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Dear FERPA Professors,

I wanted to request your feedback or any suggestions on the timing of our annual notification to students. We have several part-of-term and enrolled students who could best be described as registering on an almost rolling basis.

At the university, we have established a notice that is sent to every student as they register, which includes several consumer notices. The first one on the list is FERPA. It provides a brief introduction and a link to our university’s FERPA page, which contains all the necessary information for students. Given that students register at various times, I wanted to confirm with you that this would satisfy our required annual notification.

We have drafted a more comprehensive email that we anticipate sending at the beginning of each long semester, as that is when most of our students begin. Would you encourage this, given that it won’t reach all students? Any suggestions are greatly appreciated.

Regards,

Reg Rolling


Dear Reg Rolling,

The University’s means of notifying students of their FERPA rights appears to meet the notification requirements of FERPA. This is because you notify all incoming students of these rights at the time they register at the University.

Because FERPA requires that this notice be done at least annually, you would also want to do the general notification you mention at the beginning of each long semester to those students who are now in attendance at the University. You can review the annual notice requirements at § 99.7 of the FERPA regulations.

I hope this is helpful in answering your questions. You can find the above-cited regulation starting on page 155 of the 2012 AACRAO FERPA Guide.

The FERPA Professor

Want the Professor to come to your campus? Visit our FERPA compliance training page.

AACRAO members, send your questions to the FERPA Professor at communications@aacrao.org.
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