FERPA and educational technology
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REVISION IN PROGRESS: This article contains useful information, but is being revised to reflect recent updates. Direct questions to TLT (tlt@winona.edu). |
Potential pitfalls
Emailing and texting grade information
Although emailing student grades is permissible under FERPA, the Department of Education will hold Winona State University responsible for any unauthorized access to this communication. Unless you take specific precautions, your email and text messaging conversations with students are not secure. Private and confidential information can be intercepted and you might send the message to the wrong address.
Sharing coded grade sheets online
Although it's easy to post a coded grade sheet (e.g., in an Excel spreadsheet or Word document) that does not identify students by name to your Brightspace course, a student's identity might be uncovered. StarID usernames and Winona State University Tech ID numbers are not private information and email messages that include students' secret codes can be intercepted.
Discussing grades in Zoom
When discussing grades or student progress in a Zoom meeting, someone else might join and see what you are screen sharing, read what was posted to the Chat tool, or overhear what you are saying. Recordings of these meetings might also be opened and copied.
Discussing grades on the phone
You may not know your students by voice and may be talking to the wrong person.
Confidentiality requests
Although sharing common student information (e.g., mailing address, email address, major) might seem safe, some may have submitted a confidentiality request to Winona State University that extends to this type of information.
Group projects
When providing individual grades to students working on collaborative or group projects, there is a risk of revealing that information to the rest of the group.
- Disclosing grades or other FERPA-protected information over the phone
Solutions
- Define directory, private, and confidential information. Make sure you understand what student information is considered directory information and private information.
- Identify students who request confidentiality. Even common directory information about a student cannot be shared if that student has requested confidentiality.
- Use your Brightspace grade book to provide students with online access to their grades. Brightspace grade books are already created for every class section. Just add your grade book columns and enter your grades as you would in an Excel spreadsheet. Your students select Grades from the Assessment menu in your Brightspace course to review them.
- Use email messages to share grade, DARS reports, or grade lists only when absolutely necessary. Always encrypt such email messages and ensure that you are sending the message to the right person.
- Never share grades with students in text messages.
- Posting a document online with grades listed for all students, even if the list does not identify the students by name
- Engaging in an online conversation with anyone about a student's progress without that student's consent
- Storing a recording of a student (e.g., in a Zoom meeting) in an unprotected, online location
- Sharing common directory information (e.g., mailing address, email address, major) online for a student who has requested confidentiality.
- Disclosing confidential information about a student to a third party without authorization
- Including personally identifiable information about a student in another student's record without the first student's permission
- Disclosing grades or other FERPA-protected information over the phone
- Disclosing grades or other FERPA-protected information over the phone without ensuring that the person with whom you are speaking to is your student.
- Never mail grades to students UNLESS consent is received and a self-addressed envelope (no post cards) is supplied by the student.
- Never post the grades, even if coded, in alphabetical order or any other recognizable order. Use D2L or another online learning tool to retain grade history so only the authenticated student themselves can access them.
- Post grades and academic progress in an approved learning management application like D2L. TLT has said they would love to assist any faculty member looking for help using the gradebook!
- Zoom saves the recording to its own cloud servers. When you log into your Zoom host web portal and https://minnstate.zoom.us and select Recordings in the left, you will see all of them. They are stored there for a year. Once the save to Zoom finishes, it triggers the automatic copy to your MediaSpace account. The MediaSpace copy is saved forever and can be manipulated/edited by you. It can also be close captioned. To share the video, please see TLT for training on Teams or another sharing platform that restricts access to only those who should see it.
- Learn how to send Encrypted Email in Outlook. This helps protect email content from being accessed inappropriately or forwarded without approval. This is appropriate to use when sending any private data that can’t be shared more securely through the D2L Gradebook or other secure online portal. Examples include attaching graded papers back to students (that can still be done more easily and securely directly in D2L) Contact TLT for assistance with using encrypted email or the D2L Dropbox and grading tools. They can walk you through the procedure or feel free to use the wiki links below.
- If you are communicating via email, instant messaging/online chatting or speaking over the phone please verify their identities. Ask questions about your course content or other identifiable information that only the student and you would both know. Consider using video (Teams or Zoom) to verify the student is who they say they are and not a parent, sibling or other family member. You may also request to see a photo ID held up to their camera which is especially important during remotely advising and you don’t yet know them!
- Contact TLT, WSU’s CISO, the Registrar’s Office or Legal Affairs if you have questions about FERPA and appropriate data handling. We are all standing by and willing to assist.
Ask questions
Contact Lori Mikl (Legal Affairs), Tobias Schmidt (ITS), Tania Schmidt (Registrar's Office), Jami Kovisto (Registrar's Office), or Ken Graetz (TLT)