Protecting Your Students in Times of Heightened Scrutiny: A List of Tactics
In today's climate of increased scrutiny and potential threats to vulnerable student populations, protecting those we serve has never been more important. At Students First Consulting, we've compiled this comprehensive list of practical tactics to help you safeguard your students while continuing to provide the support they need.
Data Collection and Management
Share transparently with students how their data will be used. Transparency builds trust and allows students to make informed decisions about what information to share.
Clearly communicate who will view their information (for example, staff and/or community volunteers). Students deserve to know who has access to their personal information so they can gauge their comfort level.
Allow students to decide what and how much to share in each space. Student agency over their own information is both ethical and protective.
Collect only the information you need to determine if a student is a fit for your program. Minimizing data collection reduces risk. If information doesn't exist in your system, it can't be accessed or used against students.
Gather only minimum contact and family information. Excessive personal information could expose students to risk if systems are compromised or records are subpoenaed.
Consider removing requirements for full addresses and only ask for city/state. This respects students who may be unhoused, feel unsafe providing addresses, or are in complicated family situations while still confirming eligibility for your geographic service area.
Be thoughtful about preferred names vs. legal names—preferred names are usually sufficient for most communications. Using preferred names respects student identity and privacy, especially for transgender or non-binary students.
Legal names may only be necessary for specific financial processes (such as setting up 529 plans, for example). Most program functions don't require legal documentation, minimizing exposure of potentially sensitive information.
Consider using format First "Preferred" Last on letters for students with preferred names. This format balances respect for identity with practical needs for identification and record-keeping.
Implement confidential documentation of preferred names, especially for students in sensitive situations. Some students (like those who are transitioning) may use different names in different contexts for safety reasons.
Do not collect citizenship status. This information could put undocumented students or those with complicated immigration status at risk.
Do not collect guardianship details. Complex family situations might be exposed, potentially creating legal or safety issues for students.
Do not collect Social Security numbers unless absolutely necessary (such as for 529 plans). SSNs pose significant identity theft risk and could be used to track immigration status.
Do not collect full addresses unless mailing a check there. Addresses can be used to locate individuals physically, creating safety concerns for vulnerable populations.
Do not ask about FAFSA eligibility—just ask if they completed it or not, and provide calculators. Eligibility questions can be a proxy for citizenship status, potentially forcing students to reveal sensitive information.
Avoid any questions that would force students to out themselves in any way. Forced disclosure of sensitive personal information may put students at risk or create trauma.
Store only protected, confidential records on secure servers. Proper data storage is essential to prevent unauthorized access to sensitive information.
Maintain protected records of services provided. This documents your program's impact while protecting student privacy.
Work with your software vendor on necessary backend changes to support these modifications. Standard fields can often be changed to adapt to protect students; technical limitations should not dictate your privacy policies.
Discuss privacy and security protocols with your software vendor to ensure they adequately protect sensitive student information. Third-party vendors may have different security standards or practices that could impact student data protection.
Reviewer Practices and Training
Determine your risk threshold for your students, erring on the side of maximum protection. In uncertain times, a conservative approach to student protection may prevent life-altering consequences.
Use only reviewers you know and trust. Unknown reviewers may have biases or values that could put students at risk and be at odds with your program goals.
Avoid open calls for reviewers until the climate improves. Open calls increase the chance of involving individuals who may not prioritize student safety.
Consider using only your staff team if it will better protect your students. Staff typically have deeper training and commitment to organizational and program values than volunteers.
Prepare your staff for increased workload. Protecting students may require additional steps and processes; staff should be supported accordingly.
Involve your Board if that feels safe for your organization. Board involvement can provide additional resources and oversight, but only if aligned with student protection values.
Keep processes in-house and protected when possible. Limiting information sharing reduces potential exposure points for sensitive data.
Train staff thoroughly on anti-bias and privacy/protection protocols. Unconscious bias can impact decision-making; comprehensive training ensures consistent protection.
If using external reviewers, invest extra time in their training. External participants need clear guidelines to maintain consistent protection standards.
Prepare for effective facilitation, including conflict resolution. Disagreements about student protection should be handled skillfully to maintain security.
Note that restricting review to staff does not violate IRS guidelines, which only restrict donor participation in selection. Organizations may worry about compliance issues when changing review processes, but protecting students is compatible with regulations.
Consider removing committee members who aren't aligned with your values, including in how they view students. Value misalignment can lead to decisions that compromise student safety and dignity.
Communication and Consent
Offer secure, anonymous communication options like Signal for texting/messaging. Encrypted communications protect content from interception or monitoring.
Consider encrypted options for document sharing. Sensitive documents require additional protection from unauthorized access.
Create protocols for emergency and low-barrier resources. Students in crisis need immediate support without additional barriers.
Consider FERPA implications. Educational privacy laws provide certain protections that your organization should leverage.
Get consent before communicating with others who are not the student. Students should control who has access to information about them, even within their support network.
Obtain permission before sharing student information with donors. While donor engagement is important, student privacy and safety take precedence.
Offer choice to remain anonymous when possible. Some students may face heightened risks if their participation in your program is known.
Clearly explain who is involved in processes and why. Transparency allows students to make informed decisions about participation.
Explain how you use their information and why. Understanding data usage builds trust and empowers students to share appropriately.
Allow for alternative submission formats (including over the phone). Digital footprints create risks for some students; alternative formats provide options.
Provide translated materials so students don't have to request translations. Proactive translation removes barriers and prevents students from having to identify as non-English speakers.
Technical Security Measures
Review whether your tech systems are secure for encrypted personal documents. Standard security may be insufficient for highly sensitive information.
Create protocols for name changes/updating sensitive information through encrypted channels. Updates to identifying information require special protection to prevent exposure.
Implement private, secured chats for networks. Community support is valuable but needs appropriate security measures.
Develop secure ways to report harassment or discrimination. Students facing these issues need protected channels to seek help without additional risk.
Establish organizational security, privacy, and retention policies that prioritize student protection and safety. Comprehensive policies ensure consistent protection across all organizational activities.
Invite donors to step up in supporting and protecting students. Donor education can create additional champions for student protection and mobilize resources for security measures.
At Students First Consulting, we recognize that implementing these measures may require additional time and resources. However, the safety and wellbeing of your students must remain the priority. These tactics can mean the difference between a student's security or vulnerability - between families staying together or being separated.
We're here to support you in implementing these protective measures. Schedule a free consultation with our team to discuss which strategies would work best for your organization and how to implement them effectively. We can help you navigate these challenging times with practical, tailored solutions that safeguard your students while furthering your mission.
Remember that you're not alone in this important work, and your commitment to protecting your students makes a profound difference in their lives and futures.
