Research involving students or student education records requires compliance with both FERPA and human subjects research regulations.  Before using student records, recruiting students, or accessing coursework and grades for research purposes, keep the following principles in mind:

  • Education records(Rosters, coursework, grades, and assignments)  are protected by FERPA.
  • IRB approval does not replace FERPA requirements.
  • Written student consent should be obtained before accessing FERPA-covered educational records for research. The use of opt-out consent should be avoided.
  • Researchers should avoid accessing identifiable data from their own students until final grades have been submitted.
  • Extra credit opportunities must include an equivalent non-research alternative for those who do not wish to participate in research studies.
  • Educational records may be used in research only when applicable FERPA and IRB requirements are met.
  • When questions arise regarding access to student records, researchers should consult the IRB and the Registrar's Office before proceeding.

The IRB also strongly discourages the use of a researcher's own students as research participants unless there is a compelling scientific justification and appropriate safeguards are implemented to minimize coercion and undue influence. Researchers must minimize the possibility of coercion/undue influence.

 

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  • Researchers who wish to use student education records must comply with both the Family Educational Rights and Privacy Act (FERPA) and applicable human subjects research regulations. IRB approval does not replace FERPA requirements, and researchers may not access student education records for research purposes unless an appropriate FERPA authorization or exception applies.

    Student records maintained by faculty members, departments, and the university—including coursework, grades, and academic records—may be considered education records under FERPA. Researchers are responsible for ensuring that access, use, disclosure, storage, and destruction of these records comply with university policy and federal regulations.

    What Are Education Records?

    Education records are records directly related to a student and maintained by the university or its agents. Examples include:

    • Grades and graded coursework
    • Exams, assignments, essays, and projects
    • Academic transcripts
    • Class rosters and student schedules
    • Advising records
    • Class observations and online course discussions
    • Financial aid and scholarship information
    • Student conduct records
    • Demographic and family information
    • Student identification numbers and academic communications

    Because these records are protected by FERPA, researchers cannot assume they have access to them simply because they are instructors, advisors, or university employees.

    Using Education Records for Research

    Instructors, advisors, or university employees may have access to these records due to their role(s). However, they must not assume that access allows for the use of records for research, as the records are protected by FERPA regulations. In most cases, FERPA requires written student consent before education records may be used in research unless a specific FERPA exception applies.

    Researchers must comply with both:

    • FERPA requirements governing student records; and
    • Human subjects research regulations and IRB requirements.

    If the university determines that access to an education record is not permitted under FERPA, the IRB cannot authorize access to those records.

  • Coursework submitted for academic evaluation (including essays, assignments, examinations, projects, journals, and discussion posts) remains an education record under FERPA.

    Researchers wishing to use coursework or grades for research purposes should:

    • Obtain IRB approval before conducting the research;
    • Obtain appropriate student consent unless a FERPA exception applies;
    • Minimize identifiable information whenever possible; and
    • Protect confidentiality and data security.

    Because instructors have authority over students' academic outcomes, additional safeguards are necessary. Researchers generally should not review identifiable research data from their own students until after grades have been finalized.

    Researchers should:

    • Use a third party to obtain consent and collect data when possible;
    • Delay access to identifiable data until final grades have been submitted;
    • Ensure participation has no impact on grading decisions; and
    • Clearly communicate that participation is voluntary.

    Students Under Age 18

    Although most college students are adults, some enrolled students may be minors. When research involves participants who have not reached the legal age of consent, investigators should consult the IRB regarding requirements for:

    • Parental permission
    • Participant assent
    • FERPA considerations
    • Applicable state law

  • 1. Written Student Consent

    The most common method for obtaining education records for research is through written student authorization. Researchers should ensure that FERPA authorization language is included in the IRB-approved consent process whenever education records will be accessed.

    A consent or authorization form must include:

    • The purpose of the disclosure;
    • The specific records to be disclosed;
    • Who will receive the records;
    • The frequency or duration of disclosure, if applicable; and
    • The student's signature and date.

    2. Directory Information

    FERPA permits institutions to designate certain information as "directory information," which may be disclosed without written consent unless the student has opted out.  Researchers seeking directory information must follow university policies and procedures governing access to such information.

    The specific categories of directory information are determined by each institution and may include:

    • Name
    • Address
    • Major field of study
    • Dates of attendance
    • Degrees and honors received

    3. De-Identified Information

    Education records may be used for research if all identifying information is removed prior to release to the investigator. Research using fully de-identified information may not constitute human subjects research under federal regulations. (Faculty are not allow to de-identify their own student records)

    De-identified information:

    • Does not contain direct identifiers
    • Cannot reasonably be linked to individual students
    • May include coded data when the coding key is not available to the researcher

    4. Research Conducted on Behalf of the University (Studies Exception)

    FERPA permits disclosure of personally identifiable education records without student consent when research is conducted for or on behalf of the university for specific educational purposes, including:

    • Improving instruction
    • Developing or validating assessments
    • Administering student aid programs
    • Improving educational programs

    A written agreement is required and must address:

    • The purpose, scope, and duration of the research
    • The information being disclosed
    • Restrictions on use and re-disclosure
    • Authorized personnel with access to identifiable information
    • Data security requirements
    • Procedures for data destruction or return
    • The timeline for destruction or return of records

    When records will be obtained from another educational institution, documentation authorizing release of the records (such as a letter from the Registrar, Superintendent, or other authorized official) should accompany the IRB submission.

  • Research involving students requires special consideration because of the potential power imbalance between students and instructors.

    Minimizing Coercion and Undue Influence

    Students must feel free to decline participation without fear if negative academic consequences.

    Researchers should:

    • Clearly state that participation is voluntary.
    • Explain that grades, standing, recommendations, and relationships with faculty will not be affected by participation decisions.
    • Avoid recruiting students directly when possible.
    • Consider using a third party to manage recruitment and consent.
    • When incentives such as extra credit are offered to those who participate in a research study, equivalent alternatives must be offered to those who do not wish to participate.

    Extra Credit

    Extra credit may be offered as a recruitment incentive if:

    • The amount is reasonable
    • Participation is voluntary
    • An equivalent non-research alternative is available
    • Students may earn the same credit regardless of participation choice

    Sensitive Topics

    Studies involving topics such as mental health, trauma, substance use, personal experiences, or other sensitive issues should:

    • Clearly describe study procedures during consent
    • Explain confidentiality protections
    • Provide participants with appropriate support resources
    • Include safeguards to protect privacy and well-being