FERPA Compliance Checklist: How Schools Can Protect Student Data

The Family Educational Rights and Privacy Act (FERPA) establishes critical protections for student education records. FERPA is a federal law enacted in 1974 to protect the privacy of student education records. For schools and educational institutions, compliance is not optional—it is a legal obligation tied directly to federal funding. Yet FERPA compliance can be challenging, especially as schools manage increasing volumes of digital data, educational data, third-party vendors, and evolving cybersecurity risks.

This guide outlines practical steps schools can take to ensure FERPA compliance, reduce risk, and protect student data privacy.

What Is FERPA and Who Must Comply?

FERPA is a federal law that protects the privacy of student education records. It applies to any school, educational institution, and educational agencies that receive funding from programs administered by the U.S. Department of Education. This includes virtually all public schools, charter schools, and many postsecondary institutions.

Under FERPA, schools must meet FERPA compliance requirements, which include protecting, managing, and controlling access to student education records. Schools are responsible not only for how they collect and store student data, but also for how that data is accessed, shared, and protected—internally, with external parties such as third-party vendors or service providers, and externally.

Raising FERPA Awareness Across the Organization

FERPA compliance begins with awareness. Every school employee who interacts with student information has a responsibility to understand and comply with FERPA requirements.

Schools should ensure staff understand why FERPA exists, what rights it grants to students and parents, and the consequences of noncompliance. Awareness efforts should also include clear procedures to notify parents about their FERPA rights, ensuring families are informed and empowered to exercise those rights. These efforts help prevent accidental violations, which are among the most common FERPA risks.

Confirming That FERPA Applies to Your School

While FERPA applicability is broad, schools should formally confirm their obligations. Any institution receiving federal education funding is subject to FERPA, regardless of size or grade level.

Once applicability is confirmed, FERPA should be treated as a core compliance requirement—not a niche policy affecting only administrators or registrars.

Understanding Student Rights, Protections, and Exceptions

FERPA grants specific rights related to education records, including the right to inspect and review records, request corrections, and limit disclosure of personally identifiable information. FERPA protections apply to records that identify a specific student, and this includes not only obvious identifiers like names and ID numbers, but also indirect identifiers or data combinations that could reveal a student's identity.

Employees should understand what constitutes an education record, when written consent is required to share information, and which limited exceptions apply. For example, directory information—such as a student's name, address, or honors—can be disclosed without consent if parents and students are notified and given the opportunity to opt out. Disclosure is also permitted to school officials with legitimate educational interests, meaning access is necessary for their professional responsibilities. In certain cases, a FERPA exception allows disclosure without consent, such as for financial aid purposes, but it is important to document the reasons for such disclosures. Disciplinary records are protected under FERPA and require special handling to ensure confidentiality. Additionally, records maintained by a law enforcement unit are not subject to FERPA regulations.

Clarity around these nuances reduces uncertainty and supports consistent decision-making.

Implementing Clear Policies and Procedures

Policies translate legal requirements into everyday practice. FERPA-compliant policies should clearly outline how to handle education records, including how records are handled, stored, shared, and disposed of. Essential components of these policies include detailed procedures, strict access controls, and ongoing assessments to ensure the privacy and security of student education records.

Examples include prohibiting the emailing of unencrypted student data, establishing data breach response procedures, and ensuring outdated records are securely destroyed. Policies should also require organizations to maintain records of access, disclosures, and amendments to student information as part of compliance. Implementing strict access controls is necessary to limit who can access sensitive information and prevent unauthorized disclosures. Well-defined policies make compliance easier for staff and reduce reliance on individual judgment calls.

Annual Notification Requirements

Annual notification of FERPA rights is a cornerstone of FERPA compliance for educational institutions. Each year, schools must inform parents and eligible students about their rights regarding education records, including the ability to inspect and review records, request amendments, and control disclosures of personally identifiable information. This notification must be clear, accessible, and comprehensive, outlining the procedures for requesting access to education records, submitting amendment requests, and filing complaints with the Department of Education. Schools can deliver these notifications through student handbooks, official websites, email communications, or direct mail, ensuring that every family receives the information. By consistently providing annual notification, educational institutions demonstrate their commitment to transparency and empower families to exercise their FERPA rights.

Encrypting Files and Emails

Encryption is a critical safeguard for protecting student data. Encrypted files and emails cannot be accessed without proper credentials, providing protection if devices are lost, stolen, or compromised. Data security is a key reason for encrypting files and emails, as it helps ensure student information remains private and secure.

Schools should ensure encryption is used consistently across systems that store or transmit electronic records, particularly when staff use laptops, tablets, or mobile devices. It is also recommended to implement multi factor authentication for accessing encrypted or sensitive electronic records to further enhance security and prevent unauthorized access.

Choosing FERPA-Compliant Vendors

Third-party vendors often play a significant role in managing student data, including providing institutional services such as instruction, data management, or assessment delivery. However, schools remain responsible for FERPA compliance even when data is handled by outside parties.

Vendor agreements should be reviewed and updated to confirm FERPA obligations are clearly defined. Schools must maintain direct control over vendors through contractual agreements to ensure compliance and safeguard student data. Any sharing data with vendors should be properly authorized and documented to meet privacy and security standards. Additionally, schools should avoid vendors that engage in data mining practices, as these can compromise student privacy and violate FERPA requirements. Schools may be held liable for vendor actions, making due diligence essential.

Training All School Employees

FERPA training should be mandatory and recurring. Employees should receive training when they are hired and participate in refresher training at least annually.

Because FERPA has many nuances that are easy to forget, regular training helps reinforce expectations and keeps staff informed of evolving best practices.

Implementing Additional Prevention and Oversight Tools

Beyond training and policies, schools benefit from tools that support ongoing compliance. These may include compliance-monitoring mechanisms, access controls, and centralized case management systems. Using these tools to regularly review and update processes is essential to maintain compliance with FERPA requirements.

Such tools help schools track issues, document responses, and ensure consistent handling of privacy-related concerns across departments.

Audit Trails and Compliance

Maintaining detailed audit trails is essential for FERPA compliance and the protection of student education records. Educational institutions must implement systems that log every access, modification, and disclosure of student records, creating a transparent record of who interacted with sensitive student data and when. Regularly reviewing these audit trails helps schools detect unauthorized access, investigate potential compliance gaps, and ensure that only authorized personnel handle student records. Comprehensive audit trails not only support student privacy but also provide critical documentation during compliance audits or investigations, reinforcing the institution’s dedication to safeguarding education records.

Amendment Requests and Appeals

When a parent or eligible student believes that information in an education record is inaccurate or misleading, they have the right to submit an amendment request. Educational institutions must respond to these requests promptly, following clear procedures to review and address the concerns. If the institution decides not to amend the record, the parent or eligible student is entitled to a formal hearing conducted by an impartial officer. During the hearing, the requester can present evidence and explain their position. Should the amendment still be denied, the parent or eligible student may add a written statement to the record, ensuring their perspective is documented. By handling amendment requests and appeals fairly and transparently, educational institutions uphold the rights of students and families while maintaining FERPA compliance.

Data Breach Response

A swift and effective response to data breaches involving student education records is vital for educational institutions to maintain FERPA compliance and protect student privacy. In the event of a data breach, schools must immediately contain the incident, notify affected individuals, and launch a thorough investigation to determine the cause and extent of the breach. FERPA requirements also mandate that parents, eligible students, and the Department of Education are informed as appropriate. Having a comprehensive data breach response plan in place enables educational institutions to minimize harm, address vulnerabilities, and demonstrate their commitment to safeguarding education records and student privacy.

Federal Funding and FERPA

FERPA compliance is directly linked to an educational institution’s eligibility to receive federal funding. Any school or educational agency that receives federal funding from the Department of Education must adhere to FERPA’s requirements for protecting student education records and ensuring student privacy. Noncompliance can result in the loss of federal funding, which can significantly impact the institution’s ability to provide educational services. By prioritizing FERPA compliance, maintaining robust policies, and regularly reviewing procedures for handling education records, educational institutions not only protect student privacy but also secure the federal funding necessary to fulfill their educational mission.

How Case IQ Helps Schools Support FERPA Compliance

Maintaining FERPA compliance requires visibility, consistency, and accountability. Case IQ’s case management platform helps schools manage FERPA-related concerns by centralizing reporting, documentation, and oversight.

With Case IQ, schools can track privacy incidents, document investigations, monitor trends, and maintain audit-ready records. Centralized case management also supports cross-department collaboration and helps ensure FERPA obligations are applied consistently across the institution. Case IQ enables schools to protect student records by implementing secure workflows and robust controls that safeguard sensitive education data as part of their compliance efforts.

By providing structure and transparency, Case IQ helps schools move from reactive compliance to proactive student data protection.

Frequently Asked Questions About FERPA Compliance

What is FERPA?

FERPA is a federal law that protects the privacy of student education records and applies to schools receiving U.S. Department of Education funding.

Who is responsible for FERPA compliance?

All school employees who access or handle student data share responsibility for FERPA compliance.

Does FERPA apply to third-party vendors?

Yes. Schools are responsible for ensuring vendors that handle student data comply with FERPA requirements.

Why is training important for FERPA compliance?

Training reduces accidental violations by helping employees understand their responsibilities and FERPA’s requirements.

What happens if a school violates FERPA?

FERPA violations can result in investigations, corrective actions, and potential loss of federal funding.