May a social security number or other student identification number be listed as directory information?

May a social security number or other student identification number be listed as directory information?

A school may not designate a student’s social security number as directory information.  However, directory information may include a student’s user ID or other unique identifier used by the student to access or communicate in electronic systems, but only if the electronic identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the student’s identity, such as a personal identification number (PIN), password, or other factor known or possess only by the student or authorized user.   34 CFR § 99.3 “Directory information”