Ask the FERPA Professor

August 8, 2022
  • FERPA Professor
cartoon figure reminiscent of Einstein stands in front of a chalkboard with the board "FERPA" written on it

Dear FERPA Professor,

Is proctoring technology (and any potential captures) considered education records? I appreciate all of your help, with questions that I send you.

Ms. Roberts

Dear Ms. Roberts,

Education records are records that are directly related to a student and maintained by an institution or a party acting for the institution.  This would include any proctoring service that is contracted by LU.  Thus, if the proctoring service is creating such records, these would be subject to FERPA.

I hope this is helpful in answering your question.  You can find the definition of "Education Records" on page 154 of the 2012 AACRAO FERPA Guide.

The FERPA Professor

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