Yes. Simply having access to records through your place of employment, does not grant you permission to use them. You must still seek permission to use these records for data analysis and to use them for recruitment from the owner of the records (note that as a teacher, you do not own your student records, they belong to the State). All permissions to use records or access participants, must be in writing on letterhead, signed by the appropriate signatory.

If you have your own private practice and wish to use your own records in your research, contact the IRB Office for more information.