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Identification Photo Policy
Faculty, Staff and Students of the University of Missouri – St. Louis (UMSL)
Policy Statement Revised 02/24/2015
The University of Missouri – St. Louis believes in the protection of the privacy of its students, faculty and staff. Photos taken for identification purposes (hereafter, Identification Photos) are considered a form of personally identifiable (PI) information and must be protected as prescribed by FERPA, applicable UM Policies on handling classified PI information and generally accepted privacy standards.
1) Identification Photos defined. UMSL wishes to use the guidelines of a biometric data standard (ISO/IEC 19794-5:2011(en) for the interoperability of facial recognition systems) to distinguish Identification Photos from all other photography and imaging. Identification Photos in the sense of this policy will, therefore, consist of 2D head/shoulder digital frontal images of single individuals under controlled lighting, against a plain white background at a controlled resolution taken for the purpose of identification by the TritonCard office or its designees.
2) Privacy. Identification Photos are a part of the student’s academic record, are non-directory data under FERPA and may only be used as limited by FERPA and this policy. Identification Photos for faculty and staff are part of their HR record. Identification Photos and other personally identifiable information may be released at the direction of UM legal and/or a court of law or to other educational institutions for the purposes of enrollment. This policy and the current usage of Identification Photos will be made available on the UMSL website. At the time of acquisition, faculty, staff and students must be provided the following information:
a. A copy of this policy or a way to access it via a website.
b. A notice that posting policy changes on the website will constitute informing the community.
c. The specific purpose for this Identification Photo and the mandatory and optional applications in which it will be used.
d. A statement that the Identification Photo will not be used for purposes other than those stated on the website (including in this policy) without notification.
e. A statement that the Identification Photo data will be handled at the appropriate Data Classification Level (DCL).
f. A statement as to how the Identification Photos can be updated (some cost may be incurred).
g. A statement as to how to opt out of optional applications wishing to use Identification Photos will be available if use of the Identification Photo is optional.
3) The TritonCard. To attend UMSL, students must have a TritonCard. To work for UMSL, faculty and staff must have a TritonCard. This requires students, faculty and staff to have Identification Photos taken at the TritonCard office or under its auspices. TritonCards are used to identify the holder of the card as a current member of the UMSL community for the purpose of
a. Accessing UMSL services, facilities or obtaining goods.
b. Upholding public safety by the Campus Police.
4) Mandatory Identification Photo usage:
a. are available on class rosters to assist faculty recognition of students.
b. are available to staff for academic and administrative procedures.
5) Other usage. In general, Identification Photos will be used solely for identification purposes and will not be transferred to internal or external third parties. However, Identification Photos may be used for any purposes on any UM campus, UM System or Cloud based system (even if created and/or operated by third parties) so long as:
a. individuals are informed of this fact directly or on the UMSL web site.
b. in the case of students, the Registrar has approved the use.
c. in the case of Faculty and Staff, HR has approved the use.
d. in all cases the CIO has approved the use.
e. individuals can opt out of optional/non-mandatory usage.
f. so long as the individuals can update their Identification Photos in third party systems .
g. so long as any systems involved have passed a security review and steward the Identification Photos at the same or higher DCL level.
6) Non-Identification Photos. Photos or images of any nature not taken by the TritonCard Office expressly for identification purposes do not fall under this policy but may be subject to other policies and/or laws.