If a school nurse maintains personal notes, are they part of the educational record and thus subject to FERPA?
No, but only if all of the following criteria are met: • The notes are kept only as a memory aid; • They remain in the sole possession of the writer; • They are shared with no one except a temporary substitute RN; and • They are not used to replace or avoid normal documentation. In general, personal notes are not recommended. Information related to health office visits should be documented in the student’s individual record. Source: Schwab NC, Rubin M, Maire JA, Gelfman MHB, Bergren MD, Mazyck D, Hine B. (2005), Protecting and Disclosing Student Health Information: How to Develop School District Policies and Procedures, Kent, OH: American School Health Association.
