Approval to use student educational record data in your research is contingent on your agreement to:
- Use the information only for purposes of your IRB approved research project. Any new use of the information requires new approval.
- Provide adequate protection for the information to ensure that it is not compromised or subject to unauthorized access.
- Ensure that no one outside of the research team members who are specifically listed on the IRB application have access to the personally identifiable information.
- Ensure that all data shared in aggregate form is properly de-identified to avoid unauthorized disclosure to third parties. IU’s disclosure avoidance procedure is to restrict any cell size that is smaller than 10 when paired with restricted data.
Examples of FERPA violations and possible corrections:
Professor Mathwin and her graduate student assistant Elayne wish to conduct a study which will involve recruiting students who are enrolled in SPEA-E 162. They plan to ask the instructors of each of the class sections to provide them with class rosters to that they can email the students to recruit them for the study.
This recruitment strategy would require the course instructors to violate FERPA regulations because class rosters and student schedules are considered to be confidential information and should not be shared with third parties. The researchers could request that the class instructors send out an email on their behalf and then provide additional information to students who initiate contact.
Professors Cauthon and Aybara wish to test the effectiveness of Professor Cauthon’s introductory course. To do this, they will use pre- and post-test surveys to evaluate the students’ understanding of course material and review their class work, which includes short papers. Professor Cauthon plans to remove student names from the papers and surveys and replace them with subject numbers before any analysis begins.
Professor Aybara does not have authority to access the class work from Professor Cauthon’s class. Note that removing the student names from papers is not a valid way of de-identifying the assignments, as writing samples are considered to be identifiable. Professors Cauthon and Aybara will need to obtain written permission from the students in order for Professor Aybara to have access to their papers.
Professor Ramman, an anthropology professor, wants to research the correlation between Pell grant eligibility and GPA of history majors. To do this, he plans to request a copy of the names of all history majors and their GPAs from the Registrar’s office and a copy of all Pell grant recipients from the financial aid office. After merging the two lists, he will remove all student names.
This information will not be provided to Professor Ramman by either office, as he does not have a legitimate educational interest as part of his university duties to access this data. It may be possible for him to obtain a de-identified list of history majors, their GPAs and Pell eligibility.