FERPA and Human Subjects Research at the University of Tennessee, Knoxville
The Family Educational Rights and Privacy Act (FERPA) is a Federal law designed to protect the privacy of student education records. It regulates the disclosure of personally identifiable information from student education records and applies to all educational institutions that receive funds under programs administered by the U.S. Department of Education. Such institutions can be public or private elementary, intermediate, high school, or college institutions. This guidance document focuses on FERPA as it applies to conducting research with student data at the University of Tennessee, Knoxville. See our other guidance document “FERPA and Human Subjects Research in Elementary, Intermediate, and High School Institutions” for information on FERPA in those settings.
FERPA gives university students certain rights with respect to their education records, including the right to review those education records and the right to request an amendment in the education records. Generally, schools must have written consent from the student in order to disclose personally identifiable information from education records, unless an exception applies.
Student Directory Information can be shared without student written consent, UNLESS the student has invoked the FERPA right to limit disclosure. At the University of Tennessee, Knoxville, this means that they have a submitted a Request for Directory Exclusion Form to the Registrar. If you have questions about whether a student has invoked the FERPA right to limit disclosure of Directory Information, please contact the Registrar’s Office to ask.
The information below is considered by the University of Tennessee, Knoxville to be Directory Information. This information can be used for research purposes without obtaining written consent from students:
- Graduate or Undergraduate Level
- Semester (local) Address
- Full-time or Part-time Status
- Permanent Address
- Most Recent Previous Educational Institution Attended
- Email Address
- Dates of Attendance
- Telephone Number (if published in directory)
- Degrees, Honors, and Awards
- Participation in School Activities and Sports (and photographs of such)
- Weight and Height of Students Participating in Intercollegiate Athletics
The information below is FERPA-protected and cannot be used for research purposes without obtaining student consent. This list is not exhaustive, and any education records that are not considered Directory Information are FERPA-protected.
- Social Security Number
- Student ID Number
- GPA (term or cumulative)
- Notes From a Conversation with a Student
- Emails Containing Information About a Student
- Online Discussion Forums (e.g., Canvas)
- Student Schedule
- Academic History
- Academic Standing
- Graded Papers
- Class Rosters
- Recordings of Class Discussions (audio and video)
Frequently Asked Questions
- When the data is being used by a University official with legitimate educational interests; and
- When the data is being used by an organization conducting institutional services or functions on behalf of the University.
Examples of working with FERPA-protected data at the University of Tennessee, Knoxville:
A professor wants to conduct research on how first-year college students are adjusting to the transition to college. She asks instructors of First-Year Studies courses to give her the email addresses of their students so that she can send them a recruitment flyer about the study.
This recruitment method would require the course instructors to violate FERPA because course rosters are FERPA-protected and cannot be released for research purposes without student consent. An alternative option would be for the professor to ask instructors of First-Year Studies courses to share a recruitment flyer with their students on her behalf.
A graduate student wants to conduct research on how student grades differ for classes that are taught online versus in-person. A faculty member in her department (who is not affiliated with the research) is teaching two sections of an English Course – one is online, and one is in person. The graduate student asks the faculty member to share de-identified exam scores for each course so that she can compare them to each other. No direct or indirect identifiers will be included in the data that is shared and there is no code key that would allow for re-identification of students.
This study does not violate FERPA regulations. Although student grades are being shared for research purposes, they are not being shared in an identifiable manner.
If student demographic data was being shared along with the grades, there is the possibility that the data may become identifiable. For example, if student gender and race were shared and there was only one black female student in the online course, that individual student’s grades would be able to be identified even though her name wasn’t shared. In this case, written consent from the students would be required for this research.
A faculty member wants to conduct research on whether student anxiety about math is related to their exam scores in his Economics course. Students who participate in the study will be asked to complete a survey that assesses their anxiety about math, and this will be correlated to their exam scores throughout the semester.
Although the faculty member has access to student exam scores for teaching purposes, he must obtain written consent from the students to use them for research purposes. This research does not violate FERPA as long as students give written consent for their exam scores to be used for the research.