Dear FERPA Professor:
Happy New Year! I have fielded a few calls from faculty asking about granting secondary teacher role access in our online learning platform. They’d like to provide access to their unpaid undergraduate teaching assistants. Is it a FERPA violation to provide these teaching assistants gradebook access?
Thank you for any guidance you can offer for this situation.
Thank you for the question, and happy 2021 to you.
To answer your question: §99.31(a)(1)(i)(B) permits an institution to designate as "school officials" those parties, including student workers, who are under the direct control of the institution and are performing a service for the institution.
Note: just as with all those who are designated as school officials by the University, all of the other conditions of §99.31(a)(1), including limiting access to those education records in which the teaching assistants have a legitimate educational interest, must be met. Also, as with all of your other school officials, the University is responsible for ensuring that the teaching assistants are properly trained in, and comply with, the requirements of FERPA.
I hope this is helpful in answering your question. You can find the above cited regulations on page 159 of the AACRAO 2012 FERPA Guide.
All the best,
The FERPA Professor