Approval to use student educational record data in your research is contingent on your agreement to:
- Use the information only for purposes of your 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 only members of the research team who have a legitimate educational interest access student records without signed permission from the parent or eligible student.
- Ensure that no one outside of the research team members who are specifically listed on the protocol 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 working with FERPA-protected data at IU:
Professor Mathwin and her graduate student assistant Elayne wish to conduct a study that will involve recruiting students who are enrolled in SPEA courses and interview them about their opinions about campus safety. They plan to ask the instructors of various classes to provide them with class rosters so that they can email the students to recruit them for the study.
This recruitment strategy would require the course instructors to violate FERPA regulations. Class rosters and student schedules are student records information and should not be shared with third parties. The researchers in this case are not studying the effectiveness of instructional techniques, curricula, or classroom management, and thus are not eligible to review student records for this research. They 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.
At IU, this would be permissible so long as both researchers are IU affiliates. If one of the two researchers were not an IU affiliate, then a signed release from students would be required in order for the student record data to be accessed by that person.
Noal, a graduate student in anthropology, wants to research the correlation between Pell grant eligibility and the GPA of math majors. To do this, he plans to request a copy of the names of all math 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.
Noal does not have a legitimate educational interest as part of his professional duties at IU to access this data because he does not teach the courses in question and has no responsibility for their conduct or effectiveness.