- On this page:
- Live instruction timing
- Recording classes, meetings, and exams
- FERPA-compliant technologies
Live instruction timing
Must live instruction occur during the assigned day/time?
- Yes. If instructors elect to use synchronous instruction they must do so during their assigned day/time in the UW time schedule (Pacific Time Zone) to avoid creating schedule conflicts for students.
- In some cases, it may be appropriate to record and post a live lecture for review later by students.
Recording classes, meetings, and exams
May I record students while they sit for an exam?
Generally, no. Instructors must ensure that their in-person and remote exam practices are consistent. If an exam would not be recorded when administered in-person and the instructor’s syllabus did not communicate at the start of the quarter that the exam(s) would be recorded, then instructors may not record students when they sit for an exam remotely. However, if instructors would ordinarily observe the behavior of students taking exams in-person, students may be asked to switch on the video feature in an online conferencing solution provided they are not recorded. At the beginning of the exam, the instructor should state that individuals are not permitted to record the exam.
If an in-person exam would have ordinarily included a recorded component (ex. a recorded oral presentation, dance or music performance, etc.) and the instructor’s syllabus communicated at the start of the quarter that the exam(s) would be recorded, then recording students while remote is permissible. However, instructors must retain the recording under the same retention schedule as they would have retained an in-person recording, and the recording would become part of the student’s educational record.
Instructors must also be mindful of student equity when requiring the use of any technologies for remote exams.
Instructors may need to:
- Refer students who are residing locally and whose health and personal circumstances permit visiting campus to the Student Tech Loan Program for access to devices that meet the technical requirements for online conferencing
- Make adjustments for students who do not have access to appropriate devices.
Privacy best practices for online conferencing are available on the UW Privacy Office’s website.
May I record one-on-one conversations or meetings?
Generally, no. If a meeting or one-on-one conversation would not be recorded when in-person then it should not be recorded when working remotely.
The UW Privacy Office is consulting with the UW Division of the Attorney General’s Office to evaluate the legal issues related to recording one-on-one conversations, meetings, group activities, instruction, and events. As we are working on broader guidance the below table is a best practice.
Best practices for when to record class sessions
|Audio (host)||Audio (attendee)||Video (host)||Video (attendee)||Recording (host)||Recording (attendee)|
|Classroom instruction (e.g. lectures and presentations)||Yes||Yes||Yes||Yes||Yes¹||Yes¹|
|1-on-1 meetings or conversations||Yes||Yes||Yes||Yes||No||No|
¹Recordings that are personally identifiable to students (e.g., have a student’s image or audio question) are educational records and subject to FERPA protections. Access to such recordings may need to be limited to the instructor and students who are enrolled in the specific class. See FAQ on “Can I share recordings I make of Zoom classes?”
²If an in-person exam would have ordinarily included a recorded component (ex. a recorded oral presentation, dance or music performance, etc.), recording students while remote is permissible. See FAQ “May I record students while they sit for an exam?”
Can I share recordings I make of Zoom classes?
Not publicly. Zoom recordings that include a student’s voice, face, and/or any reference to student records are an educational record protected by FERPA. Access to such recordings may need to be limited to the instructor and students who are enrolled in the specific class. Zoom has signed a contract with the UW and is designated a University of Washington school official under FERPA.
If you plan to record — syllabus privacy/FERPA statement
If you plan to record your class sessions, be sure to include this statement from the UW Privacy Office in your syllabus:
This course is scheduled to run synchronously at your scheduled class time via Zoom. These Zoom class sessions will be recorded. The recording will capture the presenter’s audio, video and computer screen. Student audio and video will be recorded if they share their computer audio and video during the recorded session. The recordings will only be accessible to students enrolled in the course to review materials. These recordings will not be shared with or accessible to the public.
The University and Zoom have FERPA-compliant agreements in place to protect the security and privacy of UW Zoom accounts.
Students who do not wish to be recorded should:
- Change their Zoom screen name to hide any personal identifying information like their name or UW Net ID; and
- Not share their computer audio or video during their Zoom sessions
- Grading numerically or Credit/Non-Credit – Faculty members are strongly encouraged to use the grading mode historically associated with your class, unless there are pedagogical reasons to assign only C/NC grades. It may be necessary to adapt your grading rubric to assess course learning goals fairly, so that you may assign a numeric grade. Individual course sections must be numeric grades only or C/NC only, not a mix of the two. If you want to make this change, you can request a change with the Office of the Registrar.
- Attendance – Don’t factor in attendance as part of grading.
If a UW instructor enrolls in a Canvas course as an “Observer,” is that a FERPA violation, given that the participant can see student names?
Scholastic Regulations Chapter 102, Registration states the following:
- Registration for Courses
- Registration Required
Students are required to register for any course in which they participate. No person, other than guests approved by the instructor, may take part in a University course in which she or he has not been registered.
- Registration Required
If a UW school official needs to visit a class or observe to perform their job (such as performing instructor evaluations) this falls under the FERPA concept of providing a UW school official with a legitimate educational interest access to student records (in this case the student roster, which are student records) and no student permission is requested. It is expected that the instructor of the course has approved the visitation by the UW school official and it is a courtesy to notify students of the visitor and the duration of their visit, but this is not required.
Is it a FERPA violation if faculty are observing each other’s classes for reasons other than evaluative peer review?
In the Evidence-Based Teaching program, faculty members meet in groups to learn more about teaching. Participants observe each other teaching.
Here the same logic as above applies. If a UW official can defend that they needed access to student records to perform their job and it is a legitimate educational interest and a need to know, then sitting in on classes is permissible per FERPA and no written permission from the students is required. Again, it is expected that the instructor of the course has approved the visitation by the UW school official and it is a courtesy to notify students of the visitor and the duration of their visit, but this is not required.
If a UW instructor watches a video recording from a synchronous class session (one where students can be seen and heard), is that FERPA violation?
The UW Privacy website provides guidance here under footnote #1 as to the nature of a recording of a class becoming a student record: Footnote #1: Recordings that are personally identifiable to students (e.g., have a student’s image or audio question) are educational records and subject to FERPA protections. Access to such recordings may need to be limited to the instructor and students who are enrolled in the specific class.
Again, if a UW school official has a legitimate educational interest and a need-to-know purpose for viewing a class recording, this would not be considered a FERPA violation and we would not need permission from the students to allow this student record to be accessed.
Meeting and collaboration
For FERPA compliance, use UW-supported technologies including Panopto, Zoom, Canvas, Office365 and Google G Suite.
- UW Office 365 Microsoft Teams provides chat-based workspaces for real-time collaboration and communication, meetings, and file and app sharing. It is both HIPAA- and FERPA-aligned.
- Google G Suite allows for real-time collaboration, communication, and file creation and sharing. The G Suite includes Hangouts, Docs, Drive, Sheets, and Presentations, Gmail, Calendar, and Sites. Note that many, but not all, G Suite apps are FERPA-aligned.
These technologies have comprehensive agreements in place to help the UW protect the privacy of personal data and manage information security risks. Please be cautious about using other technologies, which may not include an appropriate agreement or adequately protect individuals’ privacy. See IT Connect for information about UW-supported technology.
Announcements and social media
For social media, consider using UW Yammer, which is FERPA– and HIPAA-compliant. Snapchat, Twitter, and Facebook are not FERPA– and HIPAA-compliant.