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Dear FERPA Professor, 

I participated in the FERPA training a couple of weeks ago and really appreciated the insights I gleaned from it.  I have a follow-up question for Section 99.32.  In my notes, I had written down that accreditation and research studies need to have a notation made on the student’s record about any data that is disclosed from the student’s educational record. 

If the person requesting the information for a research study is a school official and the study falls within their role, does a notation need to be put on the students’ records that were disclosed to the school official? 

Thanks,

Ms. Blue

Dear Ms. Blue,

If the institution is conducting the research and a school official at the institution is performing the research as part of the official's job description, then it would most likely fit the "school official" exception to signed consent.  If this is the situation, then the redecoration requirements of 99.32 would not apply.  §99.32(d)(2), which can be found on page 164 of the 2012 AACRAO FERPA Guide, is the relevant regulatory language concerning this issue.

I hope this is helpful in answering your question,

The FERPA Professor

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