Dear FERPA Professor,
With a signed consent that specifically says “I consent to post class grades on the web,” can a professor post grades for an entire class on his faculty webpage, if student grades are identified by a random identifier instead of the social security number or the student identification number?
I am on the fence deciding if this is acceptable under FERPA. On the one hand, the grades can only be released with a signed consent from the student/holder of the record, and the faculty member obtained consent from each student and withheld posting grades until he obtained the signed consent. On the other hand, the web is open for all eyes, and I’m not sure that consent can cover posting grades on a public website. I am currently thinking that we can’t allow this, but wanted an expert opinion if you can spare it.
Thanks,
Bruce Peeking
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Hello Bruce,
Posting grades on the webpage without a secure login of some kind would not seem to be a good practice, nor one I would think a postsecondary institution would want to permit under any circumstances. Having said that, FERPA does not specifically prohibit such a practice. Rather, absent a signed consent or meeting one of the exceptions to signed consent, it prohibits the disclosure of student education records in a manner which would permit the student’s identity to be known. Posting grades on the web in the manner you described creates an unnecessary risk for the institution in that regard and one that is difficult, if not impossible, to undo if a mistake is made.
I hope this is helpful in answering your question,
The FERPA Professor
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