FERPA Compliance

As part of the StudentTracker for High Schools service, state education authorities and districts disclose personally identifiable information about their graduated high school students to the National Student Clearinghouse. The Clearinghouse compares the data to the postsecondary student records of its more than 3,700 participating colleges and universities. It transmits to districts aggregate reports and detailed records of the college enrollment of their high school alumni, identifying colleges where they enrolled, attendance dates, and degrees earned.

In order to disclose personally identifiable information and be compliant with FERPA, the school, district, or education authority designates the Clearinghouse as a “school official” only for the specific purposes specified in the agreement. This means that the Clearinghouse can receive both directory, non-directory, and blocked information, but must respect the school’s directory information definition and blocks within the work it performs on behalf of the school.

FERPA also specifically allows schools to conduct research that would permit them to improve instruction of future students. The agreements with the Clearinghouse meet the requirements for both of these exceptions to the consent requirement for the release of student records.

• The Clearinghouse agrees to only use the personally identifiable student information supplied by the school for the specified purposes and to return or delete the personally identifiable information when the school is no longer under contract with the Clearinghouse; in this way, the school retains control over its data as required under FERPA.
• The Clearinghouse retains only aggregate, de-identified information for the purposes of benchmarking reports that are made available at no cost to assist schools in measuring their own performance against their peers.
• When required under FERPA, a record is made that a student’s postsecondary education record was shared with the high school; the Clearinghouse reserves the right to share with the student the identity of any organization with which the student’s education record was shared.
• The Clearinghouse does not data-mine or commercialize information shared with it by high schools and it does not collect any information directly from high school students or their parents.