Dear FERPA Professor,
I have a question/request concerning FERPA from one of my colleagues here in the math department. In a large lecture course, they would like to offer students the option of having their graded assignments available for pick-up unattended in a box in the hallway so that they can get their graded assignment at any time rather than only during office hours. The Math Dept. would be asking them to waive their privacy for these educational records.
The Math department would like the Registrar's Office to craft some brief text that they would or could include as a cover sheet on an assignment that the students could sign if they wish to signify their consent to releasing their grades in this way. We in the Registrar's office are thinking "no." We also put the question out to a list serve of registrars in North Carolina and they agreed with us.
Is the Math department's request something we should entertain?
Sincerely,
Mary Band
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Dear Mary,
Generally leaving graded tests that are personally identifiable to a student in an open area would be prohibited by FERPA if someone other than the student could gain access to them. One possibility, if your institution wanted to entertain permitting such a practice, would be to have the individual faculty member assign a random, non-sequential, number to each student in the class and have the student write that number on the work product. Otherwise, the signed consent conditions of §99.30 would have to be met prior to any such practice of disclosing student education records as described in your inquiry.
I hope this is helpful in responding to your inquiry.
The FERPA Professor
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