Date of Birth Question

This is a worksheet for suggestions for revising the Date of Birth (Birthdate) question in OpenCCC and CCCApply.

Action Item: Send all information, existing question language and proposed language, and details of the meetings discussions to Mia Keeley, CCCCO for help in determining if the onscreen language/text in the DOB question can be changed (shortened, revised, etc.).

 

Purpose of the Date of Birth Question

The data field behind this question is called “Birthdate” = <birthdate> and the format is a valid date.

In the 2020 CCCApply Data Dictionary and General Specification, the Date of Birth data field storage and usage specifications explain:

“Birth date is used in the admission application to calculate <your> age and to identify minors for residency calculation and collection of parent or guardian contact information. The Office of Civil Rights (OCR) acknowledges that the collection of birth date is allowed under California State law.

For residency and minor identification, the applicant’s age is calculated as of the day before the first day of the term start date, or the RDD <ResidencyDeterminationDate>.”

“Birth date is sensitive information, protected by federal law and the Office of Civil Rights (with regard to age discrimination). Any change to the text, prompt, access, or transmission of this data item must be approved by the Legal Counsel of the CCC Chancellor’s Office and the Office of Civil Rights.

This information may not be provided to staff in the capacity of making a decision to admit an applicant until after the applicant is admitted—that is, uniformly enabled to register for classes.

This is MIS data: CO MIS DED SB03.

OpenCCC Account: OCR acknowledges that collection of date of birth is allowed under California State law.”

 

Note: In September 2018 (release 6.2.0), the CCCApply Steering Committee approved a change request supported by the CCCCO to remove the restriction preventing persons under age 13 from creating an OpenCCC account per COPPA law. The argument was that the COPPA law was specific to non-educational online accounts, and therefore applicants under age 13 would be allowed to create an OpenCCC account and apply for admission through CCCApply.

 

 

Statistical Information

In FY 2018-2019, over 2.6 million CCCApply applications were submitted. For the purposes of this breakdown, spam applications were not removed from the total = 2,647,615.

Of the 2,647,615 apps submitted:

  • X number of all apps are from minors under age 13


Next Actions:

Work with the Chancellor’s Office to confirm if the language in the DOB question in OpenCCC system can be revised.

  1. Mia Keeley offered to work with us to ensure all changes are compliant and approved for development

  2. Review proposed language changes

 


Problem / Need

The DOB question will remain in the new OpenCCC system, currently under-development by the Tech Center. However, the proposed plan is to remove all existing language that currently appears in the OpenCCC legacy system and replace with a simple label “Birthdate” - with no prompt text or legal language as mandated in the current DED.

Further, in 2018, the logic and language in the Date of Birth question was revised (approved by the Steering Committee) to no longer restrict applicants age 12 and younger from creating an OpenCCC account, based on the COPPA regulations that the regulations are for commercial websites and not educational accounts. This change was not properly approved by the CO and thus we are seeking retroactive approval to continue allowing children to create accounts for education purposes only.

What do we need to change?

 

TBD


Legal Information

COPPA: Child Online Privacy Protection Act https://www.ftc.gov/tips-advice/business-center/guidance/childrens-online-privacy-protection-rule-not-just-kids-sites

Children's Online Privacy Protection Act of 1998, 15 U.S.C. 6501–6505

Children's Privacy


From CCCApply Standard Application Data Dictionary v.2019.4)

Date of Birth

Data Element:

birthdate

Description:

Applicant’s Date of Birth

Format, Length:

date, 10

Downloads in this format: yyyy-mm-dd

Values:

Valid date

Allows Null:

No

Default:

None

Storage/Usage:

Birth date is used in the admission application to calculate <your> age and to identify minors for residency calculation and collection of parent or guardian contact information. The Office of Civil Rights (OCR) acknowledges that the collection of birth date is allowed under California State law.

For residency and minor identification, the applicant’s age is calculated as of the day before the first day of the term start date, or the RDD <ResidencyDeterminationDate>.

In OpenCCC Account: Stored in database (with leading zeros as appropriate) for use in auto population.

Included in Account Profile.

Notes:

Birth date is sensitive information, protected by federal law and the Office of Civil Rights (with regard to age discrimination). Any change to the text, prompt, access, or transmission of this data item must be approved by the Legal Counsel of the CCC Chancellor’s Office and the Office of Civil Rights.

This information may not be provided to staff in the capacity of making a decision to admit an applicant until after the applicant is admitted—that is, uniformly enabled to register for classes.

This is MIS data: CO MIS DED SB03.

OpenCCC Account: OCR acknowledges that collection of date of birth is allowed under California State law.

Error Checking

(OpenCCC Account Only):

Response required; else error message “Your Date of Birth is invalid or absent. It must be a valid date in mm/dd/yyyy format.”

Date must be valid (‘dd’ must be appropriate for ‘mm’ and ‘yyyy’—for example, 02/29/2009 would not be valid); else error message “Your Date of Birth is invalid or absent. It must be a valid date in mm/dd/yyyy format.”

Date must be a valid date that is today’s date or prior to the current date, else error message, "Your date of birth must be before today’s date."

Leading zeros are not required for ‘mm’ or ‘dd’: 02/04/2010 and 2/4/2010 are acceptable and equivalent.

When editing account information from either the Standard, International, or BOG applications, if the user attempts to change both their name and their date of birth, the following error displays: "You cannot change both your name and your date of birth. If you are sharing someone else's account to make this application, please create your own account. If you are using your own account and need to change both your name and your birthdate, please contact OpenCCC Support."

Prompt Text

(OpenCCC Account Only):

This information is used for protection of minors in online transaction environments, as well as to differentiate between persons having the same name. It is also used to comply with state and federal law pertaining to residency, guardianship, and admission of minors to college. This information will not be used in making admissions decisions except as permitted by law.

Date of Birth [date textbox combo boxes] mm/dd/yyyy

Hover Help

(OpenCCC Account Only):

DOB Year Open Text Box: Enter in the 4 digit year you were born.

Spanish Hover Help:

DOB Month Drop Down Box: Seleccione el mes en que nació en la lista desplegable.

DOB Day Drop Down Box: Seleccione el día en que nació en la lista desplegable.

DOB Year Open Text Box: Introduzca los 4 dígitos del año en que nació.

Input Rules

(OpenCCC Account Only):

Required user response, else error message “We found some problems with the information you submitted: Your Date of Birth is invalid or absent. It must be a valid date in mm/dd/yyyy format."

 

Date of birth may not be changed at the same time (i.e., during the same ‘Save’) as either the first name or the last name; else error message, “We found some problems with the information you submitted: You cannot change both your name and your date of birth. If you are sharing someone else's account to make this application, please create your own account. If you are using your own account and need to change both your name and your birthdate, please contact OpenCCC Support.”

Xap Field:

Birthdate

MIS Correlation:

SB03

Revision Log:

  1. 15.19: Added error validation that prevents a date from being entered that is after the current date.

  1. 14.18: Language & logic to restrict account creation for users under age 13 was removed in Release v.6.2.0

: Date of birth is needed in account creation to identify applicants who are too young to transact business online per COPPA (Child Online Privacy Protection Act--under age 13).

  1. 14.18 – Removed onscreen prompt text: “

Due to laws regarding children's online privacy, this system will not allow accounts to be created by persons under the age of 13. For more information, please refer to the Privacy Policy.”

  1. 14.18 - Removed error validation logic:

Date may not be less than 13 years before current date; else error message, “You cannot create an account if you are less than 13 years of age.” "Federal privacy laws restrict applicants age 13 or younger from creating an online account and applying to college using an online application. Please contact the college's Admissions & Records Office for assistance."

  1. 14.18 – Remove Input rule:

Date may not be less than 13 years before current date; else error message, “We found some problems with the information you submitted: Federal privacy laws restrict applicants age 13 or younger from creating an online account and applying to college using an online application. Please contact the college's Admissions & Records Office for assistance.

per re-evaluation of COPPA laws pertaining to an online account for the purposes of applying to an educational institution.