Table of Contents
The Privacy Block Setting (PBS) is a reportable value that your institution can use to communicate to the Clearinghouse that a student’s enrollment and/or degree record is restricted from certain uses by the Clearinghouse due to the requirements of a state or federal data privacy law (or in some cases, the law of a foreign jurisdiction). With the growing trend in new data privacy legislation—from the European Union’s General Data Protection Regulation (GDPR) to California’s Consumer Data Privacy Act (CCPA) to future legislation likely to arise in the coming years—the Clearinghouse wants to provide institutions subject to such laws with a means by which they can utilize Clearinghouse services in a compliant manner.
Directory Block Indicator vs. PBS
- Directory Block Indicator: A block that is applied to the entire student’s history at an institution designed to protect student rights under the Family Educational Rights and Privacy Act (FERPA) and ensure FERPA compliance.
- PBS: A block that is applied to the individual record reported by the institution. Due to both the uncertainty of what future privacy legislation might require, as well as the operational complications involved in making the PBS record-specific, the Clearinghouse has chosen at this time to construct the PBS so that it blocks the entire enrollment and/or degree record of a student once the PBS is submitted on a single record for that student.
Impact on Clearinghouse Services
- Compliance Reporting: There will be no impact to compliance reporting under Title IV of the federal Higher Education Act due to the PBS value on the student’s record.
- Postsecondary Data Partnership (PDP): A PBS of 01 (block from research) and 03 (block from research and verifications) will impact the Analysis Ready files for fall and spring data submissions. As for the PDP platform itself, because the data is de-identified and aggregated, the PBS will have no impact.
- Verification Services: The Clearinghouse does not use a student’s personally identifiable information in enrollment and/or degree records for its Verification Services (e.g., DegreeVerify, EnrollmentVerify) if the student has not consented to these data uses. Incoming requests without the student’s consent receive an “Unable to Confirm” response.
- Myhub: The PBS will have no impact on student data reflected in Myhub.
- Course Exchange & Reverse Transfer: The PBS will have no impact on student data in our Course Exchange and Reverse Transfer services.
Reporting the PBS
In order to report the PBS to the Clearinghouse, your institution will need to enter a contract addendum with the Clearinghouse governing its use.
The determination of whether records submitted to the Clearinghouse are subject to privacy laws, and any restriction from their use within Clearinghouse services, is a determination your institution needs to make. The Clearinghouse cannot provide legal advice to assist you in making that determination. If you assess that 1) state, federal, and/or foreign privacy laws apply to enrollment and/or degree records you submit to the Clearinghouse and 2) compliance with those laws requires you to communicate with us that a student’s enrollment and/or degree record is restricted from certain uses by the Clearinghouse, please contact firstname.lastname@example.org before you begin using the PBS.
The Clearinghouse does not require your institution to populate the PBS field for all of your students. However, depending on the student’s request and privacy regulations, you may want to send PBS values for the enrollment and/or degree record you submit to the Clearinghouse. If your institution programs your extract to include the PBS, you can include 00 (no PBS) for students who do not have a block to confirm that there is no PBS on their student records.
If the student requested a PBS, it is important you continue to submit this value in each submission until the student’s PBS election changes or your institution’s policy dictates otherwise. Student degrees for which data use is restricted should be submitted via the web so you can provide the PBS value.
If you report the student with a PBS equal to the 00 value, you will not be able to report that student with a blank PBS value going forward. We will continue to carry forward the 00 value unless your institution reports a new value for this student. See Accepted Values below for values and definitions.
|Blank||Default value for PBS. A blank PBS means that the student has no PBS and/or your institution has not programmed the PBS for all students. Once you populate the PBS with another value (00-03), you cannot report it as blank again.|
|00||Student has no PBS. Used when your institution programs for the PBS values and/or changes from a higher value to no block.|
|01||Student detail containing personally identifiable information (PII) for which the student has not provided consent to use is blocked from use for research purposes. Student data can be used in de-identified and aggregate reports as well as research reports with student consent.|
|02||Student data is blocked from use in non-consented verifications.|
|03||Student detail containing PII for which the student has not provided consent to use is blocked from use for research purposes and in non-consented verifications. Student data can be used in de-identified and aggregate reports as well as both research and verifications with student consent.|
Reporting the PBS on the School Secure Site
You can use the Individual Student Update option on the Student Look-Up tab of our School Secure Site to report a PBS value.
- Select the Student Look-Up tab.
- Search for the student by entering their Social Security number or college student ID.
- Select the appropriate option from the Select Edit Option menu.
Reporting the PBS in Enrollment Submissions
The Clearinghouse updated the enrollment file layout so you can start submitting PBS values in your enrollment reporting submissions. You will need to work with either your student information system vendor or IT department to ensure they can include the field in the extraction process.
Updating a PBS Value
Once you submit a PBS value for a student, you can update it online via our Individual Student Update option. If you submitted a block and want to remove it, update the PBS value to 00.