Ask the FERPA Professor

August 3, 2018
deuc4dqdrbqwifk27ppv_shutterstock_26355862 FERPA Professor,
There are conflicting opinions on campus about the following:
-Can a student's ID number be included in an email sent directly to that student? Email could be sent through the institutional email address, and/or possibly student's own email address (gmail, aol, yahoo, etc.).
-Can a student's ID number, along with name, be included in an email sent to a school official with legitimate educational interest? Email will only be sent through the institutional email address
Thank you in advance for your input.
Cleo Petra


Dear Cleo,

A student ID number can be disclosed through email so long as the disclosure meets the conditions of one of the exceptions to signed consent found in §99.31 of the FERPA regulations.  In the examples you give, §99.31(a)(12) and §99.31(a)(1) are the exceptions.  However, §99.31(c) requires that the institution authenticate the identity of the student prior to any disclosures from the student's education record. 

If you are sending the information to the institutional email, then you should have authenticated the identity of the student prior to any credentials being provided for accessing the email.  When a non-institutional issues email is used, you have no such established authentication of the identity of the recipient.   

I hope this is helpful in answering your questions.  You can find the cites listed above in Appendix B of the 2012 AACRAO FERPA Guide, starting on page 151.


The FERPA Professor

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