Dear FERPA Professor,
Sorry to add to your inbox in a busy week. I have a FERPA-related question, related to SACS data. In one of our new courses in communications, students who complete internships for credit create posters about their internship. We hold a poster symposium and judges evaluate the poster presentations. The instructor would like to have student RAs input the scores from prior symposia into an excel sheet for SACS reporting.
Since the poster scores were not grades, is it ok for current students to see and input these scores? Or would that violate FERPA?
Mr. Neil
Dear Mr. Neil,
Because the poster scores are directly related to the individual students, their maintained scores meet the definition of "education record" as contained in § 99.3 of the FERPA regulations. Thus, any disclosure of them would have to be done in compliance with FERPA. However, if your RAs fit the definition of "school official" in the University's annual FERPA notice, as required in § 99.7(a)(3)(iii), then the exception to FERPA's signed consent requirement found at § 99.31(a)(1)(A) would permit the University to have them enter the scores if such action is considered to be a function of their work.
I hope this is helpful in answering your question. You can find the above cited regulations on pages 154, 156, and 159 of
2012 AACRAO FERPA Guide.