Use of Student Records in Research is Protected

Federal law, the Family Education Rights and Privacy Act (FERPA), protects the privacy of student educational records which generally includes information maintained by Keuka College that identifies a student. Students should be aware of their rights under FERPA and faculty and staff should be aware of and follow their obligations under FERPA. The following resources are intended to help students, faculty, and staff understand FERPA and how to best protect the privacy of students in general.

FERPA Policy:

FERPA (Family Educational Rights and Privacy Act of 1974) is federal legislation in the United States that protects the privacy of students' personally identifiable information (PII). The act applies to all educational institutions that receive federal funds. See the link below for further information:

DOE link - https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html?src=rn

Appropriate Use of Keuka College Data:

• Refer to Keuka College's FERPA policy on the college's website (external link)

Student Educational Records Include:

• Graded papers

• Exams

• Transcripts

• Class rosters

• Notes from a conversation with a student

• Computer screens displaying student information

• Emails containing information about a student

We recommend the following website for more detailed information about FERPA and research with student records:

https://research.iu.edu/compliance/human-subjects/guidance/ferpa.html

Brief information about why this site is so useful.

Things to consider when using data from student educational records:

If you want to include student record information in your research, you will need to consider these following questions:

1. What information do you want to include?

Directory info OK, grades and other information covered by FERPA (see link below)

2. Does the information need to be tied to a specific student or could it be anonymous?

You may not need specific consent if information can be de-identified

3. Do you need specific consent?

If under 18 need parental consent,may not be released to third parties without written consent from the student unless disclosure is permitted through one of the FERPA signed consent exceptions

4. What student record protections will you need to provide?

Approval to use student record data in your research is contingent on your agreement that you will:

1. Use the information only for purposes of your approved research project. Any new use of the information requires new approval.

2. Provide adequate protection for the information to ensure that it is not compromised or subject to unauthorized access.

3. Ensure that no one outside the research team has access to the information.

De-identified student records may not require consent, but de-identification requires more than just removing names or ID numbers. De-identification to FERPA standards requires that all direct and indirect identifiers that could be used in combination to identify an individual be removed; for example, demographic information that creates small cells of individuals (e.g. less than 10) must be removed from a data set lest someone be identified by category.

For information about what is covered and what is not under FERPA, see link below:

Other Reference sites:

https://kb.wisc.edu/sbsedirbs/42988

Eliminating Unnecessary Data:

• Identify Finder Software

• Shredding Paper Records

• Disposing of Computers

• Records Clean Up