What is an institutions notification obligation to the students who are included in the CSP data base?
Colleges and universities are not required to gain permission from students or their families to disclose data under the FERPA research exemption. However, CSP institutions are still legally obligated under FERPA to place notification of the CSPs access to student information in their student educational records. The required placement of notification can be in electronic form, and a one-time notice is sufficient. The CSP Center will provide a template for the information that should be placed in student files; this template will be available in the CSPs Resource Toolkit on the CSP web site. Under FERPA, colleges and universities may also disclose, without consent, “directory information”. However, a school must inform parents and current students about what types of personally identifiable information it has designated as directory information and give parents and current students a reasonable amount of time to request that the institution not disclose directory information about them