Discussion

FERPA established a definition of an "Education Record" about a student. In short, an Education Record includes most of the information that the university maintains about a student but excludes some specific categories of information such as health records.

Information in Education Records falls into one of two categories: a/ directory information, which includes the types of information that would generally be included in published or electronic directories, and b/ all other information.

Universities decide what they consider to be "directory information" and provide that list to students. Under FERPA, students can request that directory information about themselves not be published. (See Section 3.2: FERPA Blocks.) Under FERPA, Education Records, other than the parts that the university has declared to be directory information, should be considered to be confidential information -- specifically including the student's Harvard ID number.

The Registrars of the Harvard Schools have developed a set of Common FERPA Directory Elements in order to provide a consistent University-wide understanding of what data elements might ever be considered public information about students under the Family Educational Rights and Privacy Act (FERPA). Individual Harvard schools may use subsets of the list but no school will consider any data element not on this list as directory or public information about a student. Individual schools may select elements from the Common List to be published in online or printed directories or otherwise disclosed publicly.

This Common List is provided to assist students who may cross register or transfer between schools in deciding if they should consider exercising their rights under FERPA to block public display of all such directory information or to discuss with the school other options for blocking the display of individual directory fields.

A student's Education Record may be shared without the student's permission within the university to those with a legitimate educational reason to need the information, and some specific people outside the university. (See US Government description of FERPA.) Information about a student can also be shared where required in situations involving health and safety. Other disclosures of a student's Education Record can be done with the written permission of the student.

See FERPA for more information and resources on FERPA.

Best Practice

When working with student information review the data elements that are considered public information about students.