Guide :: Education :: Exempt :: Archival Data
Archival Data/ Student Records
Archival data is any information previously collected for another data set or other use that can be linked to an individual. CFR 45 part 46 specifically mentions records, documents, and existing data. The information may be available in a public data set, or through a private source, such as a previous research study. In order to qualify for exemption, the data need to be either public data or recorded in manner that cannot identify or link the individual to that data. If these conditions are not met, the Board will need to approve the use of the data, and unless a waiver is justified, the researcher will need to document consent from the participants.
Archival data sources that are typical for education research include the use of student records and the collection of materials or exams from previous classes. These materials are not considered public data, so in order to qualify for exemption, it is necessary that the data are collected in a way that does not identify the individual student. The Board typically asks that a neutral third party link the data to a random code and then strip the identifying information from the data. The neutral third party should be someone who has access to the data outside of the research study. For example, a school administrator can access school records, or a teacher can access his or her students’ exams. However, if you are the teacher or school administrator, even though you have access to this information because of your professional position, you do not have access to it as a researcher. You may need to be a little creative in devising a way to remove yourself from the data collection. For information, please see Risks.
Student records have additional protections under FERPA and PPRA. Please see State and Federal Laws for more information.
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Guide :: Education :: Exempt :: Archival Data |
