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are you using directory photos in Active Directory / Outlook?
Does your campus use photo's for internal directory services such as Active Directory/Outlook/Lync?
Many people feel directory photos for internal use only are helpful for a number of reasons. My understanding says that FERPA considers photos directory information for students and generally employers can use this for internal directories at will for internal directories or systems.
Identity and Access Management, College of Charleston
81 St Philip Street, 521
843-953-8207 or firstname.lastname@example.org
College of Charleston