Abstract
FERPA regulations require you to keep a record of a disclosure of education records if that disclosure is for nondirectory information released to a third party. The record of the disclosure must include (1) the record(s) disclosed, (2) the party receiving the record(s), and (3) the legitimate interest that the party had in requesting the information. “Legitimate interest” is not defined in the regulations. It is different than, but similar to, our frequently mentioned “legitimate educational interest.” The term suggests a much broader meaning. To demonstrate a “legitimate interest,” the requesting party must show that the requested information is necessary to fulfill a recognized function or responsibility of the requesting party.
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