Navigating Purdue University Directory Information: Understanding FERPA

The Family Educational Rights and Privacy Act (FERPA), also known as the Buckley Amendment, is a federal law designed to protect the privacy of students' education records and personally identifiable information at institutions like Purdue University. This article provides a comprehensive guide to understanding FERPA regulations and how they apply to students, parents, faculty, and staff at Purdue University.

What is FERPA?

Passed by Congress in 1974, FERPA spells out the rights of students and the responsibilities of educational institutions regarding student education records. It provides guidelines for appropriately using and releasing student education records. An education record is any record that is directly related to a student and maintained by the university, including transcripts, disciplinary records, contact and family information, and class schedules.

Student Rights Under FERPA

All students have the right to control to whom their education record is released. To release their education record, a student must provide a signed and dated written consent specifically stating what records are to be released, the purpose of the disclosure, and the party to whom the disclosure is being made. Regulations provide flexibility for utilizing electronic signatures.

Students have the right to see everything in their education record except the following:

Information about other students
Financial records of their parents/guardians
Confidential letters of recommendation if they have waived their right of access. (Requiring a waiver of access is not allowed.)

Exceptions to Consent Requirements

There are several exceptions to when that permission is not required. The institution may release records without consent, but is not required to do so. Some examples of the exceptions for having a release include, but are not limited to, the following:

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School officials with a legitimate educational interest
Disclosure to another institution where student seeks to enroll or is enrolled
Disclosure to the Department of Education, state/local education authorities
Disclosure in connection with the receipt of financial aid (validating eligibility), including veteran’s benefits
Disclosure to state/local officials in conjunction with legislative requirements
Disclosure to organizations conducting studies to improve instruction, or to accrediting organizations
Disclosure to parents of dependent students (IRS definition)
To comply with a judicial order or lawfully issued subpoena
Disclosure for a health/safety emergency
Disclosure of directory information
Disciplinary information (Warner Amendment):
- Disclosure to the alleged victim, information from disciplinary proceedings
- Only when found in violation, and only for crimes of violence-release of name, sanction and outcome (public information)
Disclosure to parents of any student under the age of 21, a violation of federal, state, local or institutional laws/regulations related to substance abuse (Foley Amendment).

FERPA rights (and the right to privacy) end at death, unless otherwise specified by state law.

Legitimate Educational Interest

A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibility.

Health and Safety Exception

Institutions may take into consideration circumstances pertaining to the health and safety of a student or other individuals to disclose information from education records without a student’s consent. If the institution determines there is an "articulable and significant threat" to the health and safety of the student or others, information from education records can be released "to any person whose knowledge of the situation is necessary to protect" the health and safety of the student or other individuals.

Outsourcing and Access to Education Records

Institutions are allowed to disclose education records without the student’s consent to contractors, volunteers, and other non-employees performing institutional services and functions.

Directory Information

Some information is considered public (sometimes called “Directory Information”). This information can be released without the student’s written permission. However, the student may opt to consider this information confidential as well. For these students, it is important to note that no information is released without the students’ written consent. If a student elects to restrict all information, the Office of the Registrar will give the following response to all inquiries: “We have no information on this individual.”

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Parental Access to Student Education Records

When a student reaches the age of 18 or begins attending a postsecondary institution at any age, FERPA rights transfer from the parent to the student ("eligible student").

Parents may obtain non-directory information (grades, GPA, etc.) at the discretion of the institution if the student is a dependent per federal tax law. Parents may also have access to non-directory information by obtaining a signed consent from their child. Students may assign proxy access to their parent(s) and identify what types of information (financial aid awards, grades, class schedule, etc.) they can view online.

Schools must honor your request to review your child's education records within 45 days of receiving the request.

What is Personally Identifiable Information?

Personally identifiable information includes but is not limited to:

Student name
Name of student’s parent or other family member
Address of the student or the student’s family
A personal identifier (PUID, SSN)
Biometric record
Other indirect indicators (birth date, place of birth, mother’s maiden name)
Other information alone or in combination that would make the student’s identity easily traceable

Special Instructions for Faculty

To avoid violating FERPA rules, do not at any time:

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Use a part of or the entire Student Identification Number or Social Security Number of a student in a public posting of grades
Link the name of a student with that student’s identification number or Social Security Number in any public manner
Leave graded tests in a stack for students to pick up by sorting through the papers of all students
Circulate a printed class list with student names and student identification numbers or Social Security Numbers or grades as an attendance roster
Discuss the progress of a student with anyone other than the student (including parents) without the consent of the student
Provide anyone with lists of students enrolled in your classes for any commercial purpose
Provide anyone with student schedules or assist anyone other than university employees in finding a student on campus

Public Posting of Grades

The public posting of grades, either by the student’s name, institutional student identification number, or social security number is a violation of FERPA. Using an assigned random number that only the student and instructor know would be an appropriate way to post grades.

What Are Not Education Records?

Sole-possession records or private notes held by school officials that are not accessible or released to other personnel
Law-enforcement or campus-security records that are solely for law-enforcement purposes and maintained solely by the law-enforcement unit
Records relating solely to an individual’s employment by the institution that are not available for any other purpose
Records relating to treatment provided by a physician, psychiatrist, psychologist or other recognized professional or paraprofessional and disclosed only to individuals providing treatment
Records of an institution that contain only information about an individual obtained after that person is no longer a student, i.e., alumni records,
Grades on peer-graded papers that have not been collected and recorded.
This includes transcripts or other records obtained from a school in which a student was previously enrolled. A student has the right of access to these records.

Enrollment/Degree Certification

Please use one of the methods listed below for enrollment or degree certification requests.

Enrollment/Degree Certification - National Student Clearinghouse (recommended method) The place to order your enrollment or degree certification for employment, housing, healthcare or loan deferment. All other requests must use the National Student Clearinghouse.

Indiana Social Security Number Law

Internal use of Social Security Number information within the Purdue system for the purpose of conducting normal business is still permitted under that law. However, it is important to remember that Purdue data-handling guidelines address the usage and methods of exchanging sensitive and restricted data, in addition to just SSN information.

Consequences of Non-Compliance

The Department of Education in Washington, D.C., handles complaints concerning alleged failures to comply with FERPA. This complaint may result in the filing of civil litigation and/or the loss of federal funding for financial aid and educational grants for Purdue University. Action to terminate funding is generally taken only if compliance cannot be secured by voluntary means.

Additional Resources

This annual federally required training for instructors can be accessed by registering through the WebCert portal. PNW instructors will then see the course display in Brightspace under the “WebCert” tab in the MyCourses widget.

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