Supporting Students’ Gender Identity: An IT Perspective

In May 2016 the Department of Education issued a “Dear Colleague” letter regarding transgender and gender-nonconforming students. In its letter, the department reminded institutions that Title IX protects all students from sex discrimination. Thus, once the institution has been notified that student will begin asserting a gender identity that differs from previous representations or records, the institution must begin treating that student consistent with the student’s asserted gender identity. This fall a small group of EDUCAUSE members met to discuss the issues to consider in implementing processes within IT systems to support a student’s gender identity (meaning the use of both a preferred name and a preferred pronoun).¹

From an IT perspective, implementing a student’s preferred name and pronoun can be challenging. The group identified a number of questions that the institution will need to address in its preferred name policy and administrative processes supporting the policy. For example, how do institutions implement a preferred name and/or gender identification process that meets the needs of all students?²

Even where institutional preferred name policies and supporting administrative processes are carefully specified, implementing a student’s preferred name and gender identity in IT systems can challenge IT staff. The group noted that institutions will need strong identity and access management practices to ensure seamless processes that are transparent to both the student and the institution.

Key Administrative Policy Questions to Ask

As a first step in implementing a preferred name/pronoun process,you might find it helpful to understand how your peer institutions approach this issue and consider using their models to help navigate the topic on your campus where appropriate. The Campus Pride website contains a roster of the colleges and universities that allow students to change the name and gender on their campus records, divided into institutions that (1) enable students to use a preferred first name instead of their legal name on campus records; (2) enable students to change their gender on campus records without proof of medical intervention; and (3) enable students to indicate their preferred pronoun.

Once you have determined your institution’s fundamental approach to a preferred name policy, your institution will need to address a number of key issues surrounding enabling students to choose a preferred name:

• Who may indicate a preferred name? Will you enable faculty and staff as well as students to choose their preferred name? What about alumni?
• Are preferred names vetted and sometimes disallowed? Should there be a pre-approval process for preferred name choices, a review after the fact for violation of guidelines, a review triggered by complaints, or no oversight? You will probably want to prepare to deal with those who feel some options provided are inappropriate, or that individual choices of preferred names are offensive. And you will certainly need to have a means to respond to subsequent requests for a greater range of options (including orthographic options and pronoun choices).
• Who makes decisions concerning the institution's procedures and policies concerning preferred names? Students’ (and employees’) names are used throughout your institution, so whatever policies and practices you adopt will have stakeholders throughout campus and beyond, including families, media, and alumni. At the very least, you will want to engage registrars, legal counsel, students, faculty and staff governance, organizations providing support and/or advocacy for gender issues, and IT groups that will implement policies in your IT systems.
• Will you maintain a history of preferred name and who or what services will be allowed to correlate a preferred name with the person's legal name in your records? Some people might choose a preferred name in order to obscure or avoid association with a legal name, so providing an easy mapping from preferred name to legal name will be seen as partially defeating the purpose of enabling preferred names. Ultimately, institutions need a single record for an individual, so some ability to map preferred names to the corresponding legal name is essential.
• If you adopt use of preferred names incrementally, how will you handle the apparent cacophony of mixed and changing use of names in your systems? Institutions relying on identity management with a central repository of identity information used by many systems will have an advantage in having fewer distinct systems in which preferred names must be explicitly countenanced. Institutions without such a central repository will need policies to handle interim situations where different systems use different names for the same person(s).

A topic of special interest is understanding when an institution should use a student’s preferred name and when it must use the student’s legal name in institutional IT systems and campus records. While institutions should always consult with their legal counsel in making these determinations, sometimes case studies help illustrate the requirements. The University of Alaska shared that preferred names may be used in the following university IT systems or campus records: UAOnline, DegreeWorks, and Blackboard (student access systems); class and grade rosters; Dean’s List and Chancellor’s List recognition; advisee lists; student and employee ID cards; unofficial transcripts; and directory listing and directory information. Legal names, on the other hand, should be used for official university records, such as official transcripts; student account statements (bills); financial aid and scholarship documents; responses to individual enrollment inquiries such as verification requests under legal and/or preferred name; National Student Clearinghouse enrollment and degree verification; professional education certification records; student employment documents; housing contracts; legal documents and reports produced by the university; legal and mandatory reporting of benefits; paychecks, W2s, and other payroll documents; employment verifications; and employment documents.

Key Technical Implementation Concerns

In implementing a preferred name policy on your campus, a number of technical questions must be dealt with, and these almost all require the active participation of — if not complete management by — the IT division. While a number of discrete technical decisions will need attention, this section focuses on some of the high-level decisions required to implement a preferred name policy in IT systems serving your campus.

From an IT perspective, the first decision is which system should be the location of record — the primary or authoritative IT record system for the institution. Generally, it’s best to have one system (either your enterprise resource planning system or perhaps your customer relationship management system) where the preferred name will first be stored.³ Generally, modern ERP suppliers have already established a preferred name field; all you will need is a way of entering that information.

Once you have chosen a location of record, the next task will be to decide which other systems need to display the preferred name. This is a crucial choice, particularly for transgender students, because the goal of the preferred name process is to make only their preferred name visible to those who interact with them (particularly faculty, residence hall personnel, and academic advisors). Typically, populating your learning management system, advisement tracking software, and residence hall programs will require resident coders to connect the dots, and this will take time and extensive testing.

Consider also the assignment of usernames. Some institutions assign usernames (often called NetIDs, student IDs, or campus IDs) automatically based on people’s names. Once a preferred name policy is implemented, the institution will need to decide whether it’s necessary to change those automatically, or when requested. In some cases you might decide not to change things. For example, at Wayne State users may use any alias they choose, but a first.last alias is also created. The university’s technical experts decided that creating a new first.last alias every time someone added a new preferred name would proliferate aliases and might create collisions, so they decided to leave the first.last name alone. That way people who had been sending to that alias could still anticipate the recipient getting their mail.

An institution will also have to consider, from a technology perspective, to what extent it will accommodate names using expanded (non-ASCII) characters. If institutions enable greater flexibility to accommodate individuals' choice of how their name appears, they can better represent the names of international students as well. Given that some people who choose a preferred name might want characters beyond the standard ASCII set, the institution needs to decide whether to implement Unicode in UT8 encoding.

Similarly, people often have names that exceed a system-enforced character limit — a particularly vexing problem for hyphenated and non-Western names. Past restrictions of names to short strings of capital letters may have been justified by technological limits, but would seem obnoxious anachronisms today. Complete freedom to represent a name in any script is probably technically infeasible in many systems, but long names; names including spaces, hyphens, and other punctuation; and diacritics might be compatible with many systems and allowed in preferred names. A policy should consider how names with expanded characters are mapped to ASCII strings for systems that require that simpler representation.

Finally, institutions need to start working with vendors to ensure that commercial systems meet institutional needs when implementing preferred name and pronoun policies. This point is critical. Almost all customer relationship management systems are provided by commercial vendors, as are most learning management systems.⁴ Both CRMs and LMSs enable faculty members, advisors, and others to connect with students, and they must enable good “first impressions” by allowing institutional representatives to address students appropriately, using their preferred names. Institutions together should insist that vendors expand existing fields and offer new fields to implement preferred name and pronoun policies. And we must encourage them to modify their products to incorporate the appropriate range of nuance needed to comply with the law and support our entire community.

Recommendations

In this area of rapidly changing social norms and expanding awareness of options, institutions are unlikely to arrive at a solution comfortable for everyone — or that will seem adequate even a couple of years from now. At this point, we need to build in as much flexibility as possible into policy and processes, even if institutional IT systems are not as flexible as we might like. Recommendations include:

• Take action! The Department of Education requires that all students be protected from discrimination.
• Institutions should adopt a policy for preferred name changes and procedures to support that policy. This might be a difficult area for students to navigate, and having formalized policies and procedures will ease their administrative burden.
• Strong campus identity and access management practices can help manage name changes from the IT system perspective. An identity and access management system provides a framework for managing identities in IT systems. A single authoritative campus identity management system makes managing preferred name activities easier.

Notes

1. In August 2016 the EDUCAUSE Chief Information Officer (CIO) discussion list held a conversation [http://listserv.educause.edu/scripts/wa.exe?A1=ind1608&L=CIO#24] regarding preferred name policies and how those policies should be implemented in IT systems as a result of the guidance issued by the Department of Education. Ensuing conversation [http://listserv.educause.edu/scripts/wa.exe?A1=ind1608&L=CIO#34 ] noted that many individuals, for many different reasons, may use a preferred name that differs from their legal name and asked what issues should be considered, from an IT perspective, when an institution wants to implement a preferred name process for students, faculty, and staff. And, what recommendations are available to institutions creating such a process?
2. The group noted that implementing a preferred name process may benefit a number of students. For instance, international students who want to adopt a chosen name different from their legal name may also take advantage of an institutional preferred name process.
3. Customer relationship management systems were the fastest-changing higher education core information system area in 2015. Seven in 10 institutions provided a CRM system in 2015. Leah Lang and Judith A. Pirani, The 2015 Enterprise Application Market in Higher Education: Customer Relationship Management Systems, research report (Louisville, CO: ECAR, September 8, 2016).
4. Enterprise Applications in Higher Education, Implementation Data Visualization.

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David Bantz is identity and access analyst at University of Alaska.

Geoffrey S. Nathan is information privacy officer for Wayne State University.

Andrea Nixon is director of Educational Research at Carleton College.

Theresa Semmens is chief information security officer and director, Records Management, for North Dakota State University.

Renee Wells is director of the GLBT Center, North Carolina State University.