Dear FERPA Professor,
We have a new integrated library system and some of the college libraries would like to give students additional access to students' library records which include library fees, what books they have checked out or their circulation history, and staff notes entered into the database. Is this permissible under FERPA? I am not sure if student workers receive FERPA training and agree to follow it.
Thanks,
Ms. Berry
Dear Ms. Berry,
Depending on how the College defines "school official" and "legitimate education interest" in its annual FERPA notice, such student worker disclosures as you describe could be permissible. (See § 99.7(a)(3)(iii) in the FERPA regulations.) Also, keep in mind that it is the College's responsibility to ensure that the students are trained in the requirements of FERPA and that it would be responsible for any improper disclosure by the student worker, just as it is for any College school official.
I hope this is helpful in answering your question. You can find the above cited regulation starting on page 155 of the
2012 AACRAO FERPA Guide.