[TACRAO] Listserv De-Identified Release of Student Records

Lothringer, Robert rlothringer at mail.twu.edu
Mon Aug 10 15:05:44 CDT 2015

If the personally identifiable information is redacted, and the total number is not so small as to make indirect identification feasible, then you could release it and be FERPA compliant.  But you have to ensure you aren't releasing other information along with it that, when put all together, could end up identifying the student or students.

For example, if the group of students is five students all of the same major, and everyone knows that major only has those five students, then no, I would not release it.  I would especially not release it if the list contained even more information like gender and previous school.  Because then you care essentially giving them enough information to figure out who got what grade.

If the group is 50 freshmen in a developmental course, with nothing else included, then I probably would.

It's a gray area, and it's a judgement call.  You just have to feel confident that what you cumulatively release can't be used to identify the students.

Hope that helps.

Bobby Lothringer
University Registrar
Texas Woman's University
P.O. Box 425559
Denton, Texas  76204

Phone:  940-898-3031
Fax:  940-898-3097
E-mail:  Rlothringer at twu.edu<mailto:Rlothringer at twu.edu>

From: tacrao-bounces at tamuc.edu [mailto:tacrao-bounces at tamuc.edu] On Behalf Of Matthew S. Hebbard
Sent: Monday, August 10, 2015 2:57 PM
To: tacrao at tamuc.edu
Subject: [TACRAO] Listserv De-Identified Release of Student Records

Good afternoon TACRAOans,

Does anyone know if de-identification of PII permits the release of non-directory information under FERPA?  Specifically, can we release grades for groups of students to a third party if the PII is removed?

My answer is no due to FERPA and the fact that grades are part of the student record and requires written consent unless it falls under an exception such as audit/evaluation.  This request does not.

Thank you for your insights,


Matthew S. Hebbard
Dean of Enrollment Services and Registrar
South Texas College
3201. W. Pecan
McAllen, TX 78501
956.872.2147 (Office)
956.655.2450 (Cell)
mshebbar at southtexascollege.edu<mailto:mshebbar at southtexascollege.edu>

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