Your Zoom recordings may include personally identifiable information (PII) about students and thus constitute education records that are protected under the Family Educational Rights and Privacy Act (FERPA) — the federal student privacy law.
FERPA restricts the sharing of student educational records (i.e. records in any medium that relate to an identifiable student) without permission, except as allowed under certain exemptions.
If a recording includes only the instructor or voices of students that are not personally identifiable, it is not a student education record, and FERPA does not limit its use. Asynchronous recordings made via Zoom would fall under this category.
If the recording includes the names or identifiable audio, communications, or images of students asking questions, making presentations, engaging in discussion, or leading a class (other than TAs), then the portions containing that information are personally identifiable information (PII) and do constitute student education records. Synchronous Zoom lectures may fall under this category.
Faculty can share recordings of lectures that include student education records with other students enrolled in the same course in the same semester. Those recorded lectures, however, cannot be used in future semesters.
Distribution of recording links should also be taken under consideration. Zoom sessions that are initiated within D2L Brightspace do not need to have their download links distributed as the recordings are available from the D2L Brightspace Zoom dashboard and are already restricted to only those in the class.
Shared Zoom sessions initiated through mghihp.zoom.us directly, are not FERPA compliant as the recording links would need to be distributed and thus can't be guaranteed to be restricted to only those in the class.
Recordings that are not FERPA compliant should also not be allowed to be downloaded by students. (The Institute's default setting is to not allow recordings to be downloaded from Zoom) Recordings that are uploaded directly into D2L Brightspace can be downloaded