IRB – Research with Human Participants: Use of Student Education Records for Research Under FERPA Requirements
The Federal Family Educational Rights and Privacy Act affords certain rights to students and parents of minor students, including the right to privacy with respect to disclosure of their education records. Only directory information can be released without student consent.
Protected Records
Education record information protected under FERPA includes but is not limited to:
- University ID number, Social Security number, date of birth
- Race/ethnicity, country of citizenship
- All graded material
- GPA
- Transcripts
- Class rosters
- Class schedules
Acceptable Use
FERPA-protected records may be used for research purposes under one of three conditions:
A. The student provides written permission
When a researcher wishes to access identifiable education records solely for research purposes, FERPA consent is required. The researcher must document the FERPA consent by having the student sign and date a one-time FERPA release. This requires institutional review board (IRB) approval.
Written permission must include:
- Description of the records to be disclosed
- Purpose of the disclosure
- Party or class of parties to whom the disclosure may be made
- Time period or event to which the permission pertains
- Signature of the student and date
B. There is a legitimate educational interest
The institution whose education records will be used must determine that the records will be used by school officials with legitimate educational interest.
Faculty are not automatically entitled to access all information about their students. Faculty have a legitimate educational interest in information only if that information is relevant and necessary for them to fulfill their role in the student's education. Researchers may be considered school officials with a legitimate educational interest when the research is necessary for the school official to fulfill their professional responsibilities. Such research may include studies designed to evaluate the effectiveness of instructional techniques, curricula or classroom management methods. If faculty are undertaking this research (as opposed to an institutional effectiveness unit), IRB approval is required.
C. The researcher receives de-identified data
If the researcher receives records that do not include personally identifiable information, the records may be used for research purposes. Faculty researchers can receive de-identified data from a school official, usually the registrar's office. This requires approval from the IRB and the registrar's office. Faculty researchers who are also teachers are prohibited from de-identifying their own students' records or those of their colleagues for research purposes.
To inquire if a proposed use of student data is feasible under the guidance of FERPA, submit the IRB Data Request Feasibility Form. If the IRB determines that your proposed project is feasible, you will then submit a separate IRB data request form to obtain the data itself.