Institutional Practices for Verification of Student Identity and Protection of Student Privacy

Student Identity Verification

An institution offering distance education or correspondence education, as such terms may be defined in federal regulations shall have processes through which the institution establishes that the student who registers in the distance education or correspondence education courses or programs is the same student who participates in and completes and receives the academic credit.

In verifying the identity of students who participate in class or coursework the institution may make use of a one or more methods, at the option of the institution, which may include but need not be limited to: (1) secure login and pass code; (2) proctored examinations; and (3) new or other technologies and practices that are effective in verifying the identity of students. Institutions must notify students at the time of registration or enrollment of any projected additional student charges associated with the verification of student identity such as separate fees charged by proctoring services, etc.

Student Privacy

All institutions must maintain procedures and processes for ensuring the protection of student privacy. Such procedures and processes, including any methods related to student identity verification must also implement reasonable and appropriate safeguards to protect student privacy.

HLC Review

HLC will review an institution’s student identity verification protocols when an institution requests permission to add programs in distance delivery and correspondence as well as during a comprehensive evaluation that includes a Federal Compliance Review. HLC will also require that institutions submit information about student identity verification protocols on HLC’s Institutional Update.

HLC will review all institutions’ procedures and processes for ensuring the protection of student privacy during all comprehensive evaluations within the context of the Criteria for Accreditation.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 2009
History:* revised February 2010; revised and renumbered June 2012; renumbered November 2012 (former policy number 4.0(d)); revised June 2019 (effective September 2019); edited February 2021; revised June 2022; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.