Student Confidentiality

At most universities, the assessment of student work is exempt from review by the Institutional Review Board (IRB) because it is considered an educational activity and the collected data will not be generalized outside the program. In many cases, however, information secured for local assessment and evaluation purposes may be useful to other practitioners outside the institution and contribute to the knowledge base of the profession.  This type of dissemination requires approval from the IRB.

Do I need IRB approval before or after I collect / analyze assessment data?

Before collecting assessment data from students (e.g., survey, focus group), or analyzing course documents, classroom data (e.g., coursework, senior projects), or student academic data, ask yourself whether you intend to disseminate findings or would disseminate if the findings are interesting / valuable. If the answer to either of these questions is 'yes', IRB approval is required PRIOR TO the collection or analysis of data.

If, during the initial collection or analysis of assessment data, there is no intention to disseminate findings (even if the findings are interesting / valuable), however interest for disseminating results or analyzing data for research / dissemination purposes develops at a later date, IRB approval for the analysis / use of existing data is required as soon as there is intent to analyze the existing data for research / dissemination purposes.  

Note: Releasing data to accrediting agencies in order to present evidence of improvement of student learning does not constitute dissemination of research results/data, and therefore does not require IRB approval.

General guidelines for protecting students

Privacy and security:

  • Restrict access to student work to departmental faculty and campus administrators involved in assessment.
  • If student work is stored on-line, ensure security (e.g., use password protection) to limit access to departmental faculty and campus administrators. Whenever possible, do not keep sensitive (e.g., self-stigmatizing) identifiable student work on-line.
  • Instead of collecting work products from all students, collect a sample.
    • If one student work product contains sensitive information or the like replace it with another student work product.
    • If one student work product gives information about others that violates the rules of consent, replace it with another student work product.
    • If a student requests that their work not be a part of the assessment process, comply.

Anonymity and confidentiality:

  • Anonymize student work; remove any information that identifies individual students (i.e., name and/or ID number) from any student work collected/used for assessment.
    • Consider distribution of a consent form (see below for an example).

Reporting and communication:

  • Report in the aggregate to avoid identifying individual students.
  • Share your process, (aggregated) findings, and plans for program improvement with program faculty, your students, and campus administrators.
    • Clearly explain your process, particularly those parts that could apply to departments both on and off campus, in the interest of others benefiting from your work.
  • Clarify your purpose and method: (a) discuss program student learning outcomes as they relate to the findings and (b) include the scoring rubric used to evaluate student work in the report so as to show your criteria and definitions of “quality” implied in the findings.
  • Appoint a single faculty member knowledgeable of the program’s assessment process to respond to student concerns, complaints, and/or grievances. Include this person’s contact information in the report.

Copyright ownership:

  • Students own the copyright for their own works, which gives them the exclusive right to reproduce or distribute their work. While it is appropriate for faculty to review student work to assess the achievement of educational criteria/expectations, if the evaluation involves copying any or all portions of the work, students should be notified of this before submitting their work.