BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 1349
                                                                  Page  1

          Date of Hearing:   July 3, 2012

                       ASSEMBLY COMMITTEE ON HIGHER EDUCATION
                                 Marty Block, Chair
                      SB 1349 (Yee) - As Amended:  June 25, 2012

           SENATE VOTE  :   28-5
           
          SUBJECT  :   Social media privacy: postsecondary education.

           SUMMARY  :   Prohibits public and private postsecondary 
          educational institutions from requesting or requiring students, 
          prospective students, or student groups to provide access to 
          their social media information and thoughts.  Specifically,  this 
          bill  :   

          1)Finds that quickly evolving technologies and social media 
            services and websites create new challenges when seeking to 
            protect the privacy rights of students at California's 
            postsecondary institutions.

          2)Prohibits public and private postsecondary educational 
            institutions and their employees and representatives from 
            requiring or requesting a student, prospective student, or 
            student group do any of the following:

             a)   Disclose a user name or password for accessing personal 
               social media; 

             b)   Access personal social media in the presence of a 
               postsecondary educational institution's employee or 
               representative; or, 

             c)   Divulge any personal social media.

          3)Provides that a public or private postsecondary educational 
            institution shall not discharge, discipline, or otherwise 
            retaliate against a student, prospective student, or student 
            group for choosing not to comply with any request or demand 
            that violates this section.  

          4)Provides that nothing in this section shall:

             a)   Prohibit a public or private postsecondary educational 
               institution from terminating or otherwise taking other 








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               adverse action against a student, prospective student, or 
               student group for any lawful reason, or,

             b)   Affect a public or private postsecondary educational 
               institution's existing rights and obligations to protect 
               against and investigate allegations of student misconduct 
               or student violations of applicable laws and regulations.

          5)Provides that private nonprofit and for-profit postsecondary 
            educational institutions in California shall change their 
            relevant policies to ensure compliance with the bill.

          6)Defines "social media" broadly to include, but not be limited 
            to an electronic service or account, or electronic content, 
            including but not limited to videos or still photographs, 
            blogs, video blogs, podcasts, instant and text messages, 
            e-mail, online services or accounts, or Internet Web site 
            profiles or locations.

           EXISTING LAW  :

          1)Requires the University of California (UC) Board of Regents, 
            the California State University (CSU) Board of Trustees, and 
            the governing board of every California Community College 
            (CCC) district to adopt specific rules and regulations 
            governing student behavior along with applicable penalties for 
            violation of those rules and regulations.  (Education Code § 
            66017 and 66300)

          2)Authorizes the governing board of a CCC district, the 
            president or an instructor to suspend a student for "good 
            cause," and prohibits the removal, suspension, or expulsion of 
            a CCC student unless the conduct for which the student is 
            disciplined is related to college activity or college 
            attendance.  (EC § 76030)

          3)Prohibits the UC Regents, the CSU Trustees, and the governing 
            board of every CCC district from making or enforcing any rule 
            subjecting any student to disciplinary sanction solely on the 
            basis of conduct that is speech or other communication, when 
            engaged in outside a campus of those institutions, protected 
            by the United States or California constitutions.  An enrolled 
            student may pursue a civil action against these institutions 
            in the event they seek to make or enforce any such rule.  (EC 
            § 94367)








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          4)Institutional policies:

             a)   CSU rules of student conduct are outlined in the 
               California Code of Regulations (Title 5, Article 2, Section 
               41301) and provide that any student may be expelled, 
               suspended, placed on probation or given a lesser sanction 
               for one or more causes, as specified.  Conduct that 
               threatens the safety or security of the campus community or 
               substantially disrupts the function or operation of CSU, 
               whether it occurs on or off campus, is within the 
               jurisdiction of the Student Conduct Code.  Systemwide 
               procedures for implementing student disciple are set forth 
               in Executive Order #1043, which, among other things, 
               authorizes a student conduct administrator to investigate 
               the matter. 

             b)   At UC, enrolled students are subject to university 
               authority, which includes the prerogative of dismissing 
               students for a number of violations including participation 
               in a disturbance of the peace or unlawful assembly.   If 
               specified in implementing campus regulations, these 
               standards of conduct may apply to conduct that occurs off 
               campus and that would violate student conduct and 
               discipline policies or regulations had the conduct occurred 
               on campus.  

           FISCAL EFFECT  :   Unknown.  This bill was referred from the 
          Senate Appropriations Committee pursuant to Senate Rule 28.8.

           COMMENTS  :   This bill was heard by the Assembly Judiciary 
          Committee on June 26, where it was approved by a unanimous vote, 
          after being amended to remove provisions related to employers 
          and to broaden the definition of social media.

           Need for this bill  .  According to the author, "There is a 
          growing nationwide trend of colleges and universities who are 
          requiring user names and passwords to the social media accounts 
          of students.  Student athlete cases have involved requiring that 
          the student athlete download an application which monitors the 
          content of their social media account or requires that the 
          student athlete allow a coach or other designated person access 
          to the private content of their social media account."

           Current policies/practice and NCAA compliance  .  According to the 








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          public postsecondary educational institutions, they do not 
          currently engage in the activities prohibited by this bill.  
          However, it appears that some private postsecondary educational 
          institutions do request that their student athletes provide 
          information on their social media accounts.  Reportedly this is 
          to ensure that these students adhere to student athlete ethics 
          codes, as required under National Collegiate Athletic 
          Association (NCAA) rules.  However, the University of Southern 
          California (USC), which previously submitted Facebook "friend 
          requests" to its student athletes in an effort to monitor the 
          student athletes' social media postings and behavior, reports 
          that the NCAA will not penalize California schools for complying 
          with this measure.  According to USC, the NCAA requires member 
          schools to monitor its student athletes' publicly available 
          social media activity in an effort to catch possible NCAA 
          violations.  However the NCAA does not require California or any 
          other postsecondary educational institutions to seek to monitor 
          the private personal information contained in their athletes' 
          non-publicly available social media.  Thus, this measure should 
          not present any NCAA compliance concerns.

          " Require and request  ".  As noted in the Assembly Judiciary 
          Committee analysis, measures being considered in other states 
          seeking to protect privacy in the social media realm typically 
          seek to bar employers or universities from requiring social 
          media information from employees and students.  This measure, by 
          contrast, appropriately seeks to also prohibit postsecondary 
          educational institutions from requesting that students provide 
          access to social media.  The need for this broader protection is 
          clear: truly uncompelled consent is impossible when a power 
          relationship is as unbalanced as that of a student and his or 
          her university administration or as that of an employee or job 
          applicant and his or her employer or prospective employer.  
          Given that students are often young and unaware of their rights, 
          a student asked for access to her social media by a university's 
          investigatory body or application review board may reasonably 
          worry that declining a request for social media access will 
          either lead to possible retaliation or a lack of college 
          acceptance.  The practical effect of such a request may be that 
          a student (as with employees and job applicants) feels she or he 
          has no real choice but to comply with any such "requests."  This 
          approach is consistent with that taken in similar legislation 
          related to employees and job applicants (see Related legislation 
          below). 









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           Social media definition.   The Assembly Judiciary Committee 
          amended the bill to broaden the definition of social media to 
          include but not be limited to "an electronic service or account, 
          or electronic content."  This definition includes websites and 
          services on which digital media is commonly created, shared, and 
          viewed (e.g., Facebook, Twitter, email accounts), as well as 
          digital media itself (e.g., photos, video, text messages).  It 
          also allows for changing technology that may include new types 
          of media content or services that deserve equal privacy 
          protection. 

          As the Assembly Judiciary Committee analysis notes, "Some 
          observers may initially be tempted to assume that media stored 
          on an individual's mobile phone, and not posted to or shared on 
          a website or service, should not properly fall within the 
          protections of such privacy protection measures.  However it 
          quickly becomes clear that a photo, message, or other form of 
          electronic content contained on an individual's mobile device 
          should be deserving of equal -- or perhaps even more -- privacy 
          protection than a photo, message, or other form of electronic 
          content posted on an online profile or account that the owner 
          already understands that specified friends or associates can 
          view, or perhaps a very broad number of individuals may view.  
          Indeed, if anything, a piece of electronic content that a 
          student (or employee or job applicant) has kept on her or his 
          mobile device -- and chosen not to share with a bounded universe 
          of online friends - may arguably be deserving of even greater 
          privacy protections.  Thus this measure appropriately includes 
          such content in the ambit of its privacy protections."  

           Public safety exceptions  .  Institutions retain the ability to 
          protect against and investigate potential student misconduct to 
          the extent they already can and should do so under current law 
          and regulations.
           
          Author's amendment  .  The author has agreed to accept an 
          amendment to delete language requiring private institutions from 
          reporting and certifying their policies to the Bureau for 
          Private Postsecondary Education, which does not regulate some of 
          these institutions.  Instead the author has agreed to require 
          these institutions to post their social media privacy policies 
          on their websites.

           Efforts in other states  .  Legislation recently introduced at the 
          federal level (known as the "Social Networking Online Protection 








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          Act" or SNOPA) similarly seeks to ban employers from requiring 
          or requesting access to the private email accounts or private 
          social media accounts of employees and similarly seeks to bar 
          higher education institutions and schools from requiring or 
          requesting access to the private email accounts or private 
          social media accounts of students.  Maryland has already passed 
          social media privacy legislation protecting employees, and 
          employee-focused legislation has been introduced including in 
          New Jersey, Illinois, Massachusetts, New York, and other states. 


           Related legislation  .  AB 1844 (Campos), pending in the Senate, 
          would prohibit employers from requiring or requesting social 
          media access from their employees and job applicants. 

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          None on file.
           
            Opposition 
           
          None on file.


           Analysis Prepared by  :    Sandra Fried / HIGHER ED. / (916) 
          319-3960