06-05.10 – Policy on Public Records Containing Sociological Information

  1. Policy Statement:

    This policy is intended to define Sociological Information that shall be excluded from inspection and disclosure as part of a public record under the Maryland Public Information Act (codified at Annotated Code of Maryland, General Provisions Article, § 4-101, et seq.) (the “Act”).

    The Act grants the public a broad right of access to government records. Section 4-330 of the Act, however, provides, “If the official custodian has adopted rules or regulations that define sociological information . . . a custodian shall deny inspection of the part of a public record which contains sociological information, in accordance with the rules or regulations.”

    The exclusion of Sociological Information from public disclosure will serve to preserve the privacy of personal information and combat identity theft victimization of the University community.

  2. Definitions:

    1. “Sociological Information” is any information as further defined in this policy that may compromise, or be combined with other data to compromise, a University community member’s personal information or put a University community member at risk of identity theft victimization.

    2. “University” means Towson University.

    3. “University community member” includes, but is not limited to, students, faculty, staff, employees, vendors, donors, and any individuals participating in a University program or event or using University facilities.

  3. Responsible Executive and Office:

    Responsible Executive: Vice President of Legal Affairs and General Counsel

    Responsible Office: Office of the General Counsel

  4. Entities Affected by this Policy:

    All University community members including, but not limited to, all divisions, colleges, departments, operating units, students, faculty, staff, employees, vendors, donors, or other individuals participating in a University program or event or using University facilities.

  5. Procedures:

    In accordance with the Maryland Public Information Act, the University adopts the following definition of Sociological Information shielding such information from inspection or disclosure as part of a public record. Sociological Information of a University community member shall include:

    1. Scholarship, stipend and financial aid records of individuals or their families;

    2. Records about an individual’s personal history, age, family, race, national origin, creed, color, sex, pregnancy, sexual orientation, ethnic background, ancestry, physiology, religion, academic achievement, attendance in classes or employment, gender identity or expression, genetic information, veteran status, or physical or mental ability;

    3. Family history; identity of relatives, emergency contacts or representatives;

    4. Medical or psychiatric history;

    5. Social security numbers;

    6. Date of birth;

    7. Credit card and other banking information;

    8. Personal addresses, personal phone numbers, personal electronic mail address and personal social media account information;

    9. Information regarding marital status, domestic partnership, dependents, or relatives, to include related employment benefits elections;

    10. Information regarding employment status, including disciplinary records and records related to an application for employment;

    11. Applicant information for admission, scholarships, employment or awards, including those of applicants who were either not selected/admitted or chose not to matriculate;

    12. Class or employment attendance information;

    13. Military service;

    14. Driver’s license number;

    15. State residency classification;

    16. Immigration status, passport and visa numbers;

    17. Religious preference, membership and attendance;

    18. Personal relationships, beliefs and values;

    19. Any information obtained through employment coaching or surveys;

    20. Financial information, including income (excluding state salary), assets, and liabilities;

    21. Donation and donor information, such as gift agreements, communications, contact information, for individuals who have made charitable donations of goods, services, money or anything else to the University;

    22. Student education records of a deceased student;

    23. Program participation and community experiences and activities;

    24. Records not related to the transaction of State business.

    25. Records which contain political opinions, philosophical beliefs, and club/union membership;

    26. Unique biometric data biometric information including an individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity;

    27. Internet or other electronic network activity information, including browsing history, search history, wireless network location data and information regarding an individual’s interaction with an internet website or application; and

    28. Institutional identification number assigned to each applicant, student or employee (e.g. Workday ID, Employee ID, TU ID number) and photograph.

The University shall deny access to a public record, or portion thereof, containing Sociological Information.

Related Policies: TU Policy 06-05.00 – Policy on the Disclosure of Public Records

Approval Date: 04/06/2022

Effective Date: 04/06/2022

Approved by: President’s Council

How to Request the Policy PDF

This online version of the policy may include updated links and names of departments. To request a PDF of the original, signed version of this policy, email the Office of the General Counsel, .