Dear C. Cretnotes,
Thanks for participating in the Student Privacy in the Age of AI, Immigration, and Integrated Data: A Preview of AACRAO's Essential New FERPA Publication webinar. I am writing in response to your question: whether advisor notes that are kept for the advisor’s own records and not shared with anyone else, even if maintained on university platforms, are still exempt from the definition of an education record.
The general answer is: Yes. Advisor notes are exempt from FERPA if they are truly private, used solely as a personal memory aid, and not shared or accessible to others—regardless of whether they are stored on a university platform. The critical factor is access, not location. However, if the notes are stored on a university system where others could access them, even in theory, there is a greater risk that the advisor notes may lose their exemption status and become FERPA-protected education records if another person accesses the records. Thus, you should take extra care to ensure that access rights to the information stored on the university's platform are restricted to only your access.
All the best,