Information that constitutes “directory information”, as designed by the university here, may be accessed for research purposes without consent.

For UW-Madison educational records: Under limited circumstances, a DUA may be obtained in lieu of consent. A determination must be made by the Registrar’s Office that the research is being conducted for or on behalf of the institution in order to develop, validate, or administer predictive tests; administer student aid programs; or improve instruction. If this determination is made, the Registrar’s Office will enter into a DUA with the researcher.

For UHS records:

  • When not obtaining consent of the students, someone in UHS administration, acting as a school official, can de-identify the records and release the records to the study team without the consent that would otherwise be required by FERPA to conduct this research provided that the UHS administrator makes “a reasonable determination that a student’s identity is not personally identifiable, whether through single or multiple releases, and taking into account other reasonably available information.”
  • UHS records can be accessed by researchers without consent under an exception for school officials, including faculty, within the institution that have a “legitimate educational interest.” However, it only applies to clinician/researchers conducting clinical research. This is because as part of their job duties, clinician/researchers who conduct clinical research have a “legitimate educational interest” in research using medical records. At present, this would be applicable to those individuals with appointments within UHS or health sciences schools (SMPH, SoN or SoP), if the latter group were given access to the record from UHS, when the research is designed to assess or improve the quality of care provided to students by the university, and/or to understand and address health problems or conditions that may affect their academic performance or retention.
    • This would NOT apply to the faculty/professors who conduct more typical educational research (e.g., those in Education, Business, etc.). Those research projects would still need to fall under the exception for research designed develop, validate, administer predictive tests; to improve instruction; or to administer student aid programs.