Page History

Criteria

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

Criteria #1: “Directly Related to a Student”

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).

Criteria #2: An official record maintained long-term

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:

• Records maintained briefly by staff (such as student assignments)
• Records kept in the sole possession of the maker as a memory aid, that are not shared or accessible to other persons.
• Records used only as a personal memory aid (e.g. a temporary document stored on a personal computer).