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Dear FERPA Professor,

Some of our dual enrollment students will be taught online by our instructors.  It has been requested that the teachers at the high schools, who will act as monitors, be given access to the class through our LMS.  These individuals will not be employees of the College.  Can we give them access?

Thanks,
Mr. Green

Dear Mr. Green,

Because these are dual-enrolled students being taught by the College's online instructors, §99.34(b) of the FERPA regulations would permit the College to provide student record access to the high school monitors.  Any disclosures would have to meet the conditions set out in §99.34(b) and be limited to those dual-enrolled students and could not include the ability to access the education records of other, non-dual enrolled students.  You can find the above-cited FERPA regulation on page 165 of the 2012 AACRAO FERPA Guide.

I hope this is helpful in answering your question.

The FERPA Professor

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