What recordkeeping requirements exist for requests and disclosures under FERPA?
FERPA requires that an educational institution maintain a record of each request for access to and each disclosure of personally identifiable information from the educational record of each student. The record, which should be maintained with the education records of the student , should include the parties who requested or received personally identifiable information from the education records and the legitimate interests the parties had in requesting or obtaining the information. These recordkeeping requirements do not apply when the request was from or the disclosure was to the following individuals: the student, a school official with a legitimate educational interest, a third party with written consent from the student, or a party seeking directory information.
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