This week, the FERPA Professor answers two questions about communicating with students via email. Be sure to scroll all the way down to see both Q-and-As.
Dear FERPA Professor,
At my institution, communication with students is a constant struggle. We are consistently sending information to them that is important to their enrollment success, but many students say they are not receiving it because they do not check their institutional email address. As a result, several administrators on my campus have chosen to communicate with students via their personal email account like yahoo, google, etc.
As Registrar, I have raised concerns regarding communicating with students over their non-institutional email account. Sending a general message that says important information has been sent to their institutional email makes sense to me, but anything beyond that, I'm a little uneasy with.
Do you have any guidance for me on this topic? Is there a FERPA concern by allowing administrators to communicate with students via personal email addresses instead of their institutional email account? Can they communicate things such as, "your schedule has been dropped", "you owe $800", or "you've been academically dismissed" to the personal email account?
Any advice or wisdom you can provide in this area would be great!!!
Respectfully,
Mae Dae
______________________________________________
Dear Mae,
Your concerns on the use of non-institutional email addresses is understandable. It is never a problem to communicate information from education records to the student but the institution is responsible for authenticating the identity of the student (See §99.31(c) of the FERPA regulations).
The safest way to authenticate is to use the institutional-assigned email. The use of any personal email is always subject to others having access, etc. Students can forward the institutional emails to their personal email if they choose to do so. Also, your suggestion below that the school official notify the student's personal account directing them to check their institutional email for important information is a great way to proceed. Other institutions use this method to alert third parties, for example parents to whom the student has given consent to access financial records, that they should check the SIS for the update.
I hope this is helpful in responding to your inquiry.
Sincerely,
The FERPA Professor
_______________________________________
Dear FERPA Professor:
I have a two-part question regarding emailing students.
1. If a student emails you, either from their personal email address or their school email address, requesting non-directory information, are you allowed to email this information back to them? (We had a student email us wanting to know what her schedule was and she wanted us to email it back to her. I was not comfortable with this.)
2. Also, does this same issue apply to grades, etc.?
Thank you in advance for your assistance,
Dawn Difinio
_________________________________________________
Dear Dawn:
FERPA is not prescriptive on how an institution operates as far as email is concerned. What FERPA prohibits is the improper disclosure of a student's education record. This is why it is important, and protective of the institution, to only use the institutional assigned email address. The institution has established this address and issued a random password known only by the student. Thus, sending information from the student's education record to that address is reasonable authentication for the identity of the student. Sending the information to any other address does not afford the same degree of authentication and puts the institution at risk of a FERPA violation.
As a best practice, always send the email to the institutional email address. The student can, of course, then forward emails from that address to any other email address of the student's choice. This then becomes a disclosure by the student and is not an issue for the institution.
See 99.31(c) of the FERPA regulations for the authentication requirement. You can find this on page 162 of the 2012 AACRAO FERPA Guide.
I hope this answer has been helpful.
The FERPA Professor
Please visit our Ask the FERPA Professor archives for more insight from the professor. And send your questions for the FERPA Professor to connect@aacrao.org.
In addition, check out the FERPA offerings at this year's AACRAO Annual Meeting, March 20-23 in Phoenix, Arizona. AACRAO Senior Fellow LeRoy Rooker will be presenting:
- Registrar 101 & FERPA (Part I)
- FERPA: the Overview
- FERPA: the Update
- Applying FERPA in Real-life Situationsï
- FERPA and Admissions Records Requests: The View from the Registrar's Desk
To register and for more information, visit the AACRAO Annual Meeting page.