Access to Education Records for Research Purposes
The University of Iowa (UI) Office of the Registrar FERPA Team and Human Subjects Office collaborate to respond to research requests seeking the use of or access to student academic data. Investigators are required to comply with FERPA, human subject protection regulations (IRB requirements), and UI policy when accessing education records.
The FERPA Team will provide an approval/agreement memo to researchers to submit in tandem with the IRB application if the research proposal is FERPA compliant.
Obtaining Consent to Access Records for Research Purposes
Researchers have met FERPA requirements when they supply a consent form, and a student signs it thereby agreeing to participate in the research study and to release their education records for research purposes.
FERPA regulations specify that a student must provide signed and dated written consent in accordance with § 99.30 before personally identifiable information from education records can be disclosed unless the disclosure falls within the exceptions set forth in § 99.31.
FERPA's consent provisions require specification of 1) the records that may be disclosed; 2) the purpose of the disclosure; and 3) the identity of the party or class of parties to whom the records may be disclosed.
Access to Records for Research Purposes Without Obtaining Consent
FERPA allows educational agencies or institutions to disclose personally identifiable information from a student’s education record without consent if the receiving organizations are conducting studies for, or on behalf of, educational agencies or institutions to:
- develop, validate, or administer predictive tests.
- administer student aid programs.
- improve instruction [34 CFR § 99.31].
Education records may be released for research without consent under FERPA if all personally identifiable information has been removed including:
- student name and/or other direct personal identifiers such as university ID number, Hawk ID, Name
- indirect identifiers, such as parent or family member names, addresses, personal characteristics and/or other information that could allow the student’s identity to be traceable, date and place of birth, and mother’s maiden name.
- biometric records, including one or more measurable biological or behavioral characteristics that could be used for automated recognition of an individual, including physical image, voice, facial characteristics, and handwriting.
- other information, alone or in combination, that is linked or linkable to a specific student and could allow a reasonable person in the campus community who does not have personal knowledge of the relevant circumstances to identify the student with reasonable certainty.
Examples of working with FERPA-protected data at the University of Iowa:
A professor wants to conduct research on how first-year college students feel about campus safety. The researcher asks First-Year Seminar course instructors for a list of student email addresses to use to disseminate recruitment flyers explaining the study and soliciting participation.