"School Officials"
A "SCHOOL OFFICIAL" CAN BE A PERSON:
1) EMPLOYED BY THE COLLEGE IN AN ADMINISTRATIVE, SUPERVISORY, ACADEMIC, RESEARCH, OR SUPPORT STAFF POSITION (INCLUDING LAW ENFORCEMENT AND HEALTH STAFF PERSONNEL),
2) ELECTED TO THE BOARD OF TRUSTEES,
3) OR COMPANY EMPLOYED BY OR UNDER CONTRACT TO THE COLLEGE TO PERFORM A SPECIAL TASK SUCH AS THE ATTORNEY, AUDITOR, OR COLLECTION AGENCY,
4) OR STUDENT SERVING ON AN OFFICIAL COMMITTEE, SUCH AS A DISCIPLINARY OR GRIEVANCE COMMITTEE, OR ASSISTING ANOTHER SCHOOL OFFICIAL IN PERFORMING HIS OR HER TASKS.
SUMMARY: IF YOU ARE AN EMPLOYEE OF A UNIVERSITY, OR A COLLEGE TRUSTEE, YOU ARE A "SCHOOL OFFICIAL" FOR FERPA PURPOSES.
Don't read the Small Print
There is no definition in FERPA for "school official." All that FERPA says regarding "school official" is that each institution must specify the "criteria for determining who constitutes a school official…." (34 CFR 99.7 (a)(2)(iii); see Appendix 2 of the 2001 AACRAO FERPA Guide.) Therefore it is up to each institution to identify who the "school officials" are for their institution and include those individuals or groups in the annual notification. This slide identifies the typical individuals and groups who can be identified as school officials. Note that individuals other than the institution's faculty and staff may be included as "school officials." Also, if an institution has graduate assistants and/or work-study students or has students serving on committees that have access to other students' education records, the institutional definition of "school official" must be broad enough to include these students for their specified tasks. It is not necessary to require these students to sign an agreement regarding the confidentiality of these records. Generally, students who are informed of the importance of their responsibilities regarding the privacy of education records under FERPA present little, if any, threat to the violation of that privacy. Train them on FERPA and then treat them as intelligent adults. Your trust will be amply rewarded.