FERPA for Faculty and Teaching Assistants

Posting Grades

The paper or electronic posting of grades either by the student's name or institutional student identification number, without the student's written permission, is a violation of FERPA. Even with names obscured, numeric student identifiers are considered PII and therefore violate FERPA.

Options to communicate grades include posting in Canvas, having students sign (optional) waivers, or using unique identifiers. If using unique identifiers, the posting must not be alphabetic.

Returning Assignments

Leaving personally identifiable, graded papers unattended for students to view is no different from posting grades in the hallway. If these papers contain "personally identifiable" information, then leaving them unattended for anyone to see is a violation of FERPA if the instructor has not obtained the written permission of each student to do so. A possible solution would be either to leave the graded papers (exams, quizzes, and homework) with an assistant or secretary who would ask students for proper identification prior to distributing them or to leave them in a sealed envelope with only the student's name on it.

Canvas and Online Course Applications and Recordings

Online environments create records of student activity, contain grades, and show a student's course enrollment. Therefore, access to information in the course should be protected and granted by appropriate means. Recordings of courses that include PII are also protected by FERPA. Common PII in recordings include names, images, and voices. Any one of those elements could lead to someone's identity being inferred. If you have a recording with PII, do not post it publicly. It should only be accessible to those enrolled in the course or with appropriate course access.

If you wish to use a recording in the future, either to post publicly or show a future class, do not capture students' identities (includes image/voice). If you already have a recording with PII, you should never share it with students who were not enrolled in the same course/section that term unless the PII has been edited out.

Sending Grades to Students

Instructors can notify students of their final grades via the U.S. Mail if the information is enclosed in an envelope. Notification of grades via a postcard violates a student's privacy. Notification of grades via email is permissible. However, there is no guarantee of confidentiality.

Access to Student Records

Faculty members and TAs are normally considered "school officials." But, the faculty member/TA will have to demonstrate "a legitimate educational interest" in their request to access student records, e.g. advising students, retention study, etc. However, faculty & TAs do not have access to student academic records unless their normal job duties specifically require access. This does not cover letters of recommendation. The process utilizing a student's academic records for letters of recommendation is noted below.

Faculty members and advisors, who have access to the student's transcript, may not release it to the student. The student would need to print their own in REGIS or contact the registrar's office for their options regarding releases or picking one up from the registrar's office in person.

Letters of Recommendation and FERPA

Writing a letter of recommendation may require express written permission from the student to allow you to, 1) access the student's educational records (transcript) and, 2) disclose confidential information about the student to a third party.

Written permission of the student is required for a letter of recommendation if any information included in the recommendation is part of the "education record" (grades, GPA and other non-directory information).

If a student asks you to write a letter of recommendation, and you would like to utilize their academic information, ask them to contact the Office of the Registrar to discuss granting access. Students may also download and share their transcript with faculty at their own discretion.

Parents Requesting Information

Such things as progress in a course, deficiencies in a subject area, scores and grades on papers, exams, etc. are all examples of personally identifiable information that make up part of the student's education record. This information is protected under FERPA and the parents may not have access unless the student has provided written authorization that specifically identifies what information may be released to the parent(s).

Crisis Situations/Emergencies

If non-directory information is needed to resolve a crisis or emergency situation, an education institution may release that information if the institution determines that the information is "necessary to protect the health or safety of the student or other individuals." Factors considered in making this assessment are: the severity of the threat to the health or safety of those involved; the need for the information; the time required to deal with the emergency; and the ability of the parties to whom the information is to be given to deal with the emergency.

Comments/Questions

Please contact the Office of the Registrar with general questions, comments or suggestions.