ROWAN UNIVERSITY POLICY
Title: Verification of Student Identity
Subject: Academic Affairs
Policy No: AA 2018:01
Applies: University-Wide
Issuing Authority: Provost and Executive Vice Chancellor for Academic Affairs, Vice Chancellor for Student Affairs and CEO of Rowan Online/CTO
Responsible Officers: Associate Vice President for Online Learning, Deans, Department Chairs, and Department Heads
Adopted: July 2013
Last Revision:
Last Reviewed:
I. PURPOSE
To ensure University compliance with the provisions of the United States Federal Higher Education Opportunity Act (602.17(g) concerning the verification of student identity in distance learning[1].
To provide students, faculty, and staff with direction regarding the use of examination integrity technology for the purpose of preventing potentially fraudulent behavior during examinations in online courses.
II. ACCOUNTABILITY
Under direction of the Provost and Executive Vice Chancellor for Academic Affairs, Senior Vice President for Academic Affairs and CEO of Rowan Online/CTO, Deans, Department Chairs, and Department Heads will ensure compliance with the policy.
III. APPLICABILITY
This policy applies to all students, faculty, and staff of Rowan University involved in credit-bearing distance learning courses and programs offered through Rowan Online, beginning with application for admission and continuing through to a student’s graduation, transfer, or withdrawal from study.
IV. DEFINITIONS
- Distance education: instruction delivered when students and instructors are not physically co-located, using technologies such as the internet.
- Automated proctoring: the use of software and technology (camera and microphone) to monitor online assessments for academic integrity violations without live human oversight.
- Personally identifiable information: any information that can be used to identify, contact, or locate an individual.
V. POLICY
To comply with federal regulations, Rowan University must verify that the student who registers for a credit-bearing distance education course is the same student who participates in and completes the course in order to award academic credit.
To verify a student’s identity, the university may use process and technical solutions, including but not limited to
- in-person or remote presentation and review of government-issued identification;
- secure account authentication solutions;
- remote or automated proctoring solutions; and/or
- other technical solutions and practices that are effective in verifying student identification and have been reviewed and approved in accordance with the university’s technology acquisition policies and procedures.
Personally identifiable information collected by Rowan may be used at its discretion and in compliance with prevailing legal regulations as the basis for identity verification.
All methods of verifying student identity in distance education must protect the privacy of the student in accordance with applicable regulations including FERPA [2].
Students must receive written notification at the time of registration or enrollment for any fees associated with verification of student identity that are to be charged to the student.
Instructors are required to provide students with advance notice before using any identity verification solution in a course.
Students have the right to request an alternative method of identity verification in consultation with the course instructor. The course instructor will determine the alternative verification method to be used.
Rowan reserves the right to employ any legally permissible manual and/or automated processes to verify that an enrolled student is the individual who applied for admission, registered for courses, participates in instructional activities, and receives academic credit or financial aid and will implement additional verification activities in the case of suspected fraud. Indicators of potential identity fraud may include inconsistent identifying information, suspicious technology-use patterns, failure to complete identity-verification requests, evidence of impersonation, or other factors suggesting the enrollment is not associated with a legitimate student. In such cases and where circumstances dictate, Rowan reserves the right to require additional documentation, conduct identity-verification interviews, place registration or financial-aid holds, or administratively withdraw an enrollment when identity cannot be satisfactorily established."
VI. References
[1] Electronic Code of Federal Regulations, “34 C.F.R. § 602.17 — Application of standards in reaching accreditation decisions,” eCFR, 2026. [Online]. Available: eCFR Section 602.17
[2] Family Educational Rights and Privacy, 34 C.F.R. Part 99, 2026. [Online]. Available: eCFR – 34 C.F.R. Part 99