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HRPP Policy - Use of Education records
About This Policy
- Effective date:
- Last updated:
- Policy Contact:
IU Human Subjects Office
This policy applies to the conduct of human subjects research involving student education records under the jurisdiction of the IU Human Research Protection Program (HRPP). This includes research under the oversight of the IU IRBs and research for which IU or its affiliates are relying on an external IRB for oversight.
This policy does not apply to directory information.Back to top
Student education records may be used for research purposes only when one of the following is true:
- The records do not include personally identifiable information
- The institution whose student education records will be used determines that the records will be used by school officials with legitimate educational interest.
- The student (or the student's parent or guardian, when appropriate) provides written permission. Written permission must include all of the following:
- Description of the records to be disclosed
- Purpose of the disclosure
- Party or class of parties to whom the disclosure may be made
The study team describes the use of student education records in the human subjects application and provides the following, if applicable:
- Documentation that the institution has determined that the records will be used by school officials with legitimate educational interest, except for use of IU student education records under section 3.2 below
- If the researcher is obtaining written permission from students (or the students' parent or guardian, when appropriate) to access student education records, the document used to secure such permission
The reviewer ensures that all requirements consistent with this policy are met.
IU researchers may be considered school officials with legitimate educational interests and may use student education records of IU students for research purposes without written permission if all of the following are true:
- The research is designed to study the effectiveness of an instructional technique or method
- The researcher will access identifiable information only from students in their own courses
- The researcher will present only aggregate data in publications and presentations
Individuals found to be in violation of this policy may be subject to sanctions relating to their participation in research with human subjects, up to and including permanent suspension or debarment from engaging in research with human subjects at Indiana University.Back to top
IU HRPP Policies
Related Policy Documents
IU HRPP Guidance
Related Guidance Documents
directory information For education records, includes, but is not limited to, the student's name; address; telephone listing; electronic mail address; photograph; date and place of birth; major field of study; grade level; enrollment status (e.g., undergraduate or graduate, full-time or part-time); dates of attendance; participation in officially recognized activities and sports; weight and height of members of athletic teams; degrees, honors, and awards received; and the most recent educational agency or institution attended.
parent A child's biological or adoptive parent.
research A systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge (Synonymous with clinical investigation For research subject to FDA regulations, any experiment that involves a test article and one or more human subjects, and that either must meet the requirements for prior submission to the FDA under §505(i), §507(d), or §520(g) of the Food, Drug & Cosmetic Act, or need not meet the requirements for prior submission to the FDA under these sections of the act, but the results of which are intended to be later submitted to, or held for inspection by, the FDA as part of an application for a research or marketing permit. The term does not include experiments that must meet the provisions of part 58 regarding nonclinical laboratory studies (21 CFR 50.3(c)).) The following activities are deemed not to be research under this definition: Scholarly and journalistic activities (e.g., oral history, journalism, biography, literary criticism, legal research, and historical scholarship), including the collection and use of information that focus directly on the individuals about whom the information is collected; Public health surveillance activities, including the collection and testing of information or biospecimens, conducted, supported, requested, ordered, required, or authorized by a public health authority. Such activities are limited to those necessary to allow a public health authority to identify, monitor, assess, or investigate potential public health signals, onsets of disease outbreaks, or conditions of public health importance (including trends, signals, risk factors, patterns in diseases, or increases in injuries from using consumer products). Such activities include those associated with providing timely situational awareness and priority setting during the course of an event or crisis that threatens public health (including natural or man-made disasters); Collection and analysis of information, biospecimens, or records by or for a criminal justice agency for the activities authorized by law or court order solely for criminal justice or criminal investigative purposes; Authorized operational activities (as determined by each agency) in support of intelligence, homeland security, defense, or other national security missions.
student education records Under FERPA, those records that are directly related to a student; and maintained by an educational agency or institution or by a party acting for the agency or institution. The term does not include: Records that are kept in the sole possession of the maker, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record; Records of the law enforcement unit of an educational agency or institution, subject to the provisions of §99.8; Records relating to an individual who is employed by an educational agency or institution, that 1) Are made and maintained in the normal course of business; 2) Relate exclusively to the individual in that individual's capacity as an employee, and; 3) Are not available for use for any other purpose; Records relating to an individual in attendance at the agency or institution who is employed as a result of his or her status as a student are education records and not excepted under paragraph (b)(3)(i) of this definition; Records on a student who is 18 years of age or older, or is attending an institution of postsecondary education, that are 1) Made or maintained by a physician, psychiatrist, psychologist, or other recognized professional or paraprofessional acting in his or her professional capacity or assisting in a paraprofessional capacity; 2) Made, maintained, or used only in connection with treatment of the student, and; 3) Disclosed only to individuals providing the treatment. For the purpose of this definition, "treatment" does not include remedial educational activities or activities that are part of the program of instruction at the agency or institution; Records created or received by an educational agency or institution after an individual is no longer a student in attendance and that are not directly related to the individual's attendance as a student; Grades on peer-graded papers before they are collected and recorded by a teacher.Back to top