The researcher must specify the exact fields that will be requested/obtained from academic records. This includes indicating the number of data pulls that are being requested (one time, each semester, for the participant’s entire time at UW-Madison) and detailing how data will be obtained (from Registrar’s Office, from departmental administrator, etc.).

De-identified student records may not require consent, but de-identification requires more than just removing names or ID numbers. De-identification to FERPA standards requires that all direct and indirect identifiers that could be used in combination to identify an individual be removed; for example, demographic information that creates small cells of individuals must be removed from a data set.

Consent is required for access to identifiable student records for research purposes, with limited exceptions. It is the researcher’s responsibility to obtain consent that is IRB approved and FERPA compliant. If the consent language and consent process do not meet the requirements of FERPA, FERPA-protected data from the student record generally cannot be released to researchers. Researchers are strongly encouraged to consult with the Office of the Registrar (for UW-Madison) or staff with a similar role (for K-12 districts/schools) early in the planning of studies that will include a request for information from the FERPA-protected student record.

In order to address FERPA, electronic consent must not only include a statement of the records to be disclosed, for what purpose, and to whom, but must also include a process to 1) identify and authenticate the person providing consent; and 2) indicate this person’s approval of the information contained in the electronic consent.