Dear FERPA Professor:
I hope this email finds you well. My FERPA question of the hour is this: a former student has filed a complaint against us with our regional accreditor. My supervisor does not think we should put the complaint in the student’s education
record. I disagree and contend that the record is the most logical place for it. What do you say?
Thank you in advance for your help,
If your institution maintains the student complaint, it is, by definition, an education record. See 99.3 "Education Records" on page 154 of the 2012 AACRAO FERPA Guide.
The decision on where to house the record is up to the institution, but is not relevant as far as its status as an education record is concerned.