IRB Requirements for Using Tennessee Tech Student Data

Proposed projects using data from Tennessee Tech student records for research purposes must comply with Tennessee Tech IRB policies and Tennessee Tech Family Educational Rights and Family Act (FERPA) policies.  

Although Administrators, Faculty, and Staff have access to Tennessee Tech student records, the use of such data for research purposes requires IRB approval and authorization from the University FERPA Officer. 

Additionally, although administrators, faculty, and staff (e.g., professors, advisors, chairpersons, mentors, deans) have access to Tennessee Tech student records, they are not authorized to share such data for research purposes. Only the Tennessee Tech FERPA Officer, Brandi Fletcher, is authorized to release data from student records for research purposes.  

The procedures for proposed projects that will use data from Tennessee Tech student records are as follows:

1. Complete and submit an IRB application to a Certified Departmental Reviewer.
2. The Departmental Reviewer will recommend the application for Expedited Review. 
3. Once the IRB approves the application through an Expedited Review, the approval will be sent to the PI with the FERPA Officer copied to the email. Although the IRB can approve an application using student records, the data will only be released to the PI by the FERPA Officer. 

IRB approval does not require the FERPA Officer to provide the data to the PI or guarantee that the FERPA Officer will provide the requested data. Additionally, an IRB approval does not stipulate any timeframe for the FERPA Officer to provide the PI with the requested data. Therefore, IRB approval, alone, is insufficient for accessing student records for research purposes. 

FERPA policies and IRB policies are separate policies under federal law and at Tennessee Tech. Therefore, each are enforced and monitored independently. The IRB and the FERPA Officer will work together to assist PIs in their research. However, the IRB does not have any jurisdiction over FERPA, and the IRB supports the FERPA Officer's ultimate decision whether or not to provide data from student records to PIs.  

FERPA requires that students grant permission  to access their student records whenever possible. IRB requires that students provide informed consent whenever it is possible to do so. However, in some research studies, it is not possible or otherwise reasonable to get permission or informed consent from students. In these cases, a waiver of informed consent must be requested from IRB. The application must provide a strong justification for such waivers in order to be approved by the IRB. 

Per Tennessee Tech Policy 1206: Confidentiality of Student Records and FERPA Compliance, the following information is considered personally identifiable:  

"Personally Identifiable Information—information including, but not limited to:

1. The student's name; 
2. The name of the student's parent or other family members; 
3. The address of the student or student's family; 
4. A personal identifier, such as the student's social security number, student number, or biometric record; 
5. Other indirect identifiers, such as the student's date of birth, place of birth, and mother's maiden name; 
6. Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or 
7. Information requested by a person who Tennessee Tech reasonably believes knows the identity of the student to whom the education record relates."

For questions related to using Tennessee Tech student records for research purposes, please contact the IRB Chairperson, sseiler@tntech.edu. 

For questions related to FERPA policies, please contact the Tennessee Tech FERPA Officer, Brandi Fletcher, bhill@tntech.edu. 

PLEASE NOTE: The procedures outlined here apply only to proposed projects that intend to use data from Tennessee Tech student records. For proposed projects that intend to use student data from any other educational institution, written permission must be provided by authorized personnel at the institution.