FERPA requirements for video anonymisation
FERPA is designed to protect personal privacy that allows parents the right to access their child’s education record, the right to have the education record amended, and the right to have some control over the disclosure of their child’s personally identifiable information (PII) from the education record. It applies to all educational institutions that receive US federal funds.
Under FERPA, parents have the right to inspect and review their child’s education records, including video footage, and schools are expected to respond within 45 days of the information request.
When video blurring is necessary to comply with FERPA
If the educational agency or institution can reasonably redact or segregate out the portions of the video directly related to other students, without destroying the meaning of the record, then the educational agency or institution would be required to do so prior to providing the parent or eligible student with access.
A photograph or video of a student is an education record when the photo or video is directly related to a student and maintained by an educational agency or institution. It is “directly related” if an educational institution uses the photo or video for official purposes involving the student, was intended to focus on a specific student, and if the images contain personally identifiable information.
Without these factors the photo or video is unlikely to be “directly related” to the student. For example, if the student’s image is incidental, or if a student is shown participating in school activities that are open to the public.
Here are some examples of videos that would be considered an education record:
surveillance video showing fighting
classroom footage of a student experiencing a medical event
footage of a faculty meeting in which a specific student’s grades are discussed.
Consequences for FERPA violations
Violating FERPA can have serious consequences. The severity of penalties can vary from loss of funding or accreditation to criminal charges and civil penalties. It varies based on the nature of the violation, the amount of harm caused, and whether the violation was intentional or unintentional.
You can find out more about FERPA regulations violation consequences in this article.
Video redaction tools for FERPA compliance
To mask PII in videos, educational institutions need to be able to blur out faces, bodies, ID tags or badges, and signage. When sharing videos that have audio tracks, they’ll also need to redact audio tracks.
There are different ways organisations can handle video redaction requests. We list the most common ones below.
Manual redaction with video editing tools
Video editing tools are easy to deploy and set up, but they are not designed to automate face or body blurring.
To provide FERPA-compliant footage, it’ll be necessary to blur out faces and other types of PII frame by frame. This can be time-consuming, with a single video taking up hours.
Manual editing also carries a high risk of human error, for example, missing a frame.
Manual video anonymisation won’t be helpful for educational organisations facing a high volume of footage requests, but can work for one-off redaction projects.
Outsourcing
Educational organisations may decide to hire service providers to complete video redaction without buying any video redaction tools.
However, outsourcing makes it hard to control video redaction costs and may create data exposure risks for student PII.
Educational organisations would still need to check footage and request changes, if necessary, before sharing the video.
Automated video redaction for FERPA compliance
Automated redaction systems detect and track objects within video footage, and provide consistent redaction. They can automate PII blurring and speed up redaction times, so that your team doesn’t need to manually blur personal data in every frame.
However, some companies have minutes-based pricing that may be hard to budget for (our tool, Identity Cloak, offers flat pricing to educational institutions).
Video redaction software is the best fit for organisations that start getting more than occasional footage requests and want to avoid bottlenecks or overworking your staff.
Keep reading for a list of 4 questions that can help you decide which video redaction solution is the best fit for your educational organisation.
4 questions to help you choose the right video redaction solution
Given the privacy risks for outsourcing and the risk of human error for video editing tools, we recommend using video redaction software. Additionally, having access to an automated solution makes it easier to process high volumes of footage requests on time with a small team.
For example, the North Plainfield School District in New Jersey that serves approximately 3,700 students adopted Facit’s AI-powered video redaction software, Identity Cloak, to automatically redact visual and audio information.
When choosing a video redaction software tool, education organisations need to balance functionality with ability to predict costs.
Here are 4 questions to start building a list of requirements for a video redaction tool:
Do you need to use an on-premise solution or a solution integrated with your VMS?
If you’re required to keep the student data on premises, cloud-based redaction solutions may not be the right solution for your organisation.What are the types of video footage that you need to redact?
For example, you may find out that in addition to CCTV footage inside the building, you also get requests for parking lot footage with different lighting conditions.Are there any typical scenarios that are likely to come up in footage requests, such as student interactions in hallways, parking lot footage or videos of students at recess?
These scenarios will help you determine your needs for blurring functionality, from types of blur to additional features, such as ability to merge or shorten videos and redact audio track before exporting the final video.What is the current volume of video footage requests? Do you expect it to change in the future?
Understanding this will help you accurately estimate redaction costs and compare different pricing plans across different solutions.
Below we’ll show how our solution, Identity Cloak, helps educational institutions redact videos in-house, automating cumbersome manual work without driving up redaction costs.
Identity Cloak video redaction for FERPA compliance
Identity Cloak can be used as a standalone desktop version and as a plug-in solution for organisations using Milestone’s XProtect. In this section, we’ll show how the desktop version of Identity Cloak helps educational institutions redact video footage and stay compliant with FERPA regulations.
Identity Cloak features for educational institutions
Identity Cloak is an AI-powered solution that automatically identifies people and cars in video footage and blurs out PII.
Educational organisations using Identity Cloak include school districts in the US and in Canada. In the UK, our clients also include specialist education providers.
Here are the Identity Cloak features relevant for educational organisations that need video redaction for FERPA compliance.
Multiple blur types
You can choose between face, body, and inverse blur options. For many educational institutions, face and body blur features are the most relevant ones, since some students or staff may be wearing identifiable clothing.
You can also blur out name tags or ID badges manually for your staff.
Support for low-quality footage redaction
Identity Cloak can handle low-quality videos, such as low-visibility CCTV footage from parking lots, including fish-eye cameras, reducing redaction workload.
Built-in audio redaction
It can also be used to edit out mentions of personal information, such as names or other personal details, in audio tracks, without having to export video files and edit them in a separate editing tool.
Screen recorder for legacy solutions
Finally, for schools that rely on legacy VMS, Identity Cloak makes it easy to import footage with a screen recorder. MP4 and AVI files can be imported directly.
For example, Chignecto Central Regional Centre for Education (CCRCE) in Nova Scotia, Canada, uses both digital and analog cameras — and was able to reduce redaction time by 80%.
Predictable pricing
Another challenge the education sector faces is the need for predictable pricing and limited budgets. Many video redaction tools have per-minute pricing, which makes costs hard to predict and control.
Identity Cloak offers a flat fee pricing option to educational institutions (reach out to find out more). Importantly for schools with multiple CCTV cameras, we don’t have any limits of file size import and export — and don’t limit the duration of the redacted video footage.
Find out more about using Identity Cloak for education organisations here.
Start your free Identity Cloak trial
Download Identity Cloak and see for yourself how it can speed up video redaction across typical types of footage requests. To get a quote for your educational organisation, reach out to our team.
