In appropriate cases, educational records are disclosed without a student's knowledge or consent to Harvard officials with legitimate educational interest in the records. "School officials" include faculty, administrators, clerical, professional employees, and agents of the University such as independent contractors performing functions on behalf of the University. Examples of "legitimate educational interest" include situations where an employee or agent of the University has a need to provide advice to or about the student or former student, or to evaluate or assist with the student's or former student's standing with the University.

Other examples of "legitimate educational interest" include situations where disclosure is required to operate or manage a University-sponsored academic or administrative program, or to perform student-related administrative, security, disciplinary, or other service. In such cases, the academic or administrative program must be prepared to provide written documentation that the information sought is, in fact, required to permit its effective management or operation.