Memorandum No. 18 Authentication in Distance Education Policy

Policyholder: Dean, Online Learning and Media Services
Effective Date: July 1, 2022
Approved By: President

I. Introduction

The purpose of this policy on authentication in distance education is to establish identity verification procedures for students enrolled in online and hybrid courses, as well as for all students who access personal, identifiable information via the student portal at myccp.ccp.edu. This policy is to ensure that Community College of Philadelphia operates in compliance with the provisions of the United States Federal Higher Education Opportunity Act (HEOA) concerning the acceptable verification of student identity in distance education.

II. Compliance

The Code of Federal Regulations 34 CFR §602.17(g) requires institutions that offer distance education to have processes in place by which the institution establishes that the student who registers in a distance education or correspondence course or program is the same student who participates in, completes the course of program, and receives the academic credit. The institution meets this requirement if it:

1. Requires verification of the identity of a student who participates in class or coursework by using methods such as
   1. A secure login and pass code;
   2. Proctored examinations; 
   3. New or other technologies and practices that are effective in verifying student identity
      
      
2. Makes clear in writing processes that protect student privacy and notify students of any projected additional student charges associated with the verification of student identity at the time of registration or enrollment.

III. Practices for Verification of Student Identity

1. Secure Login and Password
   Students are responsible for providing their complete and true identity information in any identification verification process. Students seeking registration in online courses will be required to provide appropriate identification to establish their identity.
   
   During the application for admission process, student identity is vetted in accordance with standard practices. A network account is created for all students and initial login information is provided to students via email. The login screen reminds students that by logging in they agree to the Acceptable Use Policy for Interactive Systems found on the website https://www.myccp.online/college-policies-and-procedures/acceptable-use-policy-interactive-systems.
   
   The network account in the single sign-on (SSO) system is a College authentication and security measure to ensure that accounts are managed securely across the College. All students at Community College of Philadelphia are provided credentials for secure access to College systems, including for the learning management system used in distance learning. It is against the Policy for Responsible Computing for a user to give someone their password or to allow others to use their account. https://www.myccp.online/college-policies-and-procedures/policy-responsible-computing.
   
   New students claim their network login through the SSO system after providing their unique “Student ID” number (or J#) and their date of birth. As part of this set-up, the active directory identity management system requires that the student create two secure questions and answers to be used in the event that students need to change their password or reclaim their network credentials.
   
   
2. Learning Management System
   Community College of Philadelphia uses a learning management system which integrates with the College’s SSO authentication services to ensure appropriate and secure student access to courses and other student information systems. All users of the College’s learning management system are responsible for maintaining the security of usernames and passwords, or any other access credentials as required. Attempting to discover another user’s password or attempts to gain unauthorized access to another person’s files or email is prohibited.
   
   Course sections and rosters are populated automatically by the student information system. Student enrollment in distance learning information is loaded every four hours to account for section changes or student adds and drops. All credit courses and vocational sections for non-credit courses are included. Non-credit courses considered personal interest courses are not included. Users may not create their own courses or accounts in the learning management system, ensuring that only those with valid network user accounts may access the system and that users may only access sections for which they are enrolled.
   
   

3. Lockdown Browser
   Community College of Philadelphia subscribes to a custom internet browser that locks down the testing environment within the learning management system.  When this is deployed, students are unable to copy, print, access other applications, or visit other websites during the online quiz or exam. The browser can also be installed on a student’s personal computer and is available in the computer labs on campus.

4. Proctored Examinations
   Community College of Philadelphia uses software to proctor online assessments via a web camera. Irregularities are flagged and these videos can be reviewed later by the instructor. Some faculty and departments elect to use proctored exams and students are notified through various channels prior to registering for a class if the exams will be proctored online. However, faculty are encouraged to use authentic assessments to deter academic dishonesty.

5. Charges for identity verification
   At this time there are no additional student fees associated with student verification.

6. FERPA
   Community College of Philadelphia complies fully with the provisions of the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. 1232g. This act protects the privacy of student information in distance education by requiring, with certain limited exceptions, that the student’s consent must be obtained before disclosing any personally identifiable information in the student’s education records. Additional information on FERPA can be found here https://www.myccp.online/starfish-connect/ferpa-and-privacy.

IV. Enforcement

Any online student work, assessments or activities that are graded or contribute to a student’s grade must be submitted via a system that verifies the student’s identity as noted above.

Failure of students to comply with this policy will be addressed through the College’s Policy on Academic Integrity and/or the Student Code of Conduct as noted in the College’s Student Handbook.

V. Responsibilities

All users of the College’s information systems including the learning management system are responsible for maintaining the security of usernames, passwords, and other access credentials as required. An account is given to an individual for exclusive use by that individual. Attempting to discover another user’s password or attempts to gain unauthorized access to another person’s files or mail is prohibited. It is against College policy for a user to give someone their password or allow others to use their account. Users are responsible for all activity on their accounts.

1. Faculty
   Faculty teaching courses through distance education methods also play a role in ensuring that students comply with this policy. As technology and personal accountability are not absolute in determining a student’s identity, faculty members are encouraged to design courses that use assignments and evaluations that support academic integrity. Plagiarism detection software is also available for use in determining academic integrity.
   
   
2. Administration
   The Vice President of Academic and Student Success is responsible for ensuring compliance with this policy, and that deans, department chairs, and program coordinators are informed of any changes in the policy in a timely fashion.

VI. Review

This policy will be reviewed regularly in accordance with the Policy on College Policies. The Vice President of Academic and Student Success will inform deans, department chairs, and program coordinators when changes are made to this policy.