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Faculty Use of Student Data in Research Policy Procedures

If GS student data is used as a basis for scholarship or research, the following conditions must be met:

  1. Anyone conducting research using information from student education records must receive approval for that research from the GS Institutional Review Board prior to collecting new data or accessing pre-existing data or previously collected materials.
  • IRB approval will be on a case-by-case basis. If an interpretation of the ability to access the requested data is required, the GS Registrar has final authority over FERPA protected data use. The IRB cannot override a final decision by the Registrar.
  • In addition, GS researchers who are utilizing student data in their research must agree to:
    • Use the information only for purposes of the specifically IRB approved research project. Any new use of the information outside the scope of the approved project requires a new IRB approval.
    • Provide adequate protection for the information to ensure that it is not compromised or subject to unauthorized access.
    • Create a separate research dataset and fully de-identify the student data at the earliest possible point in the study and utilize aggregated data where possible. Researchers using data for which they are not the instructor of record must obtain that research dataset in aggregated format and/or without identifiers or with documented student consent.
    • Ensure that no one outside of the approved research team has access to the information.
    • Agree not to share any named data with any person outside of the GS research team approved on the IRB approval. Collaborators from other institutions may only ever have access to the de-identified data unless specified in a prospectively collected informed consent from each subject releasing the named data for research purposes.
    • Faculty researchers are required to retain all signed consent/authorization forms and be able to produce them upon request by authorized authorities. Records should include, but not be limited to, collected informed consent, authorizations, copyright releases and syllabus notifications of future de-identified data use potential. Consent forms must be retained for the life of the data. If data is submitted to a data archive, consent forms should be included in the archive service files with the data.
    • The possibility/probability for becoming a potential research participant must be provided to students at the start of class as of the issue date of this policy for any course where named student data may be utilized in future research. This can be done as part of the syllabus.
      • Students must be provided with clear instructions on how to opt out of inclusion of their data in any unnamed data set use.
      • Pre-notification does not remove the need for informed consent for prospective research uses where named data may be accessed for any part of the study past creation of the de-identified original dataset.
      • Students must be informed that consent is voluntary and participation (or lack of) will not affect grades, academic standing, etc.
  • Faculty may use their own current, consenting students in human subject research only under the following conditions:
    • No alternative method of data collection is feasible. PI must provide a compelling reason in the IRB application stating why they need to use their own students for research over any other option.
    • Students are considered a vulnerable population due to the power dynamic in the classroom. As such the minimum level of review will be Expedited unless the IRB determines that the study qualifies under an Exempt category.
  • Faculty should explain the purpose of the research, what materials will be collected and how the materials will be used in the informed consent document provided to the students (and preferably additionally in the syllabus).
    • Where possible, student data should be collected anonymously. If named data is required, the instructor must take appropriate precautions to eliminate the potential for unintended coercion. (E.g., blind collection of informed consent and data held for analysis until after final grades are turned in. See the IRB website for guidance.)
    • Students must be informed that consent is voluntary and participation (or lack of) will not affect grades, academic standing, etc.
  • Faculty using created class materials from current students for research purposes (in addition to the above):
    • Journals and other similar materials (both electronic and paper-based) are the property of student(s) and should not be used or collected for research without express written permission retained by the researcher.
    • Appropriate credit (e.g., authorship) should be given when possible or when applicable, unless confidentiality/privacy needs to be protected.

footnotes and references:

1. Dear Colleague Letter about Family Educational Rights and Privacy Act (FERPA) Final Regulations — Printable. US Dept. of Education, 17 Dec. 2008. (Last access 13 Apr. 2018).


Faculty Use of Student Data in Research Policy

Last updated: 6/19/2020