How does the Family Educational Rights and Privacy Act (FERPA) apply to this data collection effort?
FERPA permits colleges and universities to disclose personally identifiable data about its students for specified research purposes. After legal analysis, the Mellon Foundation, in cooperation with CSP representatives at Middlebury College and Northwestern University has concluded that the proposed research is in compliance with a research exemption to FERPA non-disclosure requirements. In addition, FERPA permits colleges and universities to disclose some personally identifiable data that is classified as “directory information” except when an individual student or his or her parents have filed a written request that his or her directory information not be disclosed. When linking student data with data from third party databases, the CSP will rely on this exemption. Therefore, the information shared with third parties will be limited to “directory information” as defined by participating colleges and universities, and records of students who have elected to withhold their directory inf