing administrators. (This document can be found on the SSPO website  and on the Census Bureau website.) With so many colleges and universities taking steps to stop the spread of COVID-19, the Census Bureau realizes that many students are not currently living on campus but, instead, have returned to their parents’ homes. Also, two of the methods IHEs may select require greater physical interactions than others. As a result, the Bureau is asking IHEs that originally chose either the in-person or drop-off/pick-up methods to change to either the e-response or Group Quarters Enumeration methods instead. About 44 percent of IHEs have selected either the in-person or the drop-off/pick-up methods. Off-campus students may provide electronic responses online at my2020census.gov.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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