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For data to qualify as a FERPA student education record, it must meet both of these criteria:
Criteria #1: Directly related to a student
Criteria #2: An official record maintained long-term
Generally, if an education record contains “personally identifiable information” regarding a student, it will be “directly related” to the student.
If a particular student can be identified from the data, then the data is “directly related” to them, which satisfies Criteria #1.
This could be fulfilled by a single piece of data (e.g. an ID number or SSN), or multiple pieces of data (e.g. a name and date of birth together).
FERPA calls this a record “maintained by the educational agency.” For this criteria, the data must be kept in one place with a single record of access.
Examples of data that do not meet this criteria: