Ask the FERPA Professor

Good morning,

Our Financial Aid office is asking to add a comment in a student’s record identifying their sibling (including the sibling’s student ID). The rationale is that the Financial Aid office needs to compare the information provided by each of the siblings to verify the parent information provided is the same. Putting the sibling’s student ID in the file helps to confirm that the information was compared and to which sibling’s file it was compared to.  We do not list student ID as directory information. 

My concern is that a student has the right to inspect/review their record and would be privy to a sibling’s student ID unless we can withhold the sibling’s student ID during the inspection/review.  What are your thoughts on this request?

Thank you for your assistance,

Harry Foote

__________________________________________________________________________

Dear Harry,

Yours is not a "directory information" issue but rather a "school official" and "legitimate educational interest" issue.  Sharing of the sibling's name and student ID would be permissible under §99.31(a)(1) of FERPA because of the purpose of the disclosure described in your email.  However, the disclosure limitations found at §99.12(a) would require that the College redact the siblings student ID number during any inspection by the student.  

I hope this is helpful in answering your question.

Sincerely,

The FERPA Professor

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