Ask the FERPA Professor

Hello FERPA Professor,

I have a question regarding general access to student records.  Our institution works with recruiting partners.  One organization we partner with is requesting access to view their student records once the student has filled out an application for admission and/or has been admitted to our school. 

The issue at hand is that we cannot limit our system to filter out only students who apply through the partner organization.  Therefore, if the partner organization is granted access to our system to view student records, they will have access to view any student record including students who have not applied and/or have been admitted through their organization.

Is this a FERPA violation to allow our partner organization access to view all student records including students who have not applied or been admitted through the partner organization?

Thank you in advance for you advice.

Desi Mal



The FERPA regulations permit the sharing of information from education records with contractors under the same conditions that apply to other school officials. (See §99.31(a)(1)(B) on page 159 of the 2012 AACRAO FERPA Guide.) However, §99.31(a)(1)(ii) requires that the institution limit school official access to only those education records in which there is a "legitimate educational interest."  If your system allows the institution to track who accesses a student's education records, then you would probably be okay with the all student access.  If you don't have the ability to track or to limit the access to only those student records relevant to your contractor, then permitting such access could be difficult to defend.  

I hope this is responsive to your inquiry.

The FERPA Professor


FERPA in Orlando. Spend two days diving into the work of the Registrar's Office at the Registrar 101/FERPA Workshop March 24-25, 2018, in Orlando. This workshop is for those new to the profession and will address many of the 'what' and 'how' questions that make up the work of the registrar.

Or, if you have at least five years of experience in the profession, join Registrar 201 and explore major competencies and proficiencies of the registrar profession, FERPA beyond the basics, and look to the future of the profession. 

After the preconference workshop, stay for the AACRAO Annual Meeting, March 25-28, 2018.

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