Q: Our Events staff have asked for student names, email addresses, and mailing addresses to forward to the commencement photographer who will use the information to mail photo proofs taken at the ceremony to students. This information is considered limited directory information. Does this mean we need to receive permission from each individual student in order to release their information to the photographer? Or can we share the information so long as the student has not fully suppressed this information in their record?
A: Student contact information that hasn't been suppressed is in the "limited directory category," which means we can share it within the institution.
In a case like this, there are two potential options:
- The photographer has a contract with the University, and the contract designates the photographer as a school official and obligates them to securely handle student data.
- Students provide consent.
ASR recommends option 2. Most graduation processes have a student consent component built into them. This is typically for the student to give consent to have their name in the program or to have content on a website, regardless of whether they change their directory suppression status. Consent for the photographer can be built into this process similarly.
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