VERIFICATION OF STUDENT IDENTITY

References: Higher Education Opportunity Act (HEOA) of 2008, Public Law 110-315 and Family Educational Rights and Privacy Act of 1974 (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). Wyoming State Statutes: §40-12-101, §40-12-501; and §40-12-502,  Board Policy 5110C

Western Wyoming Community College (the College) must operate in compliance with the
provisions of the United States Federal Higher Education Opportunity Act (HEOA) of 2008,
Public Law 110-315 and the Family Educational Rights Privacy Act of 1974 (FERPA). The HEOA
requires the verification of student identity in distance education and FERPA identifies who is
allowed to access student records.

This policy requires the College to establish verification procedures for student identity during student transaction and verification of students enrolled in credit courses. In the interest of equitable and efficient operation of the College, students shall be afforded a process by which to verify their identification in order to receive student services transactions at the College.

The College shall publish and adhere to a procedure that complies with the Family Educational Rights and Privacy Act (FERPA) as it applies to full disclosure of any educational record. In addition, according to the provisions of the HEOA, all credit-bearing courses and programs offered through distance education methods must verify that the student who registers for a distance education course or program is the same student who participates in and completes the course or program and receives academic credit. The HEOA has identified the following as acceptable methods of identity verification: 

• An individual secure login and password,
• Proctored activities, and/or
• Other technologies or practices that are effective in verifying student identification including Multi-Factor Authentication and recovery mechanisms for passwords which require a cell phone to receive an additional authentication code, or provide the answer to a secret question.

This policy applies to all credit-bearing courses and programs offered by the College.  The College shall operate in compliance with the provisions of the HEOA concerning verification of student identity in distance education. All methods of verifying student identity must protect the privacy of student information. The student must be notified of any projected fees associated with student identity verification. Responsibilities for the consistent application of student identity verification procedures must be clearly stated and described.

Adopted June 23, 2022

Procedure 5110E 

VERIFICATION OF STUDENT IDENTITY

Reference: Board Policy 5110E

Western Wyoming Community College (the College) uses a secure login and complex password to ensure that the student who registers for a course is the same student who participates in the course.

• During the admissions process, each student receives a unique Student ID Number. Upon acceptance, each student receives a unique and secure network account that is linked to the Student ID Number.  This network account is used to authenticate into the College’s Learning Management System, Canvas, as well as other major applications (i.e., Microsoft Office365, Email, etc.). 
• First time users must establish their identity by visiting the MyWestern portal to set up a complex password and two security questions as well as alternate contact information. Users can manage their password resets through this portal using their secure questions or a mobile number.  More information about College usernames and passwords can be found in the Information Technology password protocols.
• Multifactor Authentication is used each time a student logs in to a system, which requires a code sent to their cell phone, or generated on a secure token, to be supplied in addition to their unique login username and password. This method of authentication guarantees at least two forms of identification from the student to allow a successful logon session.
• If a student requires assistance from the IT Help Desk, Mustang Central, or Distance Learning that requires access to any student information, three forms of identity must be verified before proceeding with a telephone request. Possible identifiers are: Student ID Number, birth date, last four digits of Social Security Number, home address, and phone number.  During an in-person request, the student’s identity is verified with their Student ID card that contains their picture and Student ID Number.
• Students are required to authenticate each time they log into the Learning Management System to access their course(s) or their Self-Service student information portal.
• All online course work that is graded or contributes to a student’s grade is submitted via a system that verifies a student’s identity through a unique and secure login.
• For courses delivered through interactive video, the identity of the students is verified visually by the instructor.

The Family Educational Rights and Privacy Act (FERPA) of 1974 is designed to protect the confidentiality of education records. The law applies to all schools that receive funds under an applicable program of the US Department of Education. The College ensures FERPA rights of their students through the following methods: 

• Students gain access to their education records and courses through a secure login with their unique username, complex password, and Multifactor Authentication.
• Students can manage their password resets through the MyWestern portal using their secure questions or the mobile number they have entered previously.
• The College has installed up-to-date network security that safeguards against unauthorized access that could threaten student privacy. This includes an intrusion prevention system, firewall, and anti-virus software.
• In compliance with Wyoming Law and the General Data Protection Regulation, the College does not collect any personal identifiable information from any visitor to their website except for specific College services, such as admissions applications, registration for events or contests, submitting an official College form, etc. More information about the personal information collected is available in the Privacy Policy.
• Strict identity verification methods are employed by the IT Help Desk, Mustang Central, and Distance Learning as described earlier in this document.

Fees:

The College does not charge additional fees for student identity verification.

Responsibilities:

The Vice President for Student Learning, or their designee, is responsible for defining and publishing acceptable ethical and academic behavior in the Student Handbook including information on Academic Dishonesty, Plagiarism, and the Student Code of Conduct. 

The Director of Financial Aid, or their designee, is responsible for ensuring practices that verify and validate student identity in order to receive student aid.

Students are responsible for knowledge of the information contained in the Student Handbook and Course Syllabi.  Failure to read College/program/course guidelines, requirements, procedures, and policies will not exempt users from responsibility. 

Students are responsible for maintaining the security of their usernames, passwords, and personally identifiable information.  Students must abide by the College’s Acceptable Use of Computing Resources regulations.  The (policy) regulation states that the user should not reveal their password and is responsible for all activity related to their account.  This policy further states that users will not violate the privacy of others, intentionally or unintentionally.  See Board Policy 2180A for more information.

Students are responsible to have a web camera and audio equipment for online courses, if such equipment is required.  Faculty provide this specific information in their course materials and syllabus.

Faculty are responsible for applying pedagogical practices that are effective in verifying student identity. Possible methods used include: virtual class meetings using video display; reviewing student writing samples from written assignments; routine interaction with the student (through email, phone, and video); group assignments; etc.

Faculty are responsible for including information on academic dishonesty in their course syllabus. Faculty must also include any computer hardware and software requirements in their course syllabus and materials. 

Faculty are responsible for noticing changes in student behavior and coursework such as sudden shifts in academic performance, writing styles, or behaving differently in group assignments, because technology and personal accountability may not verify identity absolutely or ensure academic integrity completely.

The Chief Information Officer (CIO) is responsible for having an up-to-date learning management system, network security, robust password management protocols, and stringent IT Help Desk procedures.  They are also responsible for providing instruction and support to employees on the College’s Cybersecurity protocols.  Should a security breach occur, it is the CIO’s responsibility to assess the scope of the breach and inform the College President, who shall then inform the Board.   A plan to notify those affected and provide restitution shall be adopted.

Definitions:

Distance Education/Online Course: A method of education or a single course that relies on the internet for part or all communication, collaboration, participation, and assignment submission.

Adopted June 23, 2022