It depends. Under FERPA, this situation must be treated as if the recordings were being shown to a third-party audience, which requires FERPA compliance through use of consents or de-identification of any students depicted. There are several ways to use recordings that might include students’ names or personally identifiable audio, communications, or images:
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The instructor can plan the recording so that students (such as those asking questions during a class) are not shown in the video or referred to by name (another way to de-identify the students). One option for lecture-style classes is to first record the lecture, and then afterwards engage in unrecorded student questions and class discussion.
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The instructor may obtain individualized FERPA consents from the students in the recording which allow use of this portion of the recordings. This type of consent can be obtained on a case-by-case basis or from all the students at the outset of a class. Consent forms are available here.
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The instructor can edit the recording to either omit any student who has not consented to the use of their voice or image or to de-identify the student in the recording (which can include avoiding or removing any mention of the student’s name, blurring the student’s image, altering voice recordings, etc.).