1. Applying FERPA in Real Life Settings
Leroy Rooker, Senior Fellow, AACRAO
Jonathan Helm, Registrar, Baylor University
February 4, 2019

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3. Question #1
The daughter of one of our administrators is a university student. The administrator has asked one of the daughter’s instructors to keep him informed of her progress and to let him know if her attendance starts to drop off. Is that permissible under FERPA?

4. Question #2
A local company contacts you to verify a degree for a job applicant. They provide the name, but there are several students with that name, so they also provide the social security number to help you identify the student. The applicant did in fact earn a degree from your institution, and “degrees earned” is included in your list of published directory information items. Is it OK for you to verify the degree?

5. Question #3
An undergraduate student has the right to review ALL the following records that pertain to the student and are maintained by your university:
Parental financial information
A letter of recommendation for a sophomore scholarship
University police Records
Graduate College records related to denial of the student’s application to a graduate program

6. Question #4
You are contacted by a colleague from a community college in your state asking you to send an unofficial transcript for a student who attended his college first and then attended your university. He is trying to determine whether the student is a candidate for reverse transfer. Do we need student consent to send him the unofficial transcript?

7. Question #5
You receive a phone call from worried parents saying there’s a family emergency and they need to find their daughter immediately. Because it’s an emergency, can you tell the parents the time and location of their daughter's class even though class schedule is not considered directory information at your school?

8. Question #6
A 16-year-old high school junior enrolls in a college course you are teaching during the summer. The student’s parents come to your office and ask about their son’s attendance and his grades. They are concerned because they have noticed that he seldom studies for the course. You have not seen this student in several weeks. Are you permitted to release attendance and grade information to the parents since the student is under the age of 18?

9. Question #7
You are a faculty member in the Mathematics Department and have been tasked with administering a grant the university received to offer mathematics tutoring for first-generation college students. Although first-generation student information is not considered directory information, you request from the Registrar names, addresses, telephone numbers, and addresses for this group of students. Is it permissible under FERPA for you to obtain this information?

10. Question #8
The password reset process for our university’s student portal asks the student to enter the following:
Username (first part of the institutional address)
Student ID number
Date of birth
Last four digits of social security number
Is this a FERPA-compliant process since we’ve included some non-directory information (ID number and SSN)?

11. Question #9
Does FERPA apply to individuals who are taking non-credit continuing education courses through our college? The office of continuing education maintains records on these students, but no transcript is generated.

12. Question #10
A student’s father has provided the most recent year’s tax return showing he claimed the student as a dependent. The parents are divorced, and the mother is not listed on the return. To whom may we release information about the student?

13. Question #11
Sometimes students come to our office asking for copies of their transcripts from former schools. Because we are not the primary source of this information, we are hesitant to provide it. Do we have to provide copies under FERPA?

14. Question #12
We received a summons for a transcript from the Department of the Treasury/IRS with no student consent attached. Do we treat this the same way we would a legally issued subpoena?

15. Question #13
A list of students on academic probation was accidentally ed to one of the students on the list. Must we notify all of the students that this information was released?

16. Question #14
We are implementing a new student information system that provides the capability of including student ID photos on the class rolls and advising lists. Our published list of directory items does not include student photographs. May we use this photo capability?

17. Question #15
An employee of the Federal Office of Personnel Management is asking for the transcript of one of our graduates. She showed proper identification as an OPM employee and provided a copy of a form that was “digitally signed” by the graduate. May we release the transcript?

18. Thank you!
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