This policy establishes the requirements for Research Requests from Dartmouth Researchers for individual-level Student Data from institutionally managed systems.
Research is a fundamental function of Dartmouth, and impactful research benefits Dartmouth both directly and indirectly. Integral to research is the use of data, including Student Data, which carries legal and privacy concerns.
Student Data is defined as education records of current and former students as informed by the Family Educational Rights and Privacy Act (FERPA). This policy establishes the requirements for Research Requests from Dartmouth Researchers for individual-level Student Data from institutionally managed systems. This policy does not apply to aggregated data in which it would be impossible to identify individuals directly or through any combination of data fields.
All members of the Dartmouth community, including current and former students, faculty, and staff should have a reasonable expectation of privacy. While this policy is specific to Student Data, these general principles may apply to other structured data in institutionally managed systems, including faculty data, staff data, and financial data.
Dartmouth will not disclose personally identifiable information from a current or former student's education records without the student's consent, except in specific situations outlined in Dartmouth's FERPA policy.
Requests for Student Data must follow a Data Governance process distinct from the process required by the Committee for the Protection of Human Subjects, which is Dartmouth's Institutional Review Board.
Requests for Student Data originating from or involving Dartmouth Researchers are considered Research Requests, even if the purpose includes an administrative benefit.
Research Requests for Student Data must be sponsored by a member of Dartmouth's senior leadership and submitted to Data Governance.
Research Requests will only be considered for sponsored projects.
Before Student Data are provided to Dartmouth Researchers, a data use agreement, provided by the Data Steward or the Data Governance Manager, must be adopted specifying data storage requirements, access permissions, destruction timelines, and other details particular to the request as appropriate. Any changes to the terms of the original data use agreement must be submitted as a new request and approved by Data Governance in advance of implementation.
If individual students can be identified directly or through any combination of data fields, Dartmouth Researchers must obtain explicit consent from students before Student Data will be prepared or released.
This policy applies to future requests for Student Data and to Student Data previously provided, to the extent such data is identified and can be reasonably remediated.
Email data.governance@dartmouth.edu with questions about this policy.
Dartmouth Researcher: An employee of Dartmouth engaged in research as part of their Dartmouth role.
Research Request: Any Student Data request originating from or involving researchers even if the purpose includes an administrative benefit
Student Data: Education records of current and former students as informed by the Family Educational Rights and Privacy Act (FERPA)