Dear FERPA Professor,
We have social events on our campus that are chaperoned by students within the organization hosting the event. These students are not employees of the institution. Our student affairs office would like to provide these student chaperones with a list of students who are not permitted to attend the event due to any type of disciplinary infractions. They will not list the infraction, only the names of the students that cannot attend, Doesn’t this violate FERPA?
Similarly, they would like to provide these same lists to residence hall directors (student employees of the institution) regarding students that should not have access to the hall because of disciplinary infractions. Student employees must complete FERPA training as part of their employment requirements. Would providing them with these lists violate FERPA?
Thanks,
Cat Erwaul
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Dear Caterwaul,
Disclosing information to the student organization on students who have disciplinary issues would not generally be permitted under FERPA. While you could have students assisting with work at your institution, it would need to be for something that the institution is doing, not a campus organization. Disclosure to student employees at your residence halls would be permitted, however, because they could meet the “school officials” exception in FERPA.
Keep in mind that, just like any other staff or faculty, the institution is responsible for ensuring that the student workers are properly trained on the requirements of FERPA.
I hope this response provides the guidance you need moving forward.
The FERPA Professor
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