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2003 Opinions

Date:   March 10, 2003
Prepared By:   Ronald G. Stowers
Phone:   (850) 922-7095
Opinion No.:   03-03
Staff Contact:    
TO: Terry Bovino, Chief Officer
Quality Assurance & Curriculum Support
Okaloosa County School Board
FROM: Daniel Woodring
General Counsel
SUBJECT: Use of teachers' social security numbers in submitting state database "responsible instructor" information
RE: Opinion request dated January 10, 2003

QUESTION PRESENTED: Are school districts required to use teachers’ social security numbers when reporting to the state database concerning information concerning “responsible instructor?”


DISCUSSION: The Commissioner of Education is charged with maintaining an integrated information system for educational management. See, Sections 1001.11(4), (5) and(6) and 1008.385(2), Florida Statutes. This is called the Comprehensive Management Information System. The Commissioner’s responsibilities include providing operational definitions for the system (Section 1008.385(2)(a)2., Florida Statutes), determining information and data elements required for management decisions (Section 1008.385(2)(a)3., Florida Statutes) and developing standardized terminology and procedures (Section 1008.385(2)(a)4., Florida Statutes). To maintain this system, the Department of Education collects data from school districts to determine student, school, and district performance, and to support management decisions at the departmental, district, and school levels.

The State Board of Education is authorized to adopt rules and administer provisions of Section 1008.385, Florida Statutes. See, Section 1008.385(3), Florida Statutes.

The Department of Education’s Bureau of Education, Information, and Accountability Services maintains the database established by Section 1008.385, Florida Statutes. The Department has promulgated a rule to implement this section. See, Rule 6A-1.0014, Florida Administrative Code. The rule prescribes data collection on an annual basis and specifically incorporates a three volume publication entitled “DOE Information Data Base Requirements: Volume I-- Automated Student Information System, 2000; Volume II--Automated Staff Information System, 2000; and, Volume III–Automated Finance Information System, 1995.” This publication is also known as the “Manual.” This rule was initially adopted in 1987 and has been amended several times since to incorporate changes to the Manual. The collection of the “responsible instructor” element was first required in the 2000-2001 Manual. The social security number of the “responsible educator” is specifically required by the data element.

CONCLUSION: You have requested our opinion as to whether the use of teacher social security numbers is appropriate when reporting “responsible educator” information to the state database, because of concerns raised by the Okaloosa County Education Association. The social security numbers of teachers are used for various purposes by both school districts and the Department of Education. These purposes include employment, retirement and certification information. Please be advised that the use of teachers’ social security numbers in reporting the “responsible instructor” element is mandatory, as it is specifically required by the Manual and incorporated into Rule 6A-1.0014, Florida Administrative Code.

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