Ask the FERPA Professor

November 15, 2016
  • AACRAO Connect
  • FERPA
Illustrated figure resembling Einstein standing next to a chalk board with the word "FERPA" written on it.

Dear FERPA Professor,

Two of our faculty are doing a paper which studies the correlation between Art Majors and ethnicity/family income.

No student names are provided.  Demographic information only.

We are a very small campus.  There is one student on the report I have generated for them that lists: "Art Major = Ethnicity = 2 or more races and Family Income = $60,000+."

Is disclosing this information too revealing to present in a meeting?  My concern is that many in attendance will know who this student is based on major and ethnicity.

Please let me know your thoughts.

Sincerely,

Ann Sient

_____________________________________________________________

Dear Ann,

Generally, disclosing information from education records in a de-identified format is not a problem.  If, however, someone could identify the student, then any disclosure must be limited to those permitted by the exceptions to signed consent found in §99.31 of the FERPA regulations.  Even giving the two professors access to the education records with personally identifiable information would generally require that the study was being done on behalf of the College and that a written agreement, as required by §99.31(a)(7), was in place. 

I hope this is helpful in answering your questions.

Sincerely,

The FERPA Professor

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