New Report – Without Consent: An analysis of student directory information practices in U.S. schools, and impacts on privacy


⬇ Download the Report (PDF)

⬇ Download the Summary and Recommendations (PDF)

⬇ Download the Resources for Schools, Students, and Parents (PDF)


by Pam Dixon

Data visualization: John Emerson

Editing: Robert Gellman


Colophon →

Without Consent:
An analysis of student directory information practices in U.S. schools, and impacts on privacy

World Privacy Forum

www.worldprivacyforum.org

© Copyright 2020 Pam Dixon, Author; Robert Gellman, Editor

Cover and design by John Emerson

All rights reserved.

EBook/Digital: ISBN: 978-0-9914500-1-5

Publication Date: April 2020

Nothing in this material constitutes legal advice.


Brief Summary of Report →

If data is the new oil, then student data is among the most desirable data wells of all. While some states have enacted laws to better protect students and their privacy, policymakers have left a formidable front door open: that is, the ability for detailed student information to be made public by schools under an exemption in the federal student privacy law, the Family Educational Rights and Privacy Act.

This exemption is called the Directory Information exemption. When schools choose to, they can designate certain student information of their choice to be made public without prior consent. This information becomes directory information. To provide a balance, Congress provided a right that students and parents can restrict unconsented public disclosure of their directory information. Eligible students can place this restriction on their directory information by submitting an opt out request at the school. Parents or guardians of students under 18 will have to place the restriction for the student. This right to restrict disclosure is an essential one, but students, parents and others may not be aware of the importance and profound privacy impact of this information.

Directory information at schools is not like information in a phone book; it can be much more extensive. Information such as legal name, exact date and place of birth, home address, photographs, gender, social media handles, parent or guardian home address, and primary language spoken are among the many categories of directory information that schools could — and do — choose to release. In our modern world this kind of information can and does create safety, privacy, and other risks for students, particularly those who are victims of crime or have other vulnerabilities, including economic vulnerabilities.

The default privacy setting of students’ directory information under FERPA is set to allow schools to “publish without prior consent.” In theory, the right to opt out should provide privacy checks and balances. But this report finds that many schools, while technically compliant, have not done enough to encourage students and parents to effectuate their FERPA opt out rights. In some cases, notices of FERPA opt out rights are not prominently posted on school web sites. In others, the very notices that students need for learning about how to activate their opt out rights are the same notices that may nudge them to do the opposite by using discouraging language that facilitates inaction or makes opting out of directory information sharing look like an unattractive option.

The research for this report examined directory information practices and related issues in a multi-year study across more than 5,000 schools at the primary, secondary, and postsecondary levels. The research found troubling and challenging student privacy problems that need to be urgently addressed. The report includes detailed findings and recommendations based on the research. In brief, the research found:

  • It is completely possible for schools to meet the FERPA minimum standards for FERPA notice and at the same time make FERPA opt out difficult or undesirable for students and parents.
  • FERPA directory information notice and opt out is not being consistently implemented in modern, updated ways at schools.
    • Not all schools post FERPA opt out forms for students online. For example, 39 percent of studied primary and secondary schools make FERPA opt out forms online and available to the public.
    • Some schools require students to write a letter to opt out.
    • Some schools give a year for students to opt out; some schools give 10 days.
  • The information designated as directory information by many schools can, in our modern world, be invasive of privacy and cause harm. Exact date of birth, home address, gender, and photographs of students released as public information is no longer acceptable and poses demonstrable risk to students.
  • Few schools have developed a culture of fostering and promoting students’ rights under FERPA to opt out of directory information sharing.
  • WPF research documented a troubling pattern of the brokering of information of minors online.
    • In one case, a company registered as a data broker acquired student directory information.
    • A facial recognition company disclosed it has been brokering the information of minors by collecting the publicly available images of minors for use in its facial recognition product.
    • Among data brokers that stated that they had actual knowledge that they possess the brokered personal information of minors, two companies said they used the information of minors to create predictive scores regarding their parents for commercial purposes.
  • Language that schools use to communicate with students and parents about FERPA opt out rights is not always encouraging of pro-privacy choices, and may contain negative nudges that discourage parents and eligible students from opting out.

WPF research found best practice exemplars of modern FERPA implementations at all levels. These best practices have the hallmarks of modern privacy thought, which is a focus on implementing FERPA in a way that creates transparency, accountability, fairness, equality of opportunity to opt out, and an environment that supports student privacy, safety and student thriving for all students and parents.

There is much that can and must be done to improve student privacy outcomes. Some solutions are simple, such as updated guidance requiring schools to post annual FERPA notices, and ideally, opt out forms, on school websites. Some solutions require legislative and regulatory attention, such as ensuring students’ directory information does not get passed to data brokers. Ensuring students’ photographs or digital images are not available on school websites to be scraped for use in test databases for biometric or other systems also requires attention. And ensuring that all students, from all walks of life, including those who are homeless or living in poverty, have the ability to learn about their privacy rights and take advantage of those rights is of utmost importance.

The days of schools designating and releasing broad swaths of directory information publicly as a “default setting” of FERPA privacy rights needs to be behind us. Advances in modern privacy thought and laws demonstrate that directory information is no longer just a dusty right consigned to dense legal notices few understand the full significance of. The COVID-19 pandemic that has so deeply impacted all schools, parents, and students shows the urgent need to ensure that FERPA notices and opt outs are online, available all year, and can utilized without resorting to paper handouts or in-person office visits. The U.S. Department of Education, states, local school boards, and local schools need to do much more to update their approach to how directory information is handled at every level. The current default settings for directory information under FERPA need to be re-examined and the procedures need to be re-evaluated and refitted to a more modern understanding of data privacy. The safety and privacy and thriving of all students depends on it.

Key Recommendations →

We can and must do more to protect the information of students, and minors. FERPA-covered educational institutions and agencies have an important role in taking affirmative and decisive steps to protect students and minors. Some specific recommendations regarding directory information include:

  • Educational institutions covered under FERPA must provide a prominent, publicly accessible FERPA notice online and a FERPA opt out form online at a minimum. This information should be made available online on an ongoing basis all year. Ideally, this notice will be viewable on multiple types of devices, including mobile phones. Ideally, FERPA opt outs can be viewed, filled out, and submitted via online and mobile means.
  • The Department of Education, State educational agencies, local school boards, and educational institutions need to review and revise FERPA notice and opt out methods for accessibility and inclusiveness and for all students and parents, across delivery methods from online to offline, inclusive of mobile, audio, and multiple forms (and languages) of notice.
  • Educational institutions covered under FERPA must allow for student opt out on an ongoing basis and not just in the beginning of the school year or upon enrollment.
  • Educational institutions must stop brokering student directory information to data brokers, or allowing passive collection of student directory information by data brokers.
  • Educational institutions should adopt a minimum necessary rule when deciding which kinds of data to designate as FERPA directory information.
  • All FERPA-covered institutions should conduct a safety and privacy review prior to designating categories of information as directory information.
  • There should be an express prohibition on the use of photographs of minors released by schools without prior consent under the directory information exemption for training face recognition or biometric systems. This includes yearbooks made using facial recognition. Schools should require yearbook companies using facial recognition in their process to never sell or share that information, and should require specific consent for the use of facial recognition.
  • Schools using “platforms” or student information systems, must provide publicly available FERPA annual notices, opt outs, and other information outside of those systems in a way that is accessible to members of the public, including via online access.

Report Acknowledgements →

With thanks to the research team at WPF who contributed significant amounts of time over the course of four years to the detailed and extensive research and fact-checking that went into this report.

Thanks to Jack Bolen, WPF Research Fellow, who assisted with research, fact checking and also aspects of integrated student information systems.

Thanks to the legal, educational, technical, and policy experts who contributed their time and knowledge to this report. Among them, particular thanks to Robert Gellman, Professor Jane K. Winn, Timothy Sparapani, and Professor Joel Reidenberg.

We want to further acknowledge Fordham University School of Law Professor Joel Reidenberg for his decades-long work on student privacy. His work, and those of his colleagues at Fordham CLIP, have created greater transparency in challenging areas of research. Their work created a path that facilitated the research conducted for this report.

We thank the state of Vermont for leading the nation in passing a data broker registry law that requires disclosure of the brokering of the data of minors. Without this law, and without the specific provisions that makes brokering the data of minors more transparent, WPF would not have learned about significant data broker activities regarding student directory information and the data of minors.

This work was supported by a grant from the Kaplan Foundation and an individual grant from S. Kaplan. We thank them for their support of this project.

About the World Privacy Forum →

The World Privacy Forum1 is a non-profit public interest research and consumer education group focused on the research and analysis of privacy-related issues and consumer education. The Forum was founded in 2003 and has published significant, groundbreaking privacy research and policy studies, including major multi-year research studies. Among these include Medical Identity Theft: The information crime that can kill you, the first public report on medical identity theft, The Scoring of America, the first major report regarding predictive analytics and privacy, and A Failure to Do No Harm, India’s Aadhaar biometric ID program and its inability to protect privacy in relation to measures in Europe and the U.S., a multiyear peer-reviewed report regarding large scale identity and biometric systems, published in Springer-Nature and co-published at the Harvard-based Technology Journal. Each of these reports has had significant, demonstrable, and positive real-world impacts on consumer privacy.

WPF engaged substantively in the 2008 and 2011 FERPA rulemakings and the 2015 Department of Education’s Dear Colleague letter2 on student health privacy at institutions of higher education. WPF maintains educational material about student privacy, the Family Educational Rights and Privacy Act, and material about the intersection between health privacy law and student privacy law See: A Patient’s Guide to HIPAA, the Student Privacy 101 series, and additional materials at www.worldprivacyforum.org.

1 World Privacy Forum’s home page includes information about our activities, as well as numerous privacy research, data visualizations, and data privacy resources. Available at: https://www.worldprivacyforum.org.

2 World Privacy Forum Letter to DOE regarding Dear Colleague Letter about student health privacy, October 1, 2015. Available at: http://www.worldprivacyforum.org/wp-content/uploads/2015/10/WPF_comments_Edu_Medprivacy_Guidance_30Sept2015_fs.pdf. Final, Dear Colleague Letter to School Officials at Institutions of Higher Education, U.S. Department of Education, Aug. 24, 2016. This letter is “significant guidance” per OMB Good Guidance Practices. Letter available at: https://studentprivacy.ed.gov/sites/default/files/resource_document/file/DCL_Medical%20Records_Final%20Signed_dated_9-2.pdf.

Methodology for this report →

This report focuses on the privacy of student directory information at FERPA-covered educational institutions, and on students’ ability to learn about and effectuate their FERPA rights. WPF conducted a detailed, multi-year research study on FERPA and directory information-related issues at more than 5,000 primary and secondary schools in 101 U.S. school districts. At the postsecondary level, we studied 102 postsecondary schools in the U.S. The methodologies for the selection of the schools and other aspects of this research are detailed in the appendices of this report.

This report studies implementations of FERPA in regards to student directory information, and examines key risks to student privacy relative to directory information, and what practices or changes would create improved privacy outcomes for students. Because this is not a compliance report, in reporting and discussing the results of our work we have reported our data in aggregate form without identifying schools by name. If and when we identify a specific school in the main report text by name, it is because we are using one or more practices of that school as an exemplar of a good practice.

For some of the results for primary and secondary schools, we have reported results at the district level. When we have done this, it is to understand district-level policies between urban and rural school districts, and in some cases to balance the statistical effects of very large urban school districts on the results in total. For example, some large urban school districts may have 1,000 or more schools. A rural district may contain 50 or fewer schools. We have listed the primary / secondary schools studied in an appendix of this report for transparency. We have not listed the roster of postsecondary institutions we studied, as we were unable to provide results for postsecondary institutions at a high enough level of aggregation to de-identify the results.


Part I: Introduction and Background

A. Introduction →

The first major student privacy law in the United States emerged not from theoretical discussions of potential privacy harms to students, but from bare-knuckled necessity. Parents and students were experiencing serious privacy harms directly related to students’ records held by schools. Some of these harms can be seen in Diane Divokey’s 1974 testimony as she explained to Congress why the Family Educational Rights and Privacy Act was desperately needed:
“It all started innocently enough back in the 1820s, when schools in New England began keeping registers of enrollment and attendance. In the 180-odd years since, the student record has grown to grotesque proportions. Like Frankenstein’s monster, it now has the potential to destroy those it was created to protect.</px-3 Blockquote> … by 1970, almost any government agent could walk into a school, flash a badge and send a clerk scurrying to produce a file containing the psychiatric and medical records of a former student. It was unlikely that the student would even know about the intrusion into his private life.”3</px-3 Blockquote> The federal student privacy law that Congress crafted to address these problems that existed in 1974 is still in place today. This law, the Family Educational Rights and Privacy Act (FERPA), gives parents and students three key rights: the right to access educational records, the right to amend records, and they give students a third right, which is to restrict disclosure of information known as directory information. FERPA requires that sensitive information held in a school record may not be disclosed without prior consent. But schools can choose to publicly release certain categories of information about students without prior consent. This type of student data is called directory information.

What constitutes directory information does not adhere to a specific national list of data types. Rather, it is decided at the local level because schools have been given broad discretion to designate the categories of information they may disclose or release as directory information. The FERPA rules contain a simple test: directory information cannot be considered harmful if it is disclosed, nor can it be considered an invasion of privacy if it is disclosed.

The research for this report found that some of the types of information schools can — and have — designated for unconsented public disclosure include full legal name, exact date of birth, email address, phone number, grade or level of study, photographs, social media handles, videos, a physical or home address, gender, weight, original country and city of birth, and primary language spoken, among other data. Some of the information categories schools designate as directory information are considered sensitive by modern privacy standards. That information, such as precise home address and exact date of birth can pose meaningful safety4 and privacy risks to students and parents. For vulnerable students, such as those who are victims of crime or at risk in other ways, the risks of harm from disclosure are even more significant.5

Further, in 1974 there were no websites, and web “scraping” did not exist.6 Now, even information that could be considered to be acceptable to release as single data points, such as a students’ school email address, when scraped and used by data brokers, can become part of a lifelong profile of a student. And photographs posted publicly can and have been scraped and have become part of test databases for biometric systems, and in some cases products that are sold commercially, presenting an additional risk for minor students whose photographs are published on the open web by schools.7 Few schools, parents, or students would expect their innocently posted images of students participating in school activities to be used in this way.

The most recent updates to the FERPA regulations date from 2011, which in digital years is a significant amount of time. Many advances in privacy standards and law occurred since 2011, and some of these changes represent a turn of historic significance. In 2011, 78 countries around the world had significant national data privacy laws. In 2020, this number is now 142.8 The privacy laws include Europe’s globally influential General Data Protection Regulation, which reframed definitions of privacy, expanded individuals’ data rights, and added to the obligations of data controllers. Today, a set of ten minimum standards are recognized internationally, including accountability, access, correction, and purpose specification, among others.9

These advances in privacy standards, when combined with the rapid and ongoing evolution of computing techniques, structure and speed of digital architectures and data flows, combined with tools for information analysis such as machine learning, are comparable to the difference between driving a Model T and driving a Jaguar. What constituted appropriate implementation policies under FERPA in 2011 are insufficient today because those policies — even if complied with fully — leave students vulnerable to the privacy threats that FERPA sought to protect.

The world has changed, and it is essential that educational institutions and agencies modernize FERPA implementations so as to bring FERPA forward into the current era of data as predictive power and digital complexity.10 This study is not about whether or not schools comply with a minimum baseline of FERPA compliance as stated in 2011. Most do. This study asks the question: can parents and students readily effectuate their rights under FERPA in modern ways? Are schools actively facilitating students’ use of their FERPA rights?

It is entirely possible for an educational institution to comply with FERPA by doing the bare minimum. A FERPA notice can be given on paper, which is acceptable under FERPA. And parents and students may only have a few weeks each year to turn in a FERPA opt out11 form restricting disclosure. This is acceptable under FERPA. Schools may ask parents and students to write their own opt out letter. This, too, is currently acceptable under FERPA. Almost all schools take steps to comply with FERPA baseline standards, what this report calls “FERPA default settings.” However, what is most needed is to understand how schools are doing “FERPA plus settings.” These are implementations of FERPA that are modernized and do more to provide an environment that nurtures the flourishing of FERPA privacy rights.

FERPA’s rights serve institutions, agencies, students, parents, and teachers, and the rights FERPA confers to students and parents are more meaningful today than ever. FERPA gives students and parents three key rights:
Right of Access (Inspect and Review). Parents of students and eligible students12 have the right to access their educational records held by educational institutions and by State educational agencies.13</px-3 Blockquote> Right to Correct Records (Request Amendment(s)). Parents and eligible students can challenge the content of their educational records and to seek to amend records.</px-3 Blockquote> Right to Restrict Release of Records. Parents and eligible students can elect to restrict the release of their educational records to third parties, with some exceptions.14</px-3 Blockquote> Of these rights, this report focuses on the right under FERPA to opt out of, or restrict, the release of directory information by parents and eligible students. Students, or for those under 18, their parents, can elect to opt out of the sharing of directory information. However, opting out requires a supportive environment from school educators that fosters meaningful notice in the current digital environment, expanded access to information about how to opt out, and the modeling of dignity and respect as institutions create a culture of respectful, modernized FERPA opt out implementations.

Educators have a general obligation to do no harm in the area of student privacy, and to create a safe place for student flourishing by modeling the behavior they most want to see in their students. If the goal is fostering students who respect the dignity of others, then educators must themselves show respect for student dignity. This includes nurturing the dignity that students garner when students are able to exercise their rights to make choices about their information appropriate to the context of their lives. By supporting these processes, educators and students can achieve the results both seek.

To understand and document “modern FERPA plus settings” for implementations with respect to directory information opt out, this report analyzed multiple aspects of FERPA directory implementation activities across approximately 5,000 schools at the primary, secondary and postsecondary levels in both urban and rural areas.15 To conduct this analysis, the report looked at aspects of “FERPA plus” implementation that would meaningfully allow parents and students of today to effectuate their rights, including the availability of FERPA notice and opt out online, and other specific aspects of implementation. The research took over four years. The methodology in Appendix C describes the efforts made to sample a diverse array of schools, and to document FERPA implementations.

Activities ranged from analysis of web sites, to emailing schools, to calling schools and talking with faculty and staff. Additional activities included relevant literature searches, interviews with legal and other experts, and discussions with educators about problems and potential solutions.

The goals of this report include identifying the baseline presence of FERPA “default settings” and then in particular, to do the following:
(1) Identify and report on FERPA settings regarding modern, updated directory information implementation settings, challenges, and opportunities; and,</px-3 Blockquote> (2) Identify the best practices (or modern FERPA settings) that will assist schools, protect people, and protect privacy.</px-3 Blockquote>

Findings

Context for the findings

This report is not a compliance report. This report does not look at all of FERPA; rather, this report is focused on directory information. We began our research with baseline documentation of FERPA “default settings” as a starting point for our deeper research regarding student privacy and impacts of directory information data flows.

As a baseline, our research found that approximately 95 percent of studied schools studied met FERPA minimum requirements for directory information notice. This is FERPA’s “default setting,” and it means that schools must do a prescribed bare minimum of providing appropriate notice about FERPA at least once per year and provide a way for parents or eligible students to submit a directory information opt out request. The methodology in Appendix C describes the research we undertook to document this initial baseline.

Key Findings

Key findings in the research of more than 5,000 schools regarding modern FERPA implementation practices found that:

Overall findings:

While some states have enacted laws to better protect students and their privacy, almost all policymakers have left a formidable front door open: that is, the ability for detailed student information to be made public by schools under FERPA Directory Information exemption. When schools choose to, they can designate certain student information to be made public without prior consent. This information is directory information, and to provide a balance to this right, Congress included a right for students and parents to opt out of unconsented public disclosure of their information.

  • It is completely possible for schools to meet the FERPA minimum standards for FERPA notice and at the same time make FERPA opt out difficult or undesirable for students and parents.
    • FERPA is not being consistently implemented in modern, updated ways at schools.
    • There is high variability of how schools are implementing FERPA to the point that there is considerable inconsistency in implementation.
    • The information designated as directory information by many schools can, in our modern world, be invasive of privacy and cause harm. Exact date of birth, home address, gender, and photographs of students released as public information is longer acceptable and poses demonstrable risk to students.
    • Few schools have developed a culture of fostering and promoting students’ rights under FERPA to opt out of directory information sharing.
    • WPF research documented a troubling pattern of the brokering of information of minors online. In one case, a company registered as a data broker acquired student directory information. In another, a facial recognition company disclosed it had been collecting the publicly available images of minors for use in its product. Among the data brokers that said they “have actual knowledge that it possesses the brokered personal information of minors,”16 two companies said they used the information of minors to create predictive scores regarding their parents.
    • Language that schools use to communicate with students and parents about FERPA is not always encouraging of pro-privacy choices, and may contain negative nudges that discourage parents and eligible students from opting out.
  • WPF research found best practice exemplars of modern FERPA implementations at all levels. These best practices have the hallmarks of modern privacy thought, which is a focus on implementing FERPA in a way that creates transparency, accountability, fairness, equality of opportunity to opt out, and an environment that supports student privacy, safety and student thriving.

Specific findings:

  • At the primary and secondary level, 39.7 percent of 5,145 schools studied post a FERPA opt out form online that is available to the public. (Total aggregate).
  • At the postsecondary level, 60 percent of 102 postsecondary schools studied post a FERPA opt out form online that is available to the public (Total aggregate)

    51 percent of primary/secondary schools posted some form of annual FERPA notice online in a way that was available and accessible to the public. Accessibility varied depending on what format and area of the website the notice was in.

    98 percent of postsecondary schools posted an annual FERPA notice online in a way that was available and accessible to the public.

  • An analysis of FERPA opt out forms, when available, indicate that many of the forms contain “nudges,” or language that discourages a pro-privacy choice.
  • Time allowed for opt out varies considerably between K-12 and postsecondary schools. Most postsecondary schools typically offer FERPA opt outs all year. Most Primary and secondary schools typically offer 1 to 2 months for parents to opt out. Specifically:
    • At the primary / secondary level, parents have an average of just 1 to 2 months to opt out of directory information sharing. The shortest opt out time our research found was 10 days, and the longest was 90. Most schools offer between 30 to 45 days at the beginning of the school year.
    • Greater than 90 percent of postsecondary institutions allow for FERPA opt out to be turned in and effectuated during the entire academic year.
  • Some students’ FERPA directory information that has not been restricted by a FERPA opt out is being brokered. There is a provable, direct link to data broker activities regarding student directory information.
  • 49 percent of schools include student photographs in directory information that can be released without consent. The risks that can be associated with the public release of student images or digital photographs are discussed in detail in three sections of the report: the Directory Information Content, Data Brokers and the Data of Minors, and the Student Biometric Data and FERPA sections. In brief, allowing student photographs to be included as directory information poses a significant risk for “web scraping” of the images for use in face recognition systems, a risk that our research has documented is already occurring. Beyond this risk, the unconsented release of student images by schools can also pose safety and other privacy concerns to parents and students.
  • The research found that categories of information designated as directory information by schools studied for this report often contain information that is in fact privacy sensitive and consequential. The research found high variability of what schools elect to include in directory information.
    • The research found the following specific categories of student data studied schools designated for unconsented disclosure under the FERPA directory information rules. (Not all schools used all of these information categories. This is an aggregate of all fields found in the research.)
    • Name of student
    • Gender
    • Date of birth
    • Date and place of birth
    • Hometown, city, and state
    • Primary language spoken
    • Social media handles
    • Local address
    • Permanent home address
    • Residence Hall address
    • Address of parents or guardians
    • Telephone listings Student email addresses
    • Telephone number and email address of parents or guardians
    • Student email addresses
    • Student employee telephone listing
    • Dates of attendance
    • Withdrawal dates
    • Program / major field of study
    • Degrees and certificates received / dates
    • Academic and co-curricular awards, honors, and scholarships, and dates received
    • Number of hours enrolled and number completed
    • The most recent educational institution attended
    • Participation in officially recognized activities
    • Weight and Height of students on athletic teams
    • “PeopleSoft number”
    • Student ID number, user ID or other unique identifier
    • Student’s district identification number
    • Photograph(s)
    • Electronic images
    • Digitized photo
    • Class photo
    • Videos
    • Photographs or recordings of students taken by surveillance cameras where the images do not depict specific students engaging in actions that would constitute violations of the Code of Student Conduct
    • Yearbook pictures
    • Annual yearbook print copies, playbills, program guides, or recordings of school sponsored events
    • Student employee telephone listing
    • Student employee job classification
    • Student employee email address
    • Student positions held
    • Nature and place of employment
    • Nature and place of employment at school Yearbook pictures
  • The research found that platforms in use at some schools – especially at the K-12 level — did not actively facilitate the public’s ability to learn about a school’s FERPA policies. However, the research also found that some platforms facilitated improved FERPA implementations. This was particularly the case at the postsecondary level.
    • Some of the schools used platforms that produced no results for a site-wide keyword search for FERPA. (Without login).
    • When FERPA notices are not posted on publicly available pages, it does not facilitate effective modern FERPA notice, nor does it assist in facilitating students’ and parents’ exposure to and knowledge about FERPA rights.
    • Some platforms, especially some of the best practice exemplars at the postsecondary level, have used technology to provide more effective, more granular FERPA opt out in the student information systems as well as on the school’s publicly available web pages.

The findings for this report are extensive. Part II of the report discusses the above findings in detail as well as additional findings.

Recommendations

Some FERPA implementation problems could be addressed by simple solutions, such as adding permanent, prominent, and publicly available links to FERPA notices and opt out forms, and ensuring that FERPA opt out forms in particular are on prominent and publicly available positions on websites.

Other aspects, such as creating a culture that respects the dignity of students and supports students’ and parents’ efforts to achieve better privacy and safety results, will take more effort. This report unambiguously documents problems with FERPA that can have real-world impacts. There is urgency in addressing these problems cooperatively. Schools must do more to protect students’ privacy, ensure their safety and wellbeing, and prevent uses of student data that parents and students find objectionable, unsafe, or harmful, or that impedes their ability to attain educational and other goals. Ultimately, good results in privacy depend on a culture at the school level that fosters respect for privacy and a culture that values the protections students have under FERPA.

Based on the extensive research of more than 5,000 educational institutions from K-university conducted for this report, and the significant FERPA implementation gaps documented, this report offers the following recommendations:

  • Educational institutions covered under FERPA must provide a prominent and publicly accessible online FERPA notice and a FERPA opt out form at a minimum. These materials should be made available to the public in an easy to find and openly accessible location on the school’s public-facing website irrespective of whether FERPA information is also available on a student portal or technology platform. It is not acceptable for institutions to only publish FERPA materials behind registration requirements or on password protected systems.
    • Institutions that still hand out paper FERPA forms should work to also post FERPA materials to a permanent, prominent site open to the public. Paper forms should be available in a well-understood place, and schools should conduct an assessment of FERPA implementation to ensure that vulnerable and marginalized students and parents can still access, effectuate, and benefit from their FERPA rights.
  • Students and parents who are non-English speakers should have materials accessible to them in their language.
  • Ideally, each FERPA-covered institution should provide a FERPA opt out form in multiple formats for parents and eligible students: paper, electronic, call in, etc.
  • Each FERPA-covered institution should provide all students with FERPA notice and opt out that is readily accessible, including making available accessible via mobile device quickly and without undue searching. It is important to address the needs of parents who are financially vulnerable or vulnerable in other ways. Not all parents or students will have access to a computer, but many will have access to a mobile device of some sort.
  • It is important that schools provide FERPA opt out forms. Those opting out under FERPA should not have to write a letter from scratch to do so. This is a well-established principle in other areas of consumer protection law.
  • FERPA opt out forms should allow students the opportunity and option of selecting what specific information types they want to have restricted. Students should not have to have an all-or-nothing FERPA choice. For example, students should be able to allow a yearbook photo to be taken and at the same time have the ability to restrict their home address from being published. More “granular” choices are preferable to just a single selection that opts students out of all data sharing.
  • Educational institutions covered under FERPA must allow for student opt out on an ongoing basis and not just in the beginning of the school year. Information privacy problems can pose serious safety threats to students. It is neither appropriate nor safe to require students to wait, in some cases, for up to a year to opt out.
    • This report found that some educational institutions do in fact offer a yearlong, continuous opt out. However, many institutions offer only a 2 to 3 week window per year for opting out of unconsented disclosure of directory information. This is not an appropriate policy in today’s digital ecosystems. Asking students to wait a year to restrict the dissemination of their information is similar to asking identity theft victims to wait a year before they get credit monitoring, or get a new credit card.
  • Educational institutions should adopt a minimum necessary rule when deciding which kinds of data to designate as FERPA directory information.
  • All FERPA-covered institutions should conduct a safety review prior to designating categories of information as directory information. This safety review should incorporate views from law enforcement professionals, survivors of crimes such as identity theft as well as domestic violence, sexual assault, and stalking, and other stakeholders who have a viewpoint on what information is dangerous if released about them, in the context of their lives. The Department of Education should conduct one or more safety review workshops with stakeholders and provide the results to educational institutions.
  • The Department of Education should determine a standard name for FERPA notices and opt outs, and require that schools use these names. FERPA annual notices and opt out forms should be consistently named and have a consistent structure so that students, parents, and educators can more readily understand where to locate resources online and off.
  • Educational institutions must stop brokering student directory information to data brokers.17 This is a significant gap in student privacy protection. We are aware of one state education department that has put rules in place that prohibit the sale of student information. This is an appropriate and beneficial structural protection for student data that restricts data flows from the school side. It is crucial that these restrictions also apply to directory information.
    • Educational institutions must also have strict policies and procedural protections in place that prevent disclosure of student directory information that is subject to an opt out to any third party.
    • States that have passed or are considering passing a data broker registry statute should include language about the information of minors in the registry’s requirements. Data brokers should be specifically required to answer the question of if the company has had “actual knowledge that it possesses the brokered information of minors.”
  • Congress, the FTC, state legislatures, States Attorneys Generals, and the Department of Education should work together to create a do-not-broker procedure, list, or rules that ensure that student directory information does not go to data brokering activities.
  • Schools should no longer designate photographs or any images of students as directory information. Photos and videos of students pose safety risks to some students. Publicly available images of students on school web sites and elsewhere can and already have been collected by commercial companies and used in biometric and face recognition systems.
  • There should be an express prohibition on the use of student photographs for training face recognition systems by anyone. Schools that designate minor students’ photographs as directory information need to restrict those photographs from becoming available to third parties to “scrape” or otherwise utilize in training databases for biometric systems. Also, school yearbook companies that utilize facial recognition should only do so with express prior written consent, and schools should ensure that yearbook companies cannot keep or share any facial recognition templates with any other third parties.
  • Schools using “platforms,” better described as integrated student information systems,18 must provide publicly available FERPA annual notices, opt outs, and other information outside of those systems in a way that is accessible to members of the public.
    • Schools that are using a student platform need to assess the platform implementation for the availability, prominently on the school’s home page, links to FERPA annual notices and FERPA opt out forms as well as other information about FERPA for parents and students. This information needs to be posted in a way that is available to the public, including prospective parents who do not have password access to the platform contents.19
    • No student or parent should ever be asked to waive their FERPA rights by a vendor or a platform in order to view a FERPA annual notice. FERPA notices and opt outs should be made publicly and prominently available without any registration requirements by vendors or platforms.
    • Any schools using platforms must be mindful of student and parent vulnerabilities from health-related, socioeconomic and other vulnerabilities.
  • The Department of Education needs to craft a new policy regarding appropriate methods of giving FERPA notice to incorporate modern methods. For example, web sites and mobile phones.
  • The Department of Education should encourage accessible methods of FERPA notice that include people who may, for example, have low or no vision, or other challenges that would prevent or hinder them from accessing a FERPA notice or opt out form, including lack of technology.
  • DoED should require schools to provide paper and publicly available electronic versions of FERPA forms to promote accessibility and transparency.
  • The Department of Education should review its own FERPA model notice and other guidance materials for “negative nudges” that may encourage parents or students to not choose privacy and safety protective options.
  • The Department of Education needs to urgently review the categories of information that may be considered for inclusion in directory information. The current categories do not fit the test of no harm and no invasion of privacy. Several categories must be struck from the list and others should be considered for addition. While perfection in policy is not obtainable, the Department must think through the lifetime consequences for the release of home address, exact place and data of birth, and other categories. Photographs of students, including minors, under the directory information rules, can be repurposed without prior consent; for example, for biometric face recognition testing and inclusion in test databases or functional databases. Many parents and students would be likely to object to this use. While biometric templates held by the school may not be released under the current rules without consent, there is nothing to prevent photographs designated as directory information from being repurposed after disclosure, for example, in biometric products. This is not a “science fiction” scenario, it is already happening.20 The Department of Education has a responsibility to think through the more modern risks to information of students and to take appropriate action.

3 Diane Divokey, Cumulative Records: Assault on Privacy,” 120 Congr. Rec. 36,528, 36,529.

4 WPF receives phone calls and requests for assistance from students and parents who have been impacted by domestic violence and other crimes that pose privacy and safety risks. Under FERPA, a spouse cannot acquire the educational records of a student without prior consent. But if a school has designated a student’s or a parent’s or guardian’s home address as directory information, prior consent is not required for the release of that information. The disclosure of home address information can and has put victims and survivors of crime at great risk of harm. This type of risk is critically important for schools to address. See Protecting Student Privacy, Frequently Asked Questions. U.S. Department of Education. Available at: https://studentprivacy.ed.gov/frequently-asked-questions.

5 Students can experience many types of vulnerabilities, including financial vulnerability. Too little attention is paid to the sobering fact that students in Kindergarten, 1st, 2nd, and 3rd grades are most likely to experience homelessness. Out of 1,351,120 homeless students in the U.S. in 2016-2017, fully 460,937 of these students were in grades K-3. Parents of these students will be the ones who have to exercise FERPA rights. People who live in poverty have equal privacy rights under FERPA, and both deserve and need assistance and consideration in effectuating those rights. For a discussion of privacy and poverty, see: John Gilliom, Overseers of the Poor, Surveillance, resistance, and the limits of privacy. University of Chicago Press, 2001. More information available at: https://www.press.uchicago.edu/ucp/books/book/chicago/O/bo3626685.html. For statistics, see also: Digest of Education Statistics, NCES. Available at: https://nces.ed.gov/programs/digest/d18/tables/dt18_204.75a.asp.

6 Web Scraping is the use of technological tools for automatic extraction and organization of data from the Web for the purpose of further analysis of this data. (Krotov and Tennyson 2018.) See: Vlad Krotov and Leiser Silva, Legality and Ethics of Web Scraping, Emergent Research Forum (ERF), Twenty-fourth Americas Conference on Information Systems, New Orleans, 2018. Available at: https://aisel.aisnet.org/cgi/viewcontent.cgi?article=1073&context=amcis2018.

7 At least one company has disclosed that it has collected the images of minors for use in a facial recognition system. See: Filing of Clearview AI, Registration ID 367103, January 14, 2020, Vermont Data Broker Registry. Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367103. See: Response to Question 7: “Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.”

8 Graham Greenleaf, Global Data Privacy Laws 2019: 132 National Laws & Many Bills February 8, 2019. 157 Privacy Laws & Business International Report, 14-18. Available at SSRN: https://ssrn.com/abstract=3381593. Note: The 142 figure arrived at by the additions in 2019 of privacy laws in Barbados, Botswana, Congo-Brazzaville, Kenya, Nigeria, Tajikistan, Togo, Turkmenistan, Uganda, Uzbekistan. As of 2020, India has laid its Data Protection Bill before Parliament, and Thailand is in the process of passing its data protection bill. The bills in the 142-member list are those bills, which meet the minimum 10-point standard.

9 In modern global data privacy laws, there are 10 key commonalities that form a new global baseline for what is considered by scholars to be baseline “strong” data privacy legislation. These commonalities arise from standards developed by the European Union, the Council of Europe, the OECD, and APEC. The ten ‘global’ elements that are common to all four international instruments are, as quoted in Greenleaf:

1. Collection – limited, lawful and by fair means; with consent or knowledge (OECD 7; CoE 5(c), (d)), 2. Data quality – relevant, accurate, up-to-date (OECD 8; CoE 5(a)), 3. Purpose specification at time of collection (OECD 9; CoE 5)), 4. Notice of purpose and rights at time of collection (OECD ambiguous; APEC stronger; CoE not explicit but implied), 5. Uses limited (including disclosures) to purposes specified or compatible (OECD 10; CoE 5(b), 6. Security through reasonable safeguards (OECD 11; CoE 7), 7. Openness re: personal data practices (OECD 12; CoE 8(a)), 8. Access – individual right of access (OECD 13; CoE 8(b)), 9. Correction – individual right of correction (OECD 13; CoE 8(c), (d)), 10. Accountability – data controllers accountable for implementation (OECD 14; CoE 8). As discussed in: Graham Greenleaf, The Influence of European Data Privacy Standards Outside Europe: Implications for Globalisation of Convention 108 (October 19, 2011). International Data Privacy Law, Vol. 2, Issue 2, 2012; UNSW Law Research Paper No. 2011-39; Edinburgh School of Law Research Paper No. 2012/12. Available at SSRN: https://ssrn.com/abstract=1960299. See also, Robert Gellman, Fair Information Practices: A Basic History (updated occasionally), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2415020.

10 This report and its supporting research focused specifically on directory information. Additional meaningful risks to student privacy exist. Essential reading regarding these additional risks includes: Elana Zeide, The Structural Consequences of Big Data-Driven Education, June 23, 2017. Big Data, Vol 5, No. 2 (2017): 164-172. Available at SSRN: https://ssrn.com/abstract=2991794. See also: Douglas MacMillan and Nick Anderson, Student tracking, secret scores: How college admissions offices rank prospects before they apply, Washington Post, October 14, 2019. Available at: https://www.washingtonpost.com/business/2019/10/14/colleges-quietly-rank-prospective-students-based-their-personal-data/. See also: Natasha Singer, For Sale: Survey Data on Millions of High School Students, New York Times, July 29, 2018. Available at: https://www.nytimes.com/2018/07/29/business/for-sale-survey-data-on-millions-of-high-school-students.html.

11 Opt out or opt-out? Initially, this report hyphenated “opt out” when the term was used to modify a noun, and generally did not hyphenate otherwise. Parents have the right to opt out using an opt-out form is an example use. While this is technically correct, we received feedback from some reviewers that the hyphenation changes were a distraction in a long report that uses the term “opt out” repeatedly. In response, we have opted to use opt out without hyphenation throughout for consistency and ease of reading.

12 FERPA rights fall to the parents or guardians of children under the age of 18. At the age of 18, FERPA rights revert to the student. Under FERPA, students 18 and older are “eligible students.”

13 State educational agencies include, for example entities such as State departments of education, for example, the Virginia Department of Education, or the Montana Office of Public Instruction. For more on State educational agencies’ roles, see the Council of Chief State School Officers (CCSSO.) See in particular: The State Education Agency’s Role in Supporting Equitable Student-Centered Learning, CCSSO, November 10, 2019. Available at: https://ccsso.org/resource-library/state-education-agencys-role-supporting-equitable-student-centered-learning.

14 Exceptions to the consent restrictions are set out in §99.31, and include 16 specific exceptions where disclosure of student educational records are allowed without consent.

15 The sampling of the approximately 5,000 schools represents under 1 percent of the approximately105,298 educational institutions that are covered under FERPA.

16 The Vermont Data Broker registration form states: “Does the data broker have actual knowledge that it possesses the brokered personal information of minors? (Yes or No response required.) “If so, provide a statement detailing the data collection practices, databases, sales activities, and opt-out policies that are applicable to the brokered personal information of minors.” See Vermont Data Broker Registry, Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/.

17 One way to identify data brokers is to look at state data broker registration databases. See, e.g., the Vermont data broker registration records, available at https://www.sec.state.vt.us/corporationsbusiness-services/data-brokers.aspx.

18 An integrated student information system is one that manages student records in concert with additional data streams such as school budgetary information, district programs, and more. Integrated systems can be quite large and complex. The largest systems may incorporate dissemination of deidentified student data to requesting institutions. A detailed description of such a system is available at the National Center for Education Statistics, Building an Automated Student Record System, Available at: https://nces.ed.gov/pubs2000/building/desc_system.asp. The U.S. Department of Education has issued guidance on the use of integrated student information systems. Integrated Student Information Systems and Privacy, U.S. Department of Education, Privacy Technical Assistance Center, January 2017. Available at: https://studentprivacy.ed.gov/sites/default/files/resource_document/file/IDS-Final_0.pdf.

19 WPF notes the importance of the US Department of Education letter to the Agora Cyber Charter School, Nov. 2, 2017. Available at: https://studentprivacy.ed.gov/sites/default/files/resource_document/file/Agora%20Findings%20letter%20FINAL%2011.2.17.pdf. This letter clarifies that students and parents cannot be compelled to waive their FERPA rights by requests from school technology vendors, including platforms. This extends to the status of waiving FERPA rights to information collected at registration. WPF asserts that parents and students should also not be forced to register at a school platform in order to learn of and see the school’s annual FERPA notice, including the specific categories of information it has designated as directory information. FERPA annual notice is important, and should be made publicly and prominently available — without any registration requirements by vendors or platforms.

20 In January 2020, a New York Times article revealed that a facial recognition company, Clearview AI, had scraped in excess of 3 billion images from social media sites. The images were used in a product then sold to law enforcement agencies. There are new implications from the scraping of photographs from social media websites, and also the “open web.” See: Kashmir Hill, The secretive company that might end privacy as we know it, The New York Times, January 20, 2020. Available at: https://www.nytimes.com/2020/01/18/technology/clearview-privacy-facial-recognition.html. See also: Louise Matsakis, Scraping the web is a powerful tool, Clearview AI abused it, Wired, January 25, 2020. Available at: https://www.wired.com/story/clearview-ai-scraping-web/.

B. Background: The Framework of the Family Educational Rights and Privacy Act →

Congress enacted the Family Educational Rights and Privacy Act (FERPA) in 1974 to protect the privacy of students and their parents or guardians.21 Congress amended FERPA nine times since 1974.22 FERPA confers rights to parents when the student is under the age of 18. The rights transfer to students when they turn 18 or enroll in a postsecondary school, thus becoming “eligible students.” The following are FERPA’s key rights:

Right of Access (Inspect and Review). First, FERPA ensures that parents of students and eligible students23 have the right to access their educational records held by educational institutions and by State educational agencies.24

Right to Correct Records (Request Amendment(s)). Second, FERPA allows parents and eligible students to challenge the content of their educational records and to seek to amend records.

Right to Restrict Release of Records. Third, FERPA allows parents and eligible students to restrict the release of their educational records to third parties, with some exceptions.25

FERPA applies to educational institutions and agencies that receive funds under any program administered by the Department of Education.26 In practice, this means that most public elementary and secondary schools and school districts are subject to FERPA, but most private and religious K-12 schools are not subject to FERPA because they generally do not accept federal funding from the Department of Education. FERPA covers most postsecondary institutions such as colleges and universities both public and private, including medical, law, and other professional schools by virtue of the mechanics of Federal student grant and assistance programs.27

The National Center for Education Statistics’ count of U.S. educational institutions yields a total of 98,277 public schools, 34,576 private schools, and 7,021 postsecondary Title IV institutions. Title IV institutions28 are those educational institutions that accept funding administered by the Department of Education, which brings them under FERPA regulations. All totaled, counting just the public K-12 institutions and the postsecondary Title IV institutions, FERPA covers approximately 105,298 educational institutions.29

Number of educational institutions, by level and control of institution:
Selected years, 1980–81 through 2015–16

Level and control of institution

1980–81

2009–10

2015-16

Public schools

85,982

98,817

98,277

Elementary

59,326

67,140

66,758

Secondary

22,619

24,651

24,040

Combined

1,743

5,730

6,788

Other1

2,294

1,296

691

Private schools2

20,764

33,366

34,576

Postsecondary Title IV institutions

6,742

7,021

Degree-granting institutions

3,231

4,495

4,583

2-year colleges

1,274

1,721

1,579

4-year colleges

1,957

2,774

3,004

Figure 1

While the FERPA statute itself is short, the U.S. Department of Education has written extensive regulations implementing FERPA.30 These regulations include a series of rules regarding restrictions of the release of educational records to third parties. Generally, under FERPA, protected information about students is divided into three broad categories: educational records, personally identifiable information, and directory information.

21 The Family Educational Rights and Privacy Act of 1974, 20 U.S.C §1232g; 34 CFR Part 99.

22 For a legislative history of FERPA, see U.S. Department of Education, Legislative History for Major FERPA Revisions. Available at: https://www2.ed.gov/policy/gen/guid/fpco/ferpa/leg-history.html.

23 FERPA rights fall to the parents or guardians of children under the age of 18. At the age of 18, FERPA rights revert to the student. Under FERPA, students 18 and older are “eligible students.”

24 State educational agencies include, for example entities such as State departments of education, for example, the Virginia Department of Education, or the Montana Office of Public Instruction. For more on State educational agencies’ roles, see the Council of Chief State School Officers (CCSSO.) See in particular: The State Education Agency’s Role in Supporting Equitable Student-Centered Learning, CCSSO, November 10, 2019. Available at: https://ccsso.org/resource-library/state-education-agencys-role-supporting-equitable-student-centered-learning.

25 Exceptions to the consent restrictions are set out in §99.31, and include 16 specific exceptions where disclosure of student educational records are allowed without consent.

26 The scope of FERPA has changed over the course of FERPA’s legislative history. When it was first enacted, the scope of FERPA was very broad. A covered entity under the original FERPA statutory language was defined as “any state or local educational agency, any institution of higher education, any community college, any school, agency offering a preschool program, or any other educational institution.” This would have allowed FERPA to cover private schools. The Buckley/Pell amendment was brought forward just four months after the original enactment in 1974. The amendment narrowed the scope of FERPA to an “Educational agency or institution” defined as “any public or private agency or institution which is the recipient of funds under any applicable program.”

27 Educational institutions that receive funding from one or more of the programs under Title IV are covered by FERPA as a whole, even if just a constituent part of the institution receives the funds. 34 CFR §99.1 (d).

28 “Title IV institutions” in this context are those institutions that accept student assistance programs administered by the by the US Department of Education. Title IV is part of the Higher Education Act of 1965, as amended in 1998. Title IV specifies student assistance programs administered by the Department of Education. Title IV, Part A specifies grant programs to students, an exemplar of which is Federal Pell Grants. (Sec. 401). Title IV also covers federal work-study programs, federal Perkins loans, and William D. Ford Federal Direct Loan Programs, among others.

29 U.S. Department of Education, National Center for Education Statistics. (2019). Digest of Education Statistics, 2017 (NCES 2018-070), Table 105.50. The most recent data available is for 2015-2016. The table is available at: https://nces.ed.gov/fastfacts/display.asp?id=84.

30 The U.S. Department of Education, Family Education Rights and Privacy Act (FERPA) Regulations, 34 CFR Part 99. The FERPA regulations were amended in 1988, 2008, and 2011. See 53 FR 11943, Apr. 11, 1988, as amended at 73 FR 74854, Dec. 9, 2008; 76 FR 75642, Dec. 2, 2011.

C. Protected Information as defined under FERPA →

-Educational Records

Schools cannot disclose educational records of students to third parties31 without specific consent unless one of 16 exceptions applies (See below.) Examples of protected student information in educational records under FERPA include student health records, grades, disciplinary notes, assessment tests, and so forth.

In order to be considered “an educational record” under FERPA, The records must be maintained by the educational institution. A record maintained by a student is not an educational record under FERPA. When teachers and administrators discuss FERPA protections, they often mean protections for protected information in educational records. Significant recordkeeping requirements exist regarding requests for and disclosures of personally identifiable information from students’ educational records.32

Exceptions to the requirement of prior consent are nuanced, and are discussed in detail by the Department of Education.33 In appendix D of this report, we provide a complete copy of all of the FERPA exceptions. Some of the key exceptions include:

  • Directory information as defined under FERPA. A school may disclose directory information without consent if it has given public notice of the types of information it has designated as directory information, the eligible student’s right to restrict the disclosure of such information, and the period of time within which an eligible student has to notify the school that he or she does not want any or all of those types of information designated as directory information. Also, FERPA does not require a school to notify eligible students individually of the types of information it has designated as directory information. Rather, the school may provide this notice by any means likely to inform eligible students of the types of information it has designated as directory information.
  • University officials carrying out their specifically assigned educational or administrative responsibilities. A contractor, consultant, volunteer, or other party to whom an agency or institution has outsourced institutional services or functions may be considered a school official under this paragraph provided that the outside party

    (1) Performs an institutional service or function for which the agency or institution would otherwise use employees;

    (2) Is under the direct control of the agency or institution with respect to the use and maintenance of education records; and

    (3) Is subject to the requirements of § 99.33(a) governing the use and redisclosure of personally identifiable information from education records.

  • Appropriate officials in connection with a health or safety emergency.34
  • To authorized representatives of the Comptroller General of the United States, the Attorney General of the United States, the U.S. Secretary of Education, and State and local educational authorities for audit or evaluation of Federal or State supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs.
  • To organizations conducting studies for or on behalf of the school making the disclosure for the purposes of administering predictive tests, administering student aid programs, or improving instruction.
  • To comply with a judicial order or a lawfully issued subpoena.
  • To the victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense concerning the final results of a disciplinary hearing with respect to the alleged crime.
  • To any third party the final results of a disciplinary proceeding related to a crime of violence or non-forcible sex offense if the student who is the alleged perpetrator is found to have violated the school’s rules or policies. The disclosure of the final results only includes: the name of the alleged perpetrator, the violation committed, and any sanction imposed against the alleged perpetrator. The disclosure must not include the name of any other student, including a victim or witness, without the written consent of that other student.35

-Personally Identifiable Information under FERPA:

FERPA prohibits disclosure of personally identifiable information that could create a risk of harm or would constitute an invasion of privacy. Biometric information and Social Security Numbers are specifically prohibited from release without prior written consent. Under FERPA regulations, “personally identifiable information” is defined as including, but not limited to, information that directly or indirectly identifies students.36 As with disclosure of educational records, there are some exceptions that allow release without consent.37

-Directory Information under FERPA:

FERPA treats directory information, the third category of protected information, differently than other types of protected information under FERPA. Directory information means information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. See section D for specific categories of information that can and cannot be designated as directory information.

Schools may designate a subset of students’ educational records as directory information. The information that schools classify as directory information may be publicly released without prior consent from parents of students or eligible students, if certain conditions are met.

In the FERPA regulations, “publicly released” is broadly defined, and includes release of information to any individual or organization other than the student’s parents or eligible student.38 Publicly released directory information is “in the wild,” in that after the school releases it, directory information can be freely republished and redisclosed with no restrictions. Schools must track disclosures of protected information from educational records, and the information disclosed generally may not be redisclosed. However, FERPA does not require that schools to track disclosures of directory information.

31 Education records are defined under FERPA as those records that are (1) directly related to a student, and (2) maintained by an educational agency or institution or by a party acting for the agency or institution. 20 U.S.C. § 1232g(a)(4)(A); 34 CFR § 99.3. What constitutes an educational record has been particularly contentious, and the definition has been subject to extensive litigation. See for example, U.S. Supreme Court, Owasso Independent School Dist. No. I-011 v. Falvo, 534 U.S. 426, Supreme Court of the United States, (2002).

32 FERPA-covered educational institutions must maintain records of each request for access and each disclosure of personally identifiable information from the records of each student. For each request or disclosure, schools must include the names of the parties who have requested or received records, and what the legitimate interests the parties had in making the request. See: FERPA 34 CFR § 99.32. Available at: https://studentprivacy.ed.gov/ferpa-regulations#0.1_se34.1.99_137.

34 An example of a situation that falls into the health or safety FERPA exemption is the COVID-19 pandemic of 2020. For this emergency, the Department of Education issued specific guidance for schools regarding FERPA. See: FERPA and the Coronavirus Disease 2019 (COVID-19), U.S. Department of Education, March 2020. Available at: https://studentprivacy.ed.gov/resources/ferpa-and-coronavirus-disease-2019-covid-19. In Part V of this report, see also the Resources for Parents and Students, which has more information about emergencies and FERPA.

36 Definition of Personally Identifiable Information under FERPA, CFR 34 §99.3

The term includes, but is not limited to—

(a) The student’s name;

(b) The name of the student’s parent or other family members;

(c) The address of the student or student’s family;

(d) A personal identifier, such as the student’s social security number, student number, or biometric record;

(e) Other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name;

(f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or

(g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.

See Appendix D for a full list of the exemptions.

37 Exceptions to the release of student educational records without prior written consent are set out in §99.31, and include 16 specific exceptions.

38 “Publicly released” is defined in FERPA under disclosure. “Disclosure means to permit access to or the release, transfer, or other communication of personally identifiable information contained in education records by any means, including oral, written, or electronic means, to any party except the party identified as the party that provided or created the record.” 34 CFR Part §99.3.

D. What information can schools classify as Directory Information? →

As discussed, directory information means information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. Directory information is typically a subset of information that FERPA includes as “personally identifiable information.”

To reiterate, the definition of “personally identifiable information” under the FERPA 2011 regulations is as follows:

Personally Identifiable Information

  • The term includes, but is not limited to—
    • (a) The student’s name;
    • (b) The name of the student’s parent or other family members;
    • (c) The address of the student or student’s family;
    • (d) A personal identifier, such as the student’s social security number, student number, or biometric record;
    • (e) Other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name;
    • (f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or
    • (g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.39
    • Of this set of personally identifying information described in FERPA, some information is not available to use as directory information. The regulations give a list of allowable directory information, and give educational institutions discretion to add more categories to the list. The following is the most recent regulatory description of what can and cannot be included in directory information:

Directory Information

  • (a) Directory information includes, but is not limited to, the student’s name; address; telephone listing; electronic mail address; photograph; date and place of birth; major field of study; grade level; enrollment status (e.g., undergraduate or graduate, full-time or part-time); dates of attendance; participation in officially recognized activities and sports; weight and height of members of athletic teams; degrees, honors, and awards received; and the most recent educational agency or institution attended.
  • (b) Directory information does not include a student’s—
    • (1) Social security number; or
    • (2) Student identification (ID) number, except as provided in paragraph (c) of this definition.
  • (c) In accordance with paragraphs (a) and (b) of this definition, directory information includes—
    • (1) A student ID number, user ID, or other unique personal identifier used by a student for purposes of accessing or communicating in electronic systems, but only if the identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the user’s identity, such as a personal identification number (PIN), password or other factor known or possessed only by the authorized user; and
    • (2) A student ID number or other unique personal identifier that is displayed on a student ID badge, but only if the identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the user’s identity, such as a PIN, password, or other factor known or possessed only by the authorized user.40

FERPA attempts a difficult balancing act with its approach to differentiating personally identifiable information and directory information. In today’s data ecosystems,41 it is difficult to persuasively argue that the information FERPA allows for inclusion in directory information is without “risk of harm” in today’s world and its digital ecosystems. This is particularly true of full name, street address, photos and videos, and home address. See the section of this report regarding data brokers.

39 20 U.S.C. 1232g; 34 CFR Part 99.3.

40 20 U.S.C. 1232g(a)(5)(A).

41 An excellent discussion of modern ecosystems in the school setting is Elana Zeide, The Structural Consequences of Big Data-Driven Education (June 23, 2017). Big Data, Vol 5, No. 2 (2017): 164-172. Available at: https://ssrn.com/abstract=2991794. “Technological mediation and data-driven decision-making have a particularly significant impact in learning environments because the education process primarily consists of dynamic information exchange. In this overview, I highlight three significant structural shifts that accompany school reliance on data-driven instructional platforms that perform core school functions: teaching, assessment, and credentialing.”

E. FERPA Notices and the Conditions for Public Release of Students’ Directory Information →

Student directory information may be disclosed publicly without consent after certain conditions are met. The key requirement FERPA imposes on schools is that prior to disclosing directory information, schools must give public notice to parents of students and to eligible students, and this notice must be made annually. The notice must contain three specific elements:

  1. What kinds of information the school has designated as “directory information.”
  2. Clear notice that parents or eligible students have the right to refuse or opt out of these types of information as directory information.
  3. The specific time period parents or students have available to notify the educational institution in writing that they do not want all or part of the information designated as directory information. The time allowed must be reasonable for parents or eligible students to submit a FERPA directory information opt out request.

The FERPA notice requirements are specified in the regulations issued by the Department of Education under the FERPA statute. The most recent iteration of the FERPA regulations published in 2011.42

Schools may choose to designate directory information elements, but also and also take an extra step of placing restrictions on the information they have designated as available for disclosure. For example, one institution wrote in its FERPA policy that because date of birth could be considered “somewhat more sensitive to some community members” that the school was going to make reasonable efforts that the date of birth would only be released to “those who have a legitimate need to obtain such information.”

When an educational institution places restrictions like these on directory information, it is called “limiting directory information.” Putting limits on the disclosure of information designated as directory information is up to the discretion of the school. When schools specify some limits on how they disclose directory information, the limit is binding on them.

Under FERPA, the regulations regarding directory information are permissive, which means that schools may release directory information if they want to. But schools do not have to release this information because directory information disclosures are not mandated by the FERPA statute or its associated regulations, with some exceptions.

42 FERPA regulations, 2011. See 53 FR 11943, Apr. 11, 1988, as amended at 76 FR 75642, Dec. 2, 2011.

a) An educational agency or institution may disclose directory information if it has given public notice to parents of students in attendance and eligible students in attendance at the agency or institution of:

(1) The types of personally identifiable information that the agency or institution has designated as directory information;

(2) A parent’s or eligible student’s right to refuse to let the agency or institution designate any or all of those types of information about the student as directory information; and

(3) The period of time within which a parent or eligible student has to notify the agency or institution in writing that he or she does not want any or all of those types of information about the student designated as directory information.

(b) An educational agency or institution may disclose directory information about former students without complying with the notice and opt out conditions in paragraph (a) of this section. However, the agency or institution must continue to honor any valid request to opt out of the disclosure of directory information made while a student was in attendance unless the student rescinds the opt out request.

(d) In its public notice to parents and eligible students in attendance at the agency or institution that is described in paragraph (a) of this section, an educational agency or institution may specify that disclosure of directory information will be limited to specific parties, for specific purposes, or both. When an educational agency or institution specifies that disclosure of directory information will be limited to specific parties, for specific purposes, or both, the educational agency or institution must limit its directory information disclosures to those specified in its public notice that is described in paragraph (a) of this section.

(e) An educational agency or institution may not disclose or confirm directory information without meeting the written consent requirements in §99.30 if a student’s social security number or other non-directory information is used alone or combined with other data elements to identify or help identify the student or the student’s records. Available at: https://studentprivacy.ed.gov/ferpa-regulations#0.1_se34.1.99_137.

F. What Methods Can Schools Use to Make Notice Under FERPA? →

Current FERPA regulations require that schools must provide annual notice to parents and eligible students. The particular means or method of notification is left “to the discretion of each school.” The school may generally provide notice by any means likely to inform eligible students of the types of information it has designated as directory information. The Department of Education allows for group notification of FERPA rights, and does not require that schools notify parents or eligible students individually. The means of notification that have been specifically mentioned in the FERPA regulations include notice through the following methods:

  • A special letter,
  • PTA bulletin,
  • Student handbook,
  • Or a Newspaper article43

These notification methods are just examples. Nevertheless, the Department of Education needs to provide formal, updated guidance regarding FERPA notification that takes into account notification on websites, via electronic mail, or through school platforms or integrated student information systems.

The research results regarding FERPA notices appear in detail in the following section of the report along with best practices to help improve outcomes.

43 “Schools may disclose, without consent, ‘directory’ information such as a student’s name, address, telephone number, date and place of birth, honors and awards, and dates of attendance. However, schools must tell parents and eligible students about directory information and allow parents and eligible students a reasonable amount of time to request that the school not disclose directory information about them. Schools must notify parents and eligible students annually of their rights under FERPA. The actual means of notification (special letter, inclusion in a PTA bulletin, student handbook, or newspaper article) is left to the discretion of each school.” [Emphasis added] US Department of Education, Family Compliance Office Home, Family Rights and Privacy Act, Available at: https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html.


Part II: Discussion of Findings

I. Notice of FERPA Policies →

The mechanics of FERPA rely heavily on the notice component of FERPA. Each year, educational institutions must provide a FERPA notice to parents and eligible students, and this notice must provide three specific elements.
First, notice must provide specific information about what kinds of information the school has designated as “directory information.”</px-3 Blockquote> Second, the notice must clearly state that parents or eligible students have the right to refuse or opt out of these types of information as directory information.</px-3 Blockquote> Third, the notice must declare the specific time period that parents or students have to notify the educational institution in writing that they do not want all or part of the information designated as directory information. The amount of time for opt out must be reasonable.</px-3 Blockquote> Again, it is important to emphasize that schools are given broad discretion as to the mechanics of how they make the notice. For example, schools may provide a notice in a special letter, a newspaper article, a PTA bulletin, or a student handbook, for example. The means of notification are not limited to these forms of notification, however.

The FERPA regulation sets out the requirements for notice.44 The three-part FERPA notice is not a suggestion for covered schools; appropriate and compliant notice must be given. The Department of Education has published Model FERPA Notices, included for reference in Appendix E.

Effective notice is crucial. If parents and eligible students do not receive proper notification that directory information may be released without prior consent, then important protections provided by the statute become moot in practice. The intent of Congress was to provide privacy for parents and students.

We utilized two separate methodologies to understand FERPA notices.

  • First, we undertook an exhaustive search for FERPA notices at the studied schools. We attempted to find a studied school’s FERPA notice no matter how much effort it required. This meant checking web sites, emailing schools, and calling schools and school districts. The reason phone calls were in some cases necessary is because schools may distribute FERPA notice via paper or email. For a small percentage of schools, we were unable to list any result. Some schools refused to talk to us when we called them and requested a copy of the FERPA notice. A very small percentage of schools simply did not have the form, or did not understand what we were asking for.
  • In our second methodology we sought to quantify what a very simple search on the schools’ web sites would find regarding FERPA notice and opt out. We conducted a methodical search of school web sites using specific parameters for each studied school.
    • When a search tool was available for the school and/or district website, we did a keyword search for FERPA and tested for the following:
      • A.) Whether there were search results for “FERPA,” and
      • B.) If there were results, did a search lead to the annual FERPA notice?
      • For this methodology, we did not conduct hours of research in order to find the FERPA forms.
  • When a search tool was not available, we looked on the home page for a link to FERPA.

We give a more detailed description of our methodology in the appendices of this report.

For the research regarding online notice, we analyzed the web sites of educational institutions according to all of the data fields listed in Appendix A and B. It is important to contextualize the research results by noting that nowhere in the FERPA regulations is it specified that educational institutions must post FERPA notice on a web site. It is acceptable for educational institutions to provide the notice on paper, or however the institution sees fit. However, because of the widespread use of online tools today, testing for online versions of the FERPA notice is an important data point.

The purpose of conducting this research is 1) to understand how a modern parent or eligible student would reasonably be able to find FERPA materials on their own; 2) to document in this baseline study the general practices of schools; and 3) to propose improvements. It is a reasonable assumption that students and parents will seek FERPA documentation online as a primary response to acquiring the relevant FERPA information from a school. As such, this research analyzed the online implementation of FERPA.

A. What the Research Found

The research methodologies for FERPA notice included a comprehensive search and a second “simple search” for locating material on school websites as a parent or student might.45

Comprehensive search for notice across multiple posting mediums, including paper:
When utilizing many methods of searching for FERPA notice (comprehensive website searches, website searches at school and district level, and in some cases relevant board of education searches, phone calls, emails), then a majority of educational institutions did provide some form of FERPA notice.</px-3 Blockquote>

  • 98 percent or 100 of 102 postsecondary institutions studied provided annual FERPA notices when a comprehensive search for notice was performed utilizing phone, web, paper and other searches.
  • 97 percent or 5,035 of 5145 primary / secondary schools studied provided annual FERPA notice when a comprehensive search for notice was performed was performed utilizing phone, web, paper and other searches.

Note: One postsecondary school and a handful of primary/secondary schools did not respond to WPF’s queries via phone or other methods.

Comprehensive searches could take anywhere from a half hour to many hours to complete.

We note that while it was important for WPF to conduct comprehensive searches to establish a research baseline, it also became abundantly clear that FERPA notice can be very difficult and time consuming to reacquire if the notice was not also made prominently available online.

Search for online FERPA notice utilizing simple search techniques

Utilizing a “simple search” methodology, we searched for information on school websites regarding online FERPA notice. We found:

  • 51 percent of primary/secondary schools posted some form of annual FERPA notice online.
  • 98 percent of postsecondary schools posted the annual FERPA notice online.

It is important to note the overall influence of school platforms in these results. At the primary and secondary levels, if a large, urban school district was utilizing a platform that did not post FERPA notices, then it could mean that more than 1,000 schools were on that platform and did not post FERPA notices online in a public facing way.

School districts’ choice of platform and how that platform was configured had an effect on the results at the primary and secondary level in particular. Platforms at the postsecondary level generally did not interfere with the presence of public-facing FERPA pages on postsecondary educational sites.

1. At the postsecondary level, 98 percent of schools posted FERPA notice online. Within these results are important distinctions in notice:

  • 2 institutions provided no FERPA notice online, nor opt out forms.
  • 5 institutions provided FERPA notice, but the locations were in difficult locations (student financial aid web pages, how to pay a bill, IT department.)
  • 30 institutions provided FERPA notice online, but not an opt out form.
  • 8 institutions provided exceptionally clear FERPA notice online, but no opt out form.
  • 35 institutions provided very clear notice and a FERPA opt out form.
  • 22 institutions provided notice and opt out, but it was unclear, dense, or hard to navigate.

The problematic practices can be grouped into several key areas.

First, problems most typically involved the completeness of the notices. The preponderance of problems involved incomplete information, or information that was disorganized or hard to understand. The problems were not about just complying with FERPA. For example, dense and legalistic language is not a compliance problem. It is a “FERPA-plus” challenge in that the notice was not effective in communicating to students and parents.

  • Missing FERPA policies: Not all schools posted complete FERPA notices or policies online. For example, one state postsecondary school did not provide FERPA notice to students online, although an opt out form was available in the school’s online system.
  • Legalistic language: Some FERPA websites had complete FERPA notices and forms, but they contained dense language that could be difficult for many students to follow. The school technically complied with notice requirements, but the notice was ineffective.
  • Missing links to FERPA forms: One of the most common problems at the postsecondary level was that some FERPA forms were missing. Of the 100 schools that posted a FERPA notice online, 30 did not post a FERPA opt out form online. A key reason schools did not post an opt out form is because the schools directed students to opt out by writing a letter or “notifying in writing” the proper department. A number of schools had a good FERPA page with general information, but the webpages did not link to either withholding or withdrawal forms. Students learned they had rights, but could not easily effectuate them.

From our researchers’ notebooks, some excerpts of bright spots and problems when evaluating FERPA notices online.

  • “Limited information only pertaining to FERPA in the context of paying university bills.”
  • “Very clear pages for both students and staff members on FERPA rights and responsibilities.”
  • “Very obscure location under cost & aid / tuition & costs / student accounts.”
  • “Poorly organized page on IT section of website with minimal relevancy to students.”
  • “Clearly organized FERPA page with student-centric info; needs to have PDF of opt-out form.”

Figure 2. Aggregate of studied postsecondary institutions that make a FERPA opt out notice and a FERPA opt out form available on their web site that is open to the public. No registration is required to view the forms.

Figure 3. Aggregate of studied postsecondary institutions that post FERPA notices or opt outs on, or one click away from, the Registrar page. This research was to understand the role of Registrar pages of postsecondary institutions regarding FERPA information.

2. At the primary and secondary level, the research revealed several challenges regarding FERPA notices. The challenges documented by the research are:

  • Regarding online notification, FERPA notices were often extremely difficult to find on primary/secondary websites. Some school websites had literally no information about FERPA, but extended searches through district-level links tended to uncover FERPA notices posted on the school website and other related websites.
    • Approximately 32 schools posted FERPA policies on a separate Board of Education website.
    • A handful of schools, (<30) posted FERPA notice in a code of conduct.
    • 6 schools had broken links to FERPA notices.
    • In cases where the notice was difficult to find, follow- up phone calls often found that the schools primarily provided either paper or electronic forms to parents once a year. The primary and secondary schools did largely comply with FERPA, but this compliance could be invisible online.
    • Some school platforms had deleterious impacts on the public availability of FERPA notice. Schools that use certain platforms create “FERPA deserts” where literally no information about FERPA can be found through a keyword search or through following links on the public web site. Even if FERPA information is posted behind the password protection, it is not enough. Public-facing FERPA notices are important for parents and students who are looking for school policies around data privacy.
  • Multiple terms, and confusion about the terms: If schools did not use or know the term FERPA or directory information, searching for the relevant notices and opt out information online became extremely difficult. It was a challenge to discuss FERPA in general or directory information in particular with primary and secondary staff members who did not have general knowledge of these terms.
  • Student Handbooks as a notification method: Some primary and secondary schools post FERPA notices in student handbooks. The handbooks are sometimes available online. The FERPA notices tend to be buried in the handbooks even when the handbooks are posted online.
  • Parents asked to write opt out letter from scratch: Some schools ask parents to write an opt out letter from scratch.
    • For example, one school posted a notice that said: “Parents will be given an opportunity to prevent the release of this directory information by filing a written objection with the district.”46 The notice, which was primarily a notice of information designated as directory information, did not include any contact information for parents who might want to file an objection (opt out).

“FERPA Deserts” Can be Created by Poorly Implemented School Website Platforms

Website platforms can be improperly configured and can create “FERPA deserts” where no FERPA information is available on the school website to the public. When this occurs, it is a deeply flawed implementation of FERPA. FERPA policies and notices need to be publicly available on all school websites regardless of website platform or construction.

The websites below are of schools in different states. Both schools are using the same platform.

Middle School (Mid-Atlantic): No Search Results for FERPA on School Website

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Figure 4: This screenshot of an urban Mid-Atlantic middle school website shows the results after a keyword search for FERPA was performed from the home page. There were no results site-wide. This is a problematic implementation of FERPA notice. This school is using the same platform as the high school in the Figure 5.

High School (Northeastern): No Search Results for FERPA on School Website

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Figure 5: In the screenshot above, a rural Northeastern high school website in a different state displays a zero search result to a keyword search for FERPA. No FERPA notices are posted on the school’s public web site. A keyword search displays no content site wide. Clicking through the links also did not turn up FERPA notice.

3. Best Practices:

Postsecondary institutions

  • It is a best practice for the mandatory annual FERPA notice to be posted online in a prominent location year round.
  • Although it is not mandatory per the regulations, we recommend institutions provide FERPA opt out forms online along with FERPA notices.

These two following exemplars highlight key best practices at the postsecondary level.

  • Provide a permanent online repository of policies for the handling of student data, including FERPA. Ensure that all FERPA forms, including opt out, are available on the same webpage. Provide a “One Stop Shop” FERPA hub.
  • Keep responsibility for similar policies in the same office, such as the registrar. There should be a list of school officials who can answer questions from students and parents. The research found that 4/102 postsecondary schools, or less than 1 percent of postsecondary schools, posted detailed FERPA information directly on the Registrar’s site. However, 32 percent, or 33/102 postsecondary institutions posted FERPA information 1 to 2 clicks away from the Registrar’s site. Links from the Registrar’s site could easily become a quasi-standard location for postsecondary schools to post FERPA data. This would provide helpful consistency for students.

A best practice exemplar here is Penn State University, which provides a good, simple form listing relevant data policies on the Registrar’s page.47 FERPA policies are included and are thoroughly described. The FERPA materials include a link to a comprehensive, clear, and well-written document titled University Policy on Confidentiality of Student Records. That document discusses FERPA and other privacy policies, includes names and contact details of school staff who can provide more information, and lists university officials responsible for student records.48 The addition of contact information and responsible parties is helpful for students and parents.

Best Practice, PennState University Registrar’s Page

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Figure 6. PennState adds excellent contextual text about FERPA directory information and links to FERPA annual notices and FERPA opt out forms directly on its Registrar page. This is a best practice exemplar for FERPA notice.

The University of Tennessee, Knoxville, provides another best practice case study for treatment of FERPA materials.49 The university provides the FERPA annual notice, all FERPA forms, explanations of the policies, and the full context for FERPA at a FERPA website. The website provides the kind of rich notice that serves students and parents.

Best Practice, University of Tennessee, Knoxville FERPA and Student Privacy website hub

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Figure 7. The University of Tennessee, Knoxville created a “one stop shop” with prominent labeling, prominent links to FERPA directory information privacy, and additional information. This is another exemplar of a best practice in FERPA notice implementation.

Best Practices:

Primary and Secondary institutions

  • Provide parents, students, and the public with prominent online FERPA notice, and online FERPA opt out forms. In today’s digital world, all FERPA materials online must be available on a public-facing part of the school website. Parents must be able to easily find FERPA materials before they enroll their children in a school. If the school runs a non-public school platform or student portal, the school will still need to ensure that in addition to school portal activity around FERPA, that there is publicly available notice on the website.
  • Prominent FERPA notice entails providing a clearly labeled link from the home page directly to the FERPA annual notice. Or, a search for FERPA in a search box should uncover the pertinent information. Parents and students should not need to click through websites and do investigative searches to find the annual FERPA notice.

A best practice exemplar may be found on this Baltimore City School’s website,50 where a search for FERPA on the home page led to clear results for FERPA. The first search result is the relevant page: the Opt out of release of directory information. This type of simple search with a well-positioned relevant result provides a supportive environment for a student or parent searching a school website for FERPA information.

Best Practice, Baltimore City Public School website search, FERPA results

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Figure 8. At at Baltimore City Public School website, a search from the school’s home page displayed relevant results that led to FERPA notice and opt out information. This is an example of a best practice implementation of FERPA notice online.

The actual FERPA opt out notice for the school is quite good, and represents best practices regarding clarity, granularity of choice, and completeness.

Best Practice: FERPA Opt out and contextual information for Baltimore City Public Schools

 

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Figure 9. A click on a link to Opt Out of Release of Directory Information on Baltimore City Public School’s website leads directly to this quite good FERPA opt out form. Making such forms available to the public prior to any sign in requirements is a best practice.

  • Notice of FERPA policies and opt out should be prominent and should remain online year-round. Many K-12 schools provide paper forms or email forms to parents. A best practice is to provide FERPA annual notice linked from a prominent place on the home page at all times in addition to the paper forms.
  • Use consistent terms: FERPA, directory information opt out, or directory information restriction are the most commonly used terms. It would be helpful for the Department of Education to standardize the terminology so that students and parents see the same terms at all schools.
  • Put all relevant FERPA forms and information in one prominent location online that is publicly available. Parents and students who are relocating or thinking of a local move need to be able to see FERPA forms readily online.
  • To serve the needs of those who are highly adapted to digital technologies, educational institutions should ensure FERPA notices are readily available online and can be read on mobile devices as well as laptop computers. School web sites are key for providing prominent links to FERPA annual notices that are accessible to the public and students.

Additional recommendations:

  • Guidance: The U.S. Department of Education should provide new guidance for K-12 schools specifically providing that all FERPA materials be available on the public-facing web sites of K-12 schools as a minimum necessary step.
  • The guidance should also address “school platforms” or integrated student information systems The guidance should specifically provide that parents can access FERPA materials without being required to provide registration information to any system. FERPA policies should be posted online and available to the public to meet general transparency obligations.
  • School boards, state lawmakers, and Department of Education regulators should provide updated and more specific instructions for primary and secondary schools’ annual FERPA notices.

44 FERPA regulations, 2011. See 53 FR 11943, Apr. 11, 1988, as amended at 76 FR 75642, Dec. 2, 2011.

a) An educational agency or institution may disclose directory information if it has given public notice to parents of students in attendance and eligible students in attendance at the agency or institution of:

(1) The types of personally identifiable information that the agency or institution has designated as directory information;

(2) A parent’s or eligible student’s right to refuse to let the agency or institution designate any or all of those types of information about the student as directory information; and

(3) The period of time within which a parent or eligible student has to notify the agency or institution in writing that he or she does not want any or all of those types of information about the student designated as directory information.

(b) An educational agency or institution may disclose directory information about former students without complying with the notice and opt out conditions in paragraph (a) of this section. However, the agency or institution must continue to honor any valid request to opt out of the disclosure of directory information made while a student was in attendance unless the student rescinds the opt out request.

(d) In its public notice to parents and eligible students in attendance at the agency or institution that is described in paragraph (a) of this section, an educational agency or institution may specify that disclosure of directory information will be limited to specific parties, for specific purposes, or both. When an educational agency or institution specifies that disclosure of directory information will be limited to specific parties, for specific purposes, or both, the educational agency or institution must limit its directory information disclosures to those specified in its public notice that is described in paragraph (a) of this section.

(e) An educational agency or institution may not disclose or confirm directory information without meeting the written consent requirements in §99.30 if a student’s social security number or other non-directory information is used alone or combined with other data elements to identify or help identify the student or the student’s records. Available at: https://studentprivacy.ed.gov/ferpa-regulations#0.1_se34.1.99_137.

45 The survey methodologies are explained in Appendix A, B, and C.

46 A copy of this notice is on file at WPF offices.

48 Penn State University, AD11 University Policy on Confidentiality of Student Records. Available at: https://policy.psu.edu/policies/Ad11.

49 University of Tennessee, Knoxville, One Stop Shop: FERPA. Available at: https://ferpa.utk.edu/procedures/.

50 Carver Vocational Tech High School, Baltimore City Schools. Search results for term FERPA. Available at: https://www.baltimorecityschools.org/schools/454.

II. Information Schools Can Share When No Opt Out is in Place? →

Directory information means information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. The specific types of information included in directory information are left to the discretion of the school. As a result, there is wide variability in what information educational institutions share without prior consent from a student or parent.

Schools can designate as directory information a student’s full name, age, photograph, email address, phone number, grade or level of study, course of study, and physical address, among other information. Schools may not include as directory information Social Security Numbers, or school ID numbers (there are some exceptions for the use of school ID numbers).

One point worth emphasizing is that some directory information about students at all levels may be collected by data brokers and used in personal and household files about the student for the rest of the student’s life. Information that a school may eventually discard after a student leaves can live on forever in private files. Further, information that schools have disclosed about students name, exact data of birth, gender, primary language spoken, and even home address and names of parents and/ or guardians may be used in ways that schools have not intended nor imagined.

We also note that gender has become a complex and controversial designation. Gender is no longer just M or F, and gender changes can and do occur. Schools must grapple with these issues, but they do not need to make matters worse by releasing gender information publicly.

A. What the Research Found

  • The research revealed significant variability in designations of directory information. Some schools release minimal information. Others release broad categories of information.
  • Almost all schools share student names.
  • An aggregate of all fields we found during the research, from all institutions including primary, secondary, and postsecondary includes the following categories of directory information that schools, in aggregate, have designated to be released without prior consent:
    • Name of student
    • Gender
    • Date of birth
    • Date and place of birth
    • Hometown, city, and state
    • Primary language spoken
    • Social media handles
    • Local address
    • Permanent home address
    • Residence Hall address
    • Address of parents or guardians
    • Telephone listings Student email addresses
    • Telephone number and email address of parents or guardians
    • Student email addresses
    • Student employee telephone listing
    • Dates of attendance
    • Withdrawal dates
    • Program / major field of study
    • Degrees and certificates received / dates
    • Academic and co-curricular awards, honors, and scholarships, and dates received
    • Number of hours enrolled and number completed
    • The most recent educational institution attended
    • Participation in officially recognized activities
    • Weight and Height of students on athletic teams
    • “PeopleSoft number”
    • Student ID number, user ID or other unique identifier
    • Student’s district identification number
    • Photograph(s)
    • Electronic images
    • Digitized photo
    • Class photo
    • Videos
    • Photographs or recordings of students taken by surveillance cameras where the images do not depict specific students engaging in actions that would constitute violations of the Code of Student Conduct
    • Yearbook pictures
    • Annual yearbook print copies, playbills, program guides, or recordings of school sponsored events
    • Student employee telephone listing
    • Student employee job classification
    • Student employee email address
    • Student positions held
    • Nature and place of employment
    • Nature and place of employment at school Yearbook pictures

1. At the postsecondary level, controversial data types emerged in the information that secondary schools chose to designate as directory information included:.

  • Local address
  • Permanent home address
  • Residence Hall address
  • Date of birth
  • Hometown, city, and state
  • Nature and place of employment
  • The most recent educational institution attended
  • Photographs

These data fields present meaningful privacy risks to students in today’s world. The FERPA regulations are out of step with modern thought and digital realities. This is especially true for people who are victims of crime or others have heightened safety concerns (e.g., victims of domestic violence, jurors, and others). Students may not wish for their previous institutions to be named for a number of justifiable reasons. People who have experienced identity theft in the past will be aware that an exact date of birth plus a local address and other key pieces of personal data is a significant risk for identity theft.

Because directory information is essentially public and without further restrictions on use and disclosure, photographs may be repurposed in private sector and governmental analytical systems, such as face recognition systems. Parents and students may object to the unrestricted us of photographs, and the photographs may present additional safety risks for some students. Further, there are emerging issues with use of biometrics derived from “scraped” photographs.51 As a result, the release of photographs today faces new aspects of sensitivity. Clearview AI, a company that builds face recognition products for sale to law enforcement, has disclosed in writing that it collects and uses publicly available images of minors:
Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.52</px-3 Blockquote> The open posting of student photographs has acquired risks that schools need to take into account when determining what information to include in directory information. While we do not know if Clearview AI scraped school websites or not, we do know the company scraped social media sites. Schools with social media pages to which they posted images of students may have been included in the scraping.

2. At the primary and secondary school level, the research showed a similar pattern of difference is the types of information included as directory information. The problematic elements include the following information:

  • Gender
  • Permanent home address
  • Date and place of birth
  • Address of parents or guardians
  • Telephone number and email address of parents or guardians
  • Primary language spoken
  • Social media handles
  • Photographs

We note that the U.S. Department of Education guidance has already provided guidance discouraging the use of students’ gender, race, and ethnicity as directory information.
“ The Department, through letters, guidance, and compliance training, since at least 1991, has consistently advised that the disclosure of a student’s sex, ethnicity, or race as directory information would not comply with the regulatory definition, which provides that directory information is information that would not generally be considered harmful or an invasion of privacy if disclosed.”53</px-3 Blockquote> Schools routinely collect data. Collection of many types of personal information is understandable and is not, by itself, the heart of the privacy problem created by FERPA. The problem is that schools can release too much personal information as directory information without affirmative consent. Date and place of birth and primary language spoken do not belong in records released without prior written consent. Similarly, publicly releasing the home address of parents and guardians can interfere with safety plans of parents who face significant safety concerns. For example, public officials, including elected officials, judges, law enforcement, and teachers may have good reason for keeping their home addresses out of the public domain. The research found a few schools include social media handles in directory information. This too can be sensitive information for some, both students and parents.

Photographs for primary and secondary students create similar risks as discussed above for college students.

3. Roster of Information Shared Without Opt Out in Educational Institutions

This is a sampling of the data collected for the research. Note the variability of data policies across institutions. Also, note that some institutions place copious data in directory information, including information the Department of Education has specifically said should not be included, such as gender. The information in these tables comes from the sample set of rural and urban schools studied for this research.

Roster of Student Information Shared Without Prior Consent if not Opt Out is in Place
  • Names of students
  • Dates of attendance at the university
  • Program/major field(s) of study
  • Degrees and certificates received including dates
  • Participation in officially recognized university activities
  • Academic and co-curricular awards, honors, and scholarships received and dates received
  • Weight and height of students on athletic teams
  • Students’ email addresses
  • Hometown, city and state
  • Names of students
  • Dates of attendance at the university
  • Program/major field(s) of study
  • Degrees and certificates received including dates
  • Participation in officially recognized university activities
  • Academic and co-curricular awards, honors, and scholarships received and dates received
  • Weight and height of students on athletic teams
  • Students’ electronic mail addresses
  • Hometown; city and state
  • Student’s name
  • Participation in officially recognized activities and sports
  • Weight and height of members of athletic teams
  • Degrees, honors, and awards received
  • Major field of study
  • Dates of attendance
  • The most recent school attended

Directory information includes

  • student’s name,
  • address,
  • telephone number,
  • date and place of birth,
  • honors and awards, and
  • dates of attendance.
  • name,
  • address (including e-mail),
  • telephone number,
  • college,
  • class,
  • major,
  • dates of attendance,
  • degree,
  • honors and awards conferred.
  • Student’s name;
  • address (mailing, permanent, and/or e-mail);
  • telephone numbers;
  • major field of study;
  • dates of Attendance;
  • number of course units in which enrolled;
  • degrees and honors received;
  • the most recent previous educational institution attended; and
  • participation in officially recognized activities, including intercollegiate athletics, and the name, weight, and height of participants on intercollegiate /xxxx/ athletic teams.
  • Student’s name*
  • Local/Residence Hall address*
  • Home and/or Cell telephone numbers*
  • Official university email address*
  • College
  • Class standing/Classification
  • Academic program (degree, major, minor)
  • Dates of attendance
  • Status (full or part-time registration)
  • Degree(s) received
  • Honors and awards received
  • Participation in officially recognized activities
  • Weight and height of members of athletic teams
  • Student name
  • Addresses (e.g., local, home, mailing and /XXX/ e-mail, including directory number)
  • Telephone numbers
  • Date of birth
  • Degrees, honors and awards received (including Dean’s List, National Merit, National Achievement, and National Hispanic Scholars)
  • Most recently attended educational institution
  • Academic level
  • Major
  • College
  • Dates of attendance
  • Enrollment status (e.g., undergraduate or graduate, full-time or part-time)
  • Participation in officially recognized activities/sports
  • Weight/height of members of athletic teams
  • Name,
  • address,
  • telephone number,
  • date and place of birth,
  • honors and awards,
  • dates of attendance
  • Student’s name
  • Name of the school attended prior to the current one
  • Degrees and awards received
  • Participation in official school activities and sports
  • Weight and height of members of athletic teams
  • Name
  • NetID
  • PeopleSoft Number
  • School or College
  • Major Field of Study
  • Degree Sought
  • Student Level
  • Degrees, Honors & Awards Received
  • Residency/Match Information (medical/dental students)
  • Dates of Attendance
  • Participation in Officially Recognized Activities and Sports
  • Weight and Height of Athletic Team Members and Other Similar Information Including Performance Statistics
  • Photographic Likenesses and Video of Athletic Team Members
  • For Student Employees, Employing Department & Dates of Employment

On directory opt out form /XX/ University considers the following items to be directory information:

  • the student’s name,
  • address,
  • telephone listing,
  • electronic mail address,
  • photograph,
  • major field of study,
  • participation in officially recognized activities and sports,
  • weight and height of members of athletic teams,
  • dates of attendance,
  • grade level,
  • enrollment status,
  • degrees,
  • honors, and awards received, and
  • the most recent previous educational agency or institution attended by the student.
  • For bargaining unit student employees, directory information also includes: the name of the department employing the student,
  • the student employee’s telephone listing within the department,
  • the student employee’s e-mail address within the department, and
  • the student employee’s job classification.
  • No other student information is released to non
  • university personnel without your written permission
  • Student’s name;
  • address;
  • telephone number;
  • email address;
  • major field of study;
  • classification by year;
  • number of hours in which enrolled and number completed;
  • participation in officially recognized activities and sports;
  • weight and height of members of athletic teams;
  • dates of attendance including withdrawal dates;
  • degrees,
  • scholarships,
  • honors, and awards received, including type and date granted;
  • photograph
  • Student name
  • Permanent mailing address
  • Month and day of birth
  • Photographs
  • Student identification number, User ID, or other unique identifier Email address
  • Telephone number
  • University or College previously attended or currently attending Dates of attendance
  • Full vs. part-time student status
  • Awards and honors
  • Class standing/year
  • Major, minor, concentration and/or program of study Degree(s)/Certificate(s) candidacy
  • Degree(s)/Certificate(s) earned
  • Previous Institutions attended
  • Graduation expected/completion
  • Name
  • Addresses
  • Telephone numbers
  • E-mail addresses
  • Date of birth
  • Major field(s) of study
  • Enrollment status (including current year, credit load, and full-or part-time status)
  • Dates of attendance
  • Degrees, honors, and awards received
  • Previous institution attended
  • Participation in officially recognized activities
  • Participation in athletics
  • Height and weight of athletes
  • Photograph
  • Name, date, and place of birth;
  • Local address;
  • Permanent address;
  • Telephone number (if listed);
  • Classification;
  • Major field of study;
  • Participation in official University activities and sports;
  • Weight and height of members of athletic teams;
  • Dates of attendance at the University;
  • Degrees, honors, and awards received;
  • The most recently attended educational institution; and
  • Digitized photo (/XXXXX/ State University Card).

Directory information may include the following:

  • Student name
  • Address
  • Telephone listing
  • Date and place of birth
  • Photograph
  • Major field of study
  • Participation in officially recognized activities and sports
  • Weight and height of members of athletic team•Dates of attendance
  • Awards received
  • Most recent previous school attended by a student

Examples include a student’s photograph for publication in the school yearbook; a student’s name and grade level for purposes of communicating class and teacher assignment; the name, weight, and height of an athlete for publication in a school athletic program; a list of student birthdays for generating schoolwide or classroom recognition; a student’s name and photograph posted on a district-approved and -managed social media platform; and the names and grade levels of students submitted by the district to a local newspaper or other community publication to recognize the A/B honor roll for a specific grading period.

Primary Directory Information – Use in School Publications:

  • The District designates the following as primary directory information for use by the District in school publications without prior parental written consent:
  • Student’s name;
  • Grade level;
  • Student’s participation in officially recognized activities or sports;
  • Weight and height of athletes;
  • Honors, awards, and degrees;
  • Information which denotes accomplishments and achievements;
  • Individual and group photographs;
  • Dates of attendance;
  • School attending; and
  • Parent/Guardian name.

Examples of the use of the above information in school publications by the District include, but are not limited to: class rosters posted inside school buildings; a program showing a student’s role in a music or drama production; the annual yearbook; school newspaper; honor roll or other recognition lists; graduation programs; and sports activity programs, such as for wrestling, showing weight and height of team members.

Directory Information – Student Contact Lists and Public Requests (Outside Organizations):

  • The District designates the following as directory information that may be disclosed by the District without prior written parental consent:
  • Student’s name;
  • Street address;
  • Telephone number;
  • School attending; and
  • Grade level.

Examples of the use of this outside organization directory information include, but are not limited to: use in a parent/student contact list (e.g. buzz book, school telephone directory, school contact list); providing information, upon request, to individuals, groups or organizations outside of school (e.g. parent groups [booster groups, PTA], outside organizations serving youth, companies that manufacture class rings or supply graduation items, photographers).

  • Student name,
  • address,
  • telephone number,
  • date and place of birth,
  • major field of study,
  • participation in officially recognized activities and sports,
  • weight and height of members of athletic teams,
  • dates of attendance,
  • indication of “graduate” or “non-graduate”,
  • degrees and awards received,
  • most recent previous school attended, and
  • photograph.

Directory Information:

  • student’s name
  • participation in officially recognized activities and sports
  • address
  • telephone listing
  • weight and height of members of athletic teams
  • photograph
  • degrees (excludes specifying diploma type of student earning the following:
  • modified standard diploma
  • IEP diploma and/or certificate of attendance),
  • honors, and awards received
  • date and place of birth
  • dates of attendance
  • grade level

/xx/ School District has identified the following information as directory information:

  • Student’s name, address,
  • parent’s telephone number and email address
  • Student ID number, user ID, or other unique personal identifier used to communicate in electronic systems but only if the identifier cannot be used to gain access to education records except when used in conjunction
  • with one or more factors that authenticate the user’s identity, such as a PIN, password, or other factor known or possessed only by the authorized user
  • Participation in officially recognized activities and sports
  • Height and weight of members of athletic teams
  • Degrees, honors, and awards received
  • Student’s district identification number
  • Dates of attendance/enrollment
  • Grade level
  • Most recent school attended
  • Name of student in attendance or no longer in attendance
  • Address
  • Telephone listing
  • Date and place of birth
  • Dates of attendance
  • Participation in officially recognized activities and sports
  • Height and weight, if a member of athletic team
  • Awards, degrees and honors received
  • Other similar information
  • Annual yearbook print copies, playbills, program guides, photographs or recordings of school sponsored events
  • Photographs or recordings of students taken by surveillance cameras where the images do not depict specific students engaging in actions that would constitute violations of the Code of Student Conduct.
  • The School Administration reserves the right to determine whether release of such information should be released.

The /xx/ School District designates the following information as Directory Information regarding individual students:

  • name of parent(s)/legal guardian and address,
  • student name,
  • address,
  • telephone number,
  • date of birth,
  • gender,
  • weight and height of members of athletic teams,
  • participation in activities recognized by the District,
  • dates of attendance,
  • degrees and awards received,
  • yearbook pictures, and information,
  • class pictures,
  • most recent previous school attended and the school to where the student transferred, if applicable.

The following information is considered directory information:

  • parent/guardian and student name,
  • home address,
  • home telephone number,
  • home email address,
  • student photograph,
  • student date of birth,
  • dates of enrollment,
  • grade level, enrollment status,
  • degree or award received,
  • major field of study,
  • participation in officially recognized activities and sports teams,
  • height and weight of athletes,
  • most recent school or program attended,
  • and other information that would not generally be considered harmful or an invasion of privacy if disclosed.

The term directory information relating to a student includes, but is not limited to:

  • Name;
  • Physical and electronic mail address;
  • Telephone listing;
  • Date and place of birth;
  • Major field of study;
  • Participation in officially recognized activities and sports;
  • Weight and height of members of athletic teams;8.Date of attendance;
  • Degrees and awards received; and
  • The most recent previous LEA or institution attended by the student.
  • Student’s Name
  • Participation in officially recognized activities and sports
  • Address
  • Telephone listing
  • Weight and height of members of athletic teams
  • Electronic mail address
  • Photograph
  • Degrees, honors, and awards received
  • Date and place of birth
  • Major field of study
  • Dates of attendance
  • Grade level
  • The most recent educational agency or institution attendance
  • Student’s name
  • address
  • date of birth
  • dates of enrollment;
  • Parent or legal custodian’s name and address;
  • Student’s grade level classification;
  • Student’s participation in recognized school activities and sports;
  • Weight and height of members of athletic teams;
  • Student’s diplomas, certificates, awards and honors received.

Figure 10: The information in these tables comes from the sample set of rural and urban primary and secondary schools studied for this research. Each box contains a list of the information the schools designated as directory information that could be publicly released without prior consent.

4. Best Practices; all levels:

  • Follow a minimum necessary rule when designating directory information. Expansive inclusions of students’ gender, primary language, and place of birth are not necessary. Schools can use this data, but including these data fields in directory information and releasing it to third parties is unnecessary and therefore not a good practice because routinely its inclusion is not required to achieve the goal of the school through disclosure.
  • Consider exact age, date of birth, home address, photographs and videos, and gender to be categories of information that should be restricted. Home address of a student placed in directory information presents a safety risk for some students and parents. Both schools and the U.S. Department of Education should recognize a modern understanding of safety considerations attached to publicly releasing home address information. Not only is the student potentially put into a dangerous situation, their family members who may also have risks associated with others knowing their home addresses may also be endangered. For example, judges, elected officials, police officers and victims of stalking or other crimes may be put at risk.
  • Photographs of students released through directory information create high risks to all students. It is a best practice to not include digital images of students as directory information. Photographs of students can pose safety risks to some parents and students. Additionally, photographs of students are riskier to release because of the possibility of permanent storage and use by commercial and other biometric systems. The photographs may be input for web scraping tools that can undertake biometric analysis. It is a best practice to not include student photographs in directory information.

Example: One sampled K-12 school district includes a minimal amount of data as directory information.

  • Student’s name
  • Street address
  • Telephone number
  • School attended
  • Grade level.

This is a step in the right direction of a best practice but for the inclusion of street address and, perhaps, telephone number. What this example shows is that directory information can include just a few data elements about each student.

51 See: Kashmir Hill, The secretive company that might end privacy as we know it, The New York Times, January 20, 2020. Available at: https://www.nytimes.com/2020/01/18/technology/clearview-privacy-facial-recognition.html.

52 Filing of Clearview AI, Registration ID 367103, January 14, 2020, Vermont Data Broker Registry. Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367103. See: Response to Question 7: “Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.”

53 Guidance regarding the 2020 Census, U.S. Department of Education, January 29, 2020. Available at: https://studentprivacy.ed.gov/sites/default/files/resource_document/file/ED_SPPO%20Letter%20to%20IHEs%20re%202020%20Census_v_01292020.pdf.

III. How Much Time Do Parents or Eligible Students Have to Opt Out? →

The research found distinct patterns regarding allowances for opt out timing. All institutions allow parents or eligible students to submit an opt out upon enrollment, whenever that may occur. Apart from initial enrollment, colleges and universities often give students the entire academic year to opt out, and K-12 institutions give students much less time to opt out, with time periods as short as two weeks to an average of 45 days.

What the Research Found:

A. Opt out allowances at Postsecondary Institutions:

  • The majority of opt outs at postsecondary schools are allowed in an ongoing manner during the entire academic year. The opt out, with no exceptions we could find, stays in place until a student rescinds the opt out in writing.

B. Opt out allowance at Primary and Secondary Institutions:

  • At the primary and secondary levels, opt out periods range from a very short period of 10 days on the low end, to an approximate average of 45 days to submit an opt out.
  • The preponderance of primary and secondary schools allow an opt out period of an average of 45 days.
  • For students just enrolling in school, the opt out can be submitted upon enrollment.

Shortened opt out periods at the K-12 level are not sufficient for protecting privacy in the current digital environment. Schools need to modernize their approach to opt out timing, understanding that information problems will not politely wait for the start of a school year. Data moves very quickly now. A one-year waiting period for opting out is not acceptable, because safety problems can arise that need to be attended to without delay. One particular primary/secondary school in the study gave a deadline of October 15 for submission of the opt out. If parents miss the October 15 deadline, the school allows the submission of an opt out during the entire school year, but the school begins releasing directory information as of November 1 of each school year, and any opt out submitted after the October deadline would only apply the following year.

In another example particularly applicable to postsecondary students, a company that registered as a data broker in the Vermont data broker registry noted that they offer an opt out of their system. The filing at the Vermont Secretary of State’s office explained that the opt out available needed to be completed at the local schools under FERPA.54 If a student learns of this or another data broker and wants to submit an opt out, the effectiveness of the opt out will depend on whether or not the local school allows for opt outs whenever a student turns them in.

The opt out period for educational institutions needs to be regularized and modernized to be up to expected privacy standards in modern privacy legislation. This means opt outs need to be available all year for all educational institutions, and opt outs are accepted and actionable during the entire school year. The policy update to opt out deadlines needs to be made sooner rather than later, certainly at the local level, and also at the Federal level in revised regulations.

C. Best Practices for Time Allowed for FERPA Opt Out at all educational institutions:

  • Directory Information Opt Outs should be allowed all year by all institutions covered under FERPA; this is a baseline protection that needs to be updated in the FERPA guidance.
  • Expedited opt outs should be made available for vulnerable people and populations. If in the event that a safety situation, data breach, or a toxic data leak traceable to directory information that has been disclosed, those at risk need to be provided immediate means of masking or hiding their data.

54 National Student Clearinghouse, Data Broker Registration, Vermont, 2/11/2019, Registration ID 353284, Filing number 0002513425. Available at: https://www.vtsosonline.com/online/DataBrokerInquire/FilingHistory?businessID=353284.

IV. Access to FERPA Opt Out Forms →

The research found significant variability in whether or not schools posted a FERPA opt out form online. FERPA opt out forms are forms that students can fill out to request a FERPA restriction (or opt out). The overall findings were that:

60 percent of postsecondary institutions posted a FERPA opt out form online.

39.7 of percent of the primary and secondary institutions studied offered an opt out form online.

The Department of Education mandates that FERPA-covered educational institutions post an annual FERPA notice, but it does not mandate that schools provide a specific FERPA opt out form, either online or off. One of the key items this research tested was if the educational institution posted an opt out form online, and if that form was accessible to the public. The reason the research tested for this is twofold.

First, it is important for parents and eligible students to have an opt out form on hand because most students are stymied by the prospect of having to write a FERPA opt out letter from scratch. This is not a theoretical concern; some schools do ask students to write their own opt out request from scratch. The availability of a FERPA opt out form is an important tool in facilitating the ability of parents and eligible students to exercise their FERPA rights.

Second, many parents and eligible students search web sites for information as a first response to a question they may have. A best practice is that parents and students should be able to locate a FERPA notice online, read it, and either have an opt out form included with the notice, or have access to a separate opt out form online. It would be ideal for those who want to submit a FERPA opt out request to be able to easily accomplish the task from start to finish using a mobile phone. Allowing students ongoing access to FERPA opt out forms is a modernized approach to delivering forms in a consistent, year-round way. Particularly at the postsecondary level, not all relevant individuals in a student’s life may have access to a password-protected student system, so publicly available FERPA information is still important.

Currently, there is not a unitary model for a FERPA opt out form that is provided by the Department of Education. Even well-resourced schools may not have legal counsel available to draft a customized form. Therefore, many schools may fail to provide an opt out form simply because of the scarcity of legal budget or resources available. This is an area where the Department could provide very helpful information that would make a positive difference.

The Department also does not yet appear to post specific guidance regarding online FERPA opt out form policy. For example, what must be included on an opt out form? What should the format for an opt out form be, electronic and paper and audio, or all three? What is the guidance for making opt out accessible for all students and parents?

Particularly at the postsecondary level, there is movement away from paper opt out and to opt out within online password protected integrated student information systems. Within this trend are schools that are building significant FERPA “home pages” which are open to the public, and where FERPA forms and notices are posted for all to see. These are best practices. It would be a negative outcome for postsecondary FERPA opt out forms and notices to only be made available behind student systems with no public accessibility.

A. What the Research Found, Details

Postsecondary Institutions

1. 60 percent of postsecondary institutions posted a FERPA opt out form online. Recall that 98 percent of postsecondary schools posted the annual FERPA notice online. However, when it came to posting FERPA opt out forms, there was tremendous variability. Remember: there is no requirement to post a FERPA opt out form online, but it is a best practice.

Some of the details the research found include the following:

  • 32 percent of institutions posted a copy of their FERPA opt out form online and within their internal student system. This is a best practice.
  • 30 percent of institutions posted the FERPA opt out in the internal student system
  • 54 percent of institutions made a paper copy of the FERPA opt out form available.
  • 4 postsecondary institutions post FERPA opt out forms on the registrar’s page very prominently. These forms are publicly accessible.
  • 35 percent of institutions posted FERPA opt out forms either on the Registrar’s page or just one or two clicks away from the Registrar’s page.

Postsecondary institutions, with encouragement from the Department of Education, are in a particularly good position to move to a more systematized approach to the posting of FERPA opt out forms. It is a positive for eligible students and members of the public to be able to have a consistent idea of where to find FERPA opt out forms. Ideally, opt out forms would be available within a dedicated student system, and also be available as part of a complete FERPA “hub” available on the public facing school website for reference and ease of access.

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Figure 10. Postsecondary institutions that provide a paper copy of FERPA opt out forms. Of schools studied, approximately 54 percent of institutions made a paper copy of the FERPA opt out form available.

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Figure 11: Postsecondary institutions that provide a FERPA opt out within their digital student management systems. Of schools studied, approximately 30 percent of institutions posted the FERPA opt out in the internal student system.

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Figure 12. Postsecondary institutions that provide a copy of FERPA notice and opt out forms on the school website. Of schools studied, approximately 32 percent of postsecondary institutions posted a copy of their FERPA notice and opt out form online and made it publicly available outside of registration or password protected systems. This is a best practice.

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Figure 13. Aggregate of studied postsecondary institutions that post FERPA notices or opt outs on, or one click away from, the Registrar page. This research was to understand the role of Registrar pages of postsecondary institutions regarding FERPA information.

2. At the primary and secondary level:

  • 39.7 of percent of the 5,145 primary and secondary institutions studied offered an opt out form online in some form. (2,045 opt outs posted in 5,145 schools studied.
  • 617 of the 2,045 online opt outs were available in online student handbooks.
  • 34 of the 2,045 online opt outs were available in the online code of student conduct.

The numbers of primary and secondary schools offering a public posting of a FERPA opt out form is low, hovering around 40 percent. The research suggests that much more work remains to be done. In some school districts, platforms have been configured in a way that hampers public access to FERPA forms. Some platforms at the K-12 level do not facilitate the schools’ posting of a FERPA annual notice outside the password protected areas of the school web site, and similarly do not facilitate keyword searches for FERPA notices or forms on the publicly available sections of the school websites.

Although it was not material to the overall results, when we analyzed our research at the district level to see if we found any patterns, we found differences in the rural and urban implementations of posting FERPA opt out forms online.

At the primary / secondary district level, aggregate:55

  • 13.8 percent of rural school districts have posted FERPA opt out forms online at the school district level.
  • 31 percent of urban school districts have posted FERPA opt out forms online at the school district level.

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Figure 15. Aggregate of studied urban area primary/ secondary school districts that made a FERPA opt out form available online, and freely available to the public, i.e., not behind a password protected area. 31 percent of urban school districts have posted FERPA opt out forms online at the school district level.

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Figure 16. Aggregate of studied rural primary/ secondary school districts that made a FERPA opt out form available online, and freely available to the public, i.e., not behind a password protected area. 13.8 percent of rural school districts have posted FERPA opt out forms online at the school district level.

Best Practices for Access to Opt Out Forms:

  • It is a best practice for educational institutions to post a FERPA opt out form online.
  • It is crucial that all educational institutions post FERPA opt out forms online in a way that is publicly accessible and does not require a password or registration.
  • FERPA opt out forms should be posted prominently, and should be labeled clearly. Parents and students should be able to access the form from the search function on the web site. If the web site does not have a search function, the FERPA opt out notices and policies should be posted with a prominent link on the home page of the school web site.
  • Ideally, the FERPA opt out forms will be posted in the context of FERPA annual notice, and other FERPA-related information.
  • Paper opt out forms should be made available for individuals who do not have online access.
  • For postsecondary institutions, the FERPA opt out form should have a publicly available “home base,” preferably the registrar’s page.
  • For primary and secondary institutions, the FERPA opt out form should be accessible to the public, even if a platform is in use at the school web site.
  • FERPA opt out processes need to specifically accommodate individuals with disabilities or limitations.

Further Recommendations:

  • The Department of Education should seek to further understand and study the differences in FERPA opt out form implementation at the rural / urban school districts. There is a possibility that additional guidance would be helpful in facilitating rural districts to post FERPA opt out forms online.

55 Note that these results are aggregate to all rural and all urban school districts. When FERPA opt out is counted by district, the numbers become less precise and the overall count of online FERPA form postings changes to approximately 44 percent. Large urban school districts can contain hundreds of schools, which can have varying implementations apart from the district. Despite the mushiness of the number (+/- 5 %), the different between urban and rural implementation was significant and stood out in the research. More work is needed in this area to both incorporate a larger sample size, and to seek understanding of the reasons why this is happening, and what would help solve the problem(s).

V. Is the FERPA Opt Out Process Known? →

Regardless of whether or not an opt out was found online, the research probed whether or not educational institutions explained how parents or eligible students could submit an opt out. Schools, even those that did not post an opt out form, fared better in posting instructions for submitting an opt out.

1. What the Research Found:

  • The research found that almost all postsecondary schools made the FERPA opt out process known, whether that was provided via paper or online.
  • Schools that posted a FERPA notice online generally included how to opt out in that notice. In some cases the explanation of how to opt out was in the context of a FERPA “home page” with general guidance on how to manage FERPA options at the educational institution. The precise notification to students of how to opt out varied. For example, opt out could be given in writing to a registrar, it could be done via a student information system, it could be given by writing a letter and submitting it to the school, etc.
  • It was not unusual for schools to request that parents and students submit a “written request for opt out” without providing an opt out form. Parents interviewed as part of this research indicated that to avoid writing a letter, they copied another school’s opt out form they found online and turned it in. The World Privacy Forum posts a sample opt out form on its web site. Research interviews uncovered parents who had printed the WPF’s sample form out and used it as their opt out form.
  • Postsecondary institutions generally show a pattern of informing students how to opt out. Instructions are typically found in the FERPA policy notice, which 98 percent of postsecondary schools provide.
  • For primary and secondary schools, we were able to locate opt out procedures for 62 percent of urban school districts, and 49 percent of rural school districts.

2. Best Practices for Notification of Opt out Procedures:

  • It is a best practice for schools to provide information about how to opt out on the annual FERPA notice.
  • It is a best practice for schools to provide a permanent online home for information about FERPA opt out procedures and make that accessible to the public.
  • Primary and secondary schools in particular noted to WPF researchers that they communicate FERPA opt out procedures directly to parents via email. Direct notification exceeds FERPA standards, but for school districts that are resource-scarce or in the midst of transitioning to electronic systems, direct emails to ensure notification are a good practice. The practice may not be sustainable at very large institutions, but it is a sustainable practice for very small or small institutions or districts.
  • It is a best practice to notify students regarding accommodations for opting out for individuals who may not have the capacity to write their own letter. This appears to be an overlooked issue. Not all parents or eligible students will be comfortable figuring out what a FERPA opt out letter should say, or even where to start. Not providing an opt out form may prove to be an insurmountable opt out form for some students. This should be considered as part of the institution’s decision-making process regarding opt out procedures.

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Figure 17. Aggregate of studied urban area primary/ secondary school districts that provided parents or eligible students with instructions about how to submit a FERPA opt out. 62 percent of urban school districts provided this information online in some way.

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Figure 18. Aggregate of studied rural primary/ secondary school districts that provided parents or eligible students with instructions about how to submit a FERPA opt out. 49 percent of rural school districts provided this information online in some way.

VI. Content of FERPA Opt Out Forms →

The research found many varieties of opt out forms. Samples of opt out forms are located in the Appendices. There is no standard format for FERPA opt out forms, and the variety and scope of opt out forms makes it difficult to easily classify them. The Department of Education suggests some language for opt out forms, but the Department does not dictate what the opt out form specifically says. This is appropriate, given that schools have a great deal of discretion as to how they approach directory information policies.

However, the quality of students’ opt out experience could be improved overall by the use of more granular opt out forms versus “all of nothing” opt out forms.

Granular FERPA Opt Out Forms

Granular FERPA opt out forms are those that contain a list of specific categories of information the school has designated as directory information along with the option to specify an opt out of one or more of the specific categories. For example, a granular opt out may allow students to restrict the publication of their photograph, and also allow them to continue to publish their email address, if desired. This type of approach allows students to select discrete information categories of their directory information that may be disclosed without consent.

Granular forms allow students to agree to have their name published in a PTA book, without allowing the disclosure of information for other uses. Students have individualized privacy needs, and granular choices allow students to choose what is important or necessary to them and avoid other, unknown consequences.

Broad Opt Out Forms

Broad opt out forms are those that allow students to restrict all sharing of directory information. The forms offer an “on or off” choice.

What the Research Found

For studied educational institutions across all levels, the research found a continuum of opt out forms that fell into one of two main styles of FERPA opt out forms, highly granular opt outs, (opt outs that allow students to select which specific categories of information they want to restrict) and broad opt outs (opt outs that require students to opt out of everything).

  • The majority of opt out forms at are “broad” opt out forms. Because of the high variability of opt out forms and methods, it is difficult to quantify this with precise percentages. We estimate that approximately 80 percent of opt out forms that are provided online are primarily “broad opt outs.”
  • At the postsecondary level, we noticed slightly more occurrences of granular opt out forms. Of those colleges and universities posting granular opt out forms, institutions tended to allow for the most granular FERPA opt outs in integrated student information systems.

Best Practices:

  • It is a best practice to provide more choices for selecting categories of directory information on FERPA opt out notices.
  • It is a best practice to revise, if possible, “all-or-nothing” FERPA opt out notices to provide granular choices (Yes / No) about individual data categories designated by the school for inclusion in directory information.
  • It is a best practice to provide detailed categories that students can choose to opt out of. Our research indicated that integrated student information systems, particularly at the postsecondary level, may offer very granular and extensive opt outs compared to standard FERPA opt out forms. It is a best practice to use integrated systems and platforms to make FERPA opt out more accessible and more adaptive.

One best practice exemplar of a granular opt out comes from University of Arkansas. In this opt out, students have a detailed menu of information they can choose to restrict, while allowing other kinds of information sharing. This is a best practice for students.

Best Practice: University of Arkansas Granular FERPA Opt Out Form (In Student Information System)

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Figure 19. The University of Arkansas is providing a highly granular FERPA opt out for its students. In its FERPA opt out, University of Arkansas students have a detailed menu of information they can choose to restrict, while still allowing other kinds of information sharing. This is a best practice.

It is most common to find FERPA opt out forms that allow students a range of very little to some opportunity to specify particulars of an opt out. The following is a typical broad opt out FERPA form. This form is a good example of a useful opt out form.

Example of a “broad” FERPA opt out

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Figure 20. This FERPA opt out form is a broad opt out that allows for some accommodation for personalizing the opt out. This is a commonly encountered type of FERPA opt out form.

VII. Does the FERPA Opt Out Contain Nudges? →

Nudges to take a particular course of action regarding privacy choices comes in all shapes and sizes in in FERPA opt out forms. The Information Commissioner of the UK explains that a nudge occurs when the outcome of two alternatives is presented, with one alternative framed more positively than the other. This nudges the user towards the preferred option of the person who offered the choice.56 Nudges are important in the FERPA context because in our review of hundreds of FERPA opt out forms, it became clear that nudges are common in FERPA opt out forms and related materials.

The nudges take on different forms, but generally FERPA nudges can encourage parents and eligible students to choose less privacy-protective options or to not restrict directory information release at all due to fear of the potential deleterious consequences identified on the opt out form.

Nudges have become better understood in the past few years. The UK Information Commissioner’s Office is wary about nudging children: “Do not use nudge techniques to lead or encourage children to provide unnecessary personal data or turn off privacy protections.”57

What the Research Found

The research found numerous examples of varied nudges in FERPA opt out forms. The nature and type of nudges varied significantly. We estimate that at least half of the opt out forms examined for this study contained one or more nudges.

Examples of commonly encountered privacy nudges on FERPA opt out forms include the following:

Warnings of being left out of various publications

At the postsecondary level, a common warning is that student’s names will not appear on the commencement bulletin. Another common warning is that the school will not confirm a student’s attendance at the school. FERPA opt out forms, intentionally or not, could make opting out sound like a terrible idea, rather than an affirmative protective right with clear benefits.

Your name will not appear on commencement bulletin….

Here is another example of a “you’ll be left out” nudge, this one from another postsecondary institution. The language acts to discourage opt outs:

Students who wish to restrict their names should realize that their names will not appear in the commencement bulletin and other university publications. Also, third parties will be denied any of the student’s directory information and will be informed that we have no information available about the student’s attendance at /XX/.58

Lengthy list of hurdles for students who choose to opt out…..

The opt out form quoted below contains a list of consequences ranging from telling prospective employers that there is no record of graduation to a requirement that the student “must” conduct all business with the university with a signed authorization, using the self-service portal, or in person with a form of ID. The university did not mention the benefits of opting out. This is a negative nudge.

WHAT ARE THE EFFECTS OF OPTING OUT?

Some of the effects of your decision to request confidential status will be that you must conduct all business with the University with a signed authorization, self-service portal, or in person with a form of ID. Friends or relatives trying to reach you will not be able to do so through the University. Information that you are a student here will be suppressed, so that if a loan company, prospective employer, family… 59member, etc., inquires about you, they will be informed that we have no record of your attendance or graduation.

Please be aware that opting-out of releasing your child’s directory information will deny the release of this information in all circumstances

This example, below, from a primary/secondary institution, gives parents the option of doing nothing, or having an opt out with very few choices available for customization. This opt out provides an all- or- nothing choice. Putting the “you do not need to do anything” language in bold, and by making the opt out sound difficult, this opt out form may discourage parents from opting out.60

If you agree to allow /xxxx/ School District to release directory information about your child, you do not need to do anything.

If you do not want your child’s directory information released, you must provide written notification to your child’s school principal within 20 days of enrollment. You may use this form or another form of written documentation to provide that notification. Please be aware that opting-out of releasing your child’s directory information will deny the release of this information in all circumstances; parents may not select items or circumstances under which some information may or may not be released. Parents must renew their required opt-out annually.

Positive Nudges

What if a FERPA opt out form contained a positive nudge? It might look something like this:

If you opt out, your directory information will not be made public, where it can potentially fall in the hands of data brokers who can use, keep, and sell your personal information for years or even decades.

Or:

If you have safety considerations, it may be in your best interest to submit a FERPA opt out. If you submit a FERPA opt out, your directory information will not be made public without your consent. Your home address, phone number, photograph, videos of you, and other information will not be disclosed to third parties, except in certain circumstances.

Best Practices:

  • Students should not be discouraged from utilizing their rights under FERPA by the use of subtle or overt negative language or “nudges.”
  • Schools need to consider that some students want FERPA opt outs because of serious safety considerations. Schools should ensure that they present a balanced view of FERPA opt outs.

Further Recommendations:

We recommend that the Department of Education examine its FERPA education materials and guidance for negative nudges, and similarly, should undertake a sincere effort to produce neutral or privacy – protective nudges in FERPA model opt out materials.

We also recommend that educational institutions at all levels review the emerging “nudge” literature as well as their current FERPA opt out language on web sites, letters, forms, and other materials. A good resource is the January 2020 recommendations on age-appropriate design for children from the UK Information Commissioner’s Office. Their recommendations include specific examples and discussion of nudge techniques, with specific examples geared to children. The ICO recommended that information designers not use nudge techniques to lead children to make poor privacy decisions, to use pro-privacy nudges where appropriate, and to consider nudging to promote health and wellbeing.

56 See Oyvind H. Kadestad, Deceived by Design, Norwegian Consumer Council, June 27, 2018. Available at: https://www.forbrukerradet.no/undersokelse/no-undersokelsekategori/deceived-by-design. This was a groundbreaking report on “nudges.” See also: Age Appropriate Design, 13. Nudge Techniques. Information Commission Office, UK. Available at: https://ico.org.uk/for-organisations/guide-to-data-protection/key-data-protection-themes/age-appropriate-design-a-code-of-practice-for-online-services/13-nudge-techniques/.

58 A PDF of this page is available at the World Privacy Forum office.

59 FERPA Directory Information Disclosure. A PDF of the page is available at the World Privacy Forum office.

60 FERPA Opt Out Form, school district. A PDF copy of this opt out form is available at the WPF office.


Part III. Additional FERPA- Related Privacy Issues in Schools

I. Online Student Directories at FERPA-covered Schools →

About half of colleges and universities studied post a directory of faculty and enrolled students online. The information in these directories falls under the rules for directory information as defined in FERPA. The directories may be made public, or may only be available through some form of authentication given by the school to enrolled students.

Of the directories that are made public, there is often a search function that allows a user to find a student or faculty member by name.

What the Research Found:

  • Of these schools, 46 postsecondary schools make the directory available to the general public and 12 postsecondary institutions require some form of authentication before logon.
  • We did not find examples of extensive interactive student directories online at studied primary or secondary schools.

56 percent of postsecondary schools have some form of online directory of students’ information, or 58/102 schools.

The research found that postsecondary schools were the main educational institutions that utilize student directory information to provide “phone directory” service online. It is a best practice to post the directories so that the directories are not accessible to the public. Among those directories that we found that were open to the public, we found several problematic implementations.

Example One: Ability to search online student directory by first name

One type of implementation that is problematic can be seen in a large university in the Southwest that maintains its university student phonebook online. The online phonebook allows for keyword searches for students’ names, and specifically allows for searches by first name. Anyone can search the phonebook, as it is not restricted to faculty and registered students.

By typing in first names like Susan, Bob, or any other potential first name of a student, a list of all students with that first name in the university are displayed.

The list also includes the following information:

  • Full name
  • Status as student
  • Email address
  • Graduate or undergraduate level designation
  • What college the student is studying in College of Science, etc.
  • The students major; civil engineering, Spanish, etc.61

This example of an online student directory is a partial listing of information designated by the university as directory information. Unless a student restricted disclosure through a FERPA opt out, then the students’ information is viewable online. FERPA does not require that schools display this information publicly, but they can if they choose to.

Public information dissemination is a problem for any student who is the victim of a crime or who has other safety concerns. Anyone with a working mobile phone and who could guess first names could find this information in the university’s phonebook. If safety problems arise for particular students mid-semester, it is not guaranteed that they will remember about their opt-out right and take action to protect their personal information.

Further, restricting public availability of student information keeps the information from data brokers. Because the world of data brokers is largely hidden from public view, it is unlikely that most students are aware that if they fail to opt out, their personal information can end up in commercial files with the potential to be used for the rest of their lives. This may not be a major issue with transitory information, but other data such as exact date and place of birth may have commercial value for a long time.

Example Two: Ability to search for student by last name

In another example of an implementation of an online student directory, a large urban university in the Northeast maintains a phone directory online that allows limited searching — for example, this directory does not allow for searching by first name, only by last name.

This university, however, lists some of its students by their full name at several of its colleges’ web sites. For example, a program of graduate study on a particular sub-college at the university listed all enrolled students by their full name on the program website. This information enables a search in the institution’s overall online student directory.

The full name search of the student directory at this institution gives the email address of that individual, along with the department, school, and year. That this institution’s phonebook does not allow searching by first name is a sound policy. However, it is a moot point because students’ full names are listed in full elsewhere on the site.62

Best Practices:

  • Because of the potential risks to student safety, it is a best practice for educational institutions to publish their online student directories privately. Only authenticated users (e.g., faculty, staff, and enrolled students) should have access.
  • It is a best practice to require knowledge of a student’s last name for searching, even if the directory requires authentication and is not open to the public.
  • Every effort must be made to prevent “site scraping” of student contact information in online student directories. Schools need to utilize strong anti-scraping software and techniques as a preventive security measure.

In the chart below, the green states indicate that the sampled postsecondary institutions in that state allowed public access to the student directory. Red/green indicates that institutions in that state had differences in approaches; at least one institution did not allow public access to the student directory in the split states. The red states indicate states where sampled institutions did not make the student directory publically accessible.

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Figure 21. 56 percent of postsecondary schools have some form of online directory of students’ information. Of these schools, 46 postsecondary schools make the directory available to the public and 12 postsecondary institutions require some form of authentication before logon.

61 A copy of the page cited is available at WPF offices and will be made available to qualified academic research requests.

62 A copy of the page cited is available at WPF offices and will be made available to qualified academic research requests.

II. Data Brokers, the Data of Minors, and Students’ FERPA Directory Information →

Data brokers are businesses that knowingly collect and sell or license to third parties the brokered personal information of a consumer with whom the business does not have a direct relationship.63 The U.S. Federal Trade Commission has said in its report on data brokers that “Data brokers acquire a vast array of detailed and specific information about consumers; analyze it to make inferences about consumers, some of which may be considered sensitive; and share the information with clients in a range of industries. All of this activity takes place behind the scenes, without consumers’ knowledge.”64

The World Privacy Forum has studied data brokers extensively.65 For the first time, we can document that data brokers are brokering the information of minors. We can also document that student directory information itself is being acquired by at least one company that has registered as a data broker.

Specifically:

  • Our research for this report found documentation that at least one company registered as a data broker is acquiring the directory information of students.
  • Some companies registered as data brokers have disclosed that they have actual knowledge that they possess the brokered personal information of minors. Some of this information included name, age, racial data, address, child ID, and gender, among other information.
  • At least one company that has registered as a data broker is collecting the images of minors for use in facial recognition.

Data brokers are important in the context of student directory information because students, parents, and schools need to be aware that student information that has been made public by being designated as “directory information” can fall into data broker hands. Data brokers can pose potential privacy risks because they can acquire, broker, analyze, and utilize information regarding identifiable individuals without being in a direct relationship with that individual. In some cases, data brokers will use data about individuals to predict behavior. (We wrote about this topic extensively in a report called The Scoring of America.66) Some data brokers use the information of minors to infer information about their parents, and then use those resulting inferences for marketing.

54 of 145 data brokers registered in the Vermont data broker registry responded that the company has “actual knowledge that it possesses the brokered personal information of minors.”

Information about students, especially high school and college students, has been available on data broker lists for many years. A search we conducted in 2020 for types of data broker information currently available about high school students found 748 list results for the search term “high school.”67 Data brokers may offer categories of data for sale through what the industry calls “data cards.”68 One data card described a mailing list of high school students approaching graduation. The data card stated:
“The Applications and Deadlines – High School Students Approaching Graduation mailing list boasts sophisticated, affordable consumer information specific to your advertising efforts targeting students ready to finish high school. These kids are getting ready to enter a new stage of their life. Whether they’re heading to a 4-year university, community college, or entering the workforce, these students are making big moves in their lives.” 69</px-3 Blockquote> Another data card described its marketing list of “High School Students Across the US” as being comprised of “extensive, in-depth consumer data for individuals currently attending high school.”70 The data card included the following description:
“High School Students Across The US Email/Postal/Phone Mailing List</px-3 Blockquote> Our High School Students Across The US mailing list is comprised of extensive, in-depth consumer data for individuals currently attending high school. Some of us consider these the awkward years, but for others they were the golden ones. This mailing list contains the in crowd, geeks, jocks, hipsters, and a rainbow of other cliques. These consumers are working to do anything to fit in – from buying used cars to wearing the trendiest clothes. The records from this list are consistently updated every month with National Change of Address processing (3x more often than our competitors do), and provide the latest data available for high school students. Over 97% deliverable, this list allows marketers to increase their customer base by focusing their advertising on a niche, target audience – high school students across the United States.”71</px-3 Blockquote> For this list, the privacy status was listed on the data card as “unknown.” Additional information that was available to be included with the list, called “selects,” included child’s age, ethnicity, dwelling size and type, interest categories, and additional highly specific information along with postal mailing address, email, and phone.

A Portion of the Selects for the “High School Students Across The US Email/Postal/Phone Mailing List,” Nextmark, #350243

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Figure 22. This screenshot captures a portion of the data card for the High School Students Across The US Email/Postal/Phone Mailing List, Nextmark, #350243, as displayed on Nextmark.com.

The existence of data broker lists are no longer a surprise, or they should not be. For example, the Federal Trade Commission wrote a lengthy and detailed report in 2014 about data brokers.72 Fordham University testified at the Vermont data broker study hearing and published a study regarding data brokers and student information in 2018.73 WPF has repeatedly testified about data brokers before states, federal agencies, and Congress, and has asked Congress and the states to act regarding data brokers. Progress has been excruciatingly slow, but there has been some progress.

Notably, in 2018 Vermont became the first state in the country to pass a law regarding data brokers.74 The law passed in May 2018, and the state’s data broker registry became a requirement in January 2019. Until the Vermont data broker registry came online in 2019, it was nearly impossible to achieve transparency regarding the direct transfer of student directory information from schools to companies. While it was possible to locate lists of high school and college students’ data on data broker lists, irrefutable proof of direct transfers of school directory information under FERPA from schools to data brokers was not available.

A 2018 Fordham report75 was the first to analyze information available regarding students and data brokers. The authors, through extensive Freedom of Information Act requests, found that the New York City Department of Education provided student directory information to the National Student Clearinghouse (The documentation is on file with Fordham CLIP).76

Two states currently have data broker registries: Vermont, which as previously noted was the first state to have such a registry, and California.77 WPF’s findings rely on the Vermont registry, because it has disclosure requirements regarding the data of minors. California’s statute does not require mandatory disclosure regarding the information of minors.

The Vermont Data Broker Registry,78 which has been accessible to the public for review since 2019, has created some transparency into how data brokers process information about minors.79 Data brokers operating in the state of Vermont must disclose in their registration filings whether the company has “actual knowledge that it possesses the brokered information of minors.”80 It is through this transparency requirement that a company registered in Vermont as a data broker revealed that it has specifically acquired student directory information subject to FERPA.81

We have charted and analyzed the active data broker filings in the Vermont registry current to February 2020, and their responses to whether or not they possess the brokered personal information of minors. Some key findings from our research includes the following:

One Vermont data broker registrant, the National Student Clearinghouse, states in its filing that it collects student data from participating postsecondary educational institutions, including directory information. One part of its filing stated:

“NSC collects student data from participating postsecondary institutions and discloses such data to 3rd parties as contractually authorized by such institutions, in compliance with the Family Educational Rights & Privacy Act. FERPA allows disclosure of directory information (DI) without consent unless the student has opted-out of having their DI disclosed, and NSC respects such opt-outs as FERPA requires. Individuals may opt-out of the disclosure of their DI by notifying their institution.”

Regarding the information of minors, the National Student Clearinghouse stated:

There are rare cases in which the Clearinghouse has actual knowledge that it possesses such information on minors who are or who have been enrolled in postsecondary education. We collect, maintain, and protect this data with the same robust policies we apply to all student data, and respect the same FERPA directory information opt-out rights as we do for non-minors enrolled in postsecondary education. See our privacy policy at: https://www.studentclearinghouse.org/privacy-policy/.” 82

One Vermont data broker registrant, Acxiom, uses the data of minors to create insights related to the minor’s adult parent. One part of Acxiom’s filing stated:

“Acxiom will not knowingly disclose identifiable data on minors under 18 to third parties for use in marketing. We do use data such minor data to identify/remove records from our and our clients’ marketing files. We use such minor data in creating insights solely related to the minor’s adult parent, but we don’t disclose identifiable data about the minor in the insights created. Where permitted by law, we use and disclose minor data for non-marketing uses(e.g, fraud detection/prevention products).”83

Acxiom did not state where the information of minors was acquired. As a result, it is not possible at this time to know if directory information is the source for this data or not. It is unknown how Acxiom (or other data brokers) handle the information of minors when those minors reach the age of majority. In Vermont, the age of majority is 18 years old.84

Another Vermont data broker registrant, Experian Marketing, collects detailed data elements relating to minors, including date of birth, gender, ethnicity, “Child’s Person ID,” and uses this and other information to create a score indicating the presence of children indicator. One part of Experian’s filing states the following:

“Experian acquires and maintains the following data elements as they relate to minors within our ConsumerView relational database repository:

  • Parents Name
  • Child’s name if available
  • Child’s Date of Birth (includes full date of birth, month/year, exact age, combined age)
  • Child’s Person ID
  • Child’s gender
  • Child’s ethnicity
  • 1st child indicator
  • Address

Experian uses this data to create a modeled probability score and data elements that indicate the presence of children within prescribed age ranges in a household. Experian licenses this presence of children indicator to third parties to market to a household or parents, with use of presence of children indicators representing children three years old or younger requires prior Experian review and approval. Experian does not release the children’s data elements listed above to any external third parties.

Experian also collects and maintains the following data elements as they relate to minors in our Social Security Administration Death Master File:

  • Child’s name
  • Child’s Social Security Number o Child’s Date of Birth
  • Child’s Date of Death
  • Verification Code

Experian licenses the Death Master File from the Social Security Administration. We use the file for fraud prevention and for legitimate business purposes in compliance with applicable law, rule, regulation or fiduciary duty.”85

Note: To see the detailed information we have cited from the Experian filing, it will be necessary to locate the addendum to the Experian filing.86

Another Vermont data broker registrant, Clearview AI, collects images of minors that are “publicly available,” and uses them in their facial recognition product(s) except for the images of minors who are California residents. Clearview AI states the following in one part of its Vermont data broker registration filing:

“Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.” 87

We do not know if Clearview AI acquired the information of minors from school websites, but we do know that Clearview AI acquired information from social media websites. It remains a distinct possibility that Clearview AI acquired student images that schools posted on social media sites.88

Student Directory Information and Third Parties

It is possible that few schools realize the full extent of the modern privacy issues related to what happens to directory information after it has been made public. As we have discussed in this report, under current FERPA regulations, schools may choose to provide students’ directory information to third parties without prior consent from parents or eligible students. Schools are not required to disclose if they routinely give directory information to third party companies. If an educational institution meets the conditions for releasing students’ directory information, and if a student/parent did not opt out of the sharing of directory information, then the school may share the information it has designated as directory information with third parties, essentially without restriction.89 Even if a school did not specifically share directory information with any particular third party, and just posted student directory information on a publicly available website, this information can be acquired through web scraping.90

Moreover, once disclosed, unless a specific law is in place restricting onward use, no existing mechanism prevents onward transfer of directory information by an initial recipient, including data brokers. Congress should consider closing this gap in privacy protections by limiting, impeding or prohibiting onward transfer (or sale) of students’ directory information by third parties.

A bright spot exists: the state of New York, in January 2020, took action on this very issue by amending its regulations to prevent the sale of student data.91 The New York State Education Department’s amended statute requires, in part the following:
§121.2 Educational Agency Data Collection Transparency and Restrictions.</px-3 Blockquote> a. Educational agencies shall not sell personally identifiable information nor use or disclose it for any marketing or commercial purpose or facilitate its use or disclosure by any other party for any marketing or commercial purpose or permit another party to do so.</px-3 Blockquote> b. Each educational agency shall take steps to minimize its collection, processing and transmission of personally identifiable information.</px-3 Blockquote> The new amendments that the New York State Education Department has passed are important exemplars of modern privacy approaches and help ensure students’ personal information does not become a source of income for commercial marketers. These amendments will help prevent schools, particularly postsecondary schools, from being tempted by offers for the purchase or transfer of student directory information.

New York’s approach is helpful, because parents enrolling a child in kindergarten who know enough to opt out and who actually opt out, face 13 years of filing opt out forms before the child graduates from high school. Parents who just once in all those years fail to file an opt out form on time will be unable to keep their child’s information from being released to third parties who seek to exploit directory information from schools.

As a society, we can and must do better in protecting the information of children and students. And we can start by ensuring that schools:

  • Designate the minimum necessary school directory information.
  • Do not designate photographs as directory information, and do not allow student images or detailed information to be posted publicly online.
  • Ensure that all parents and all eligible students have meaningful, year-round access to FERPA notices and opt outs.
  • Ensure that schools are offering an environment that is supportive of FERPA opt out, and take the necessary steps to ensure that the information of minors never ends up in the hands of data brokers.

Additionally, schools will need to develop technology that defends against web scraping of data from school websites, both images and text related to specific students. See the biometric section in this report for more information about these kinds of techniques and issues.

In conclusion, while it is not possible to know where the information of minors has been acquired in every instance, that we now know it is being acquired by data brokers is of great concern. Schools should do everything they can to ensure that they are not the source of students’ information “in the wild” that can be collected by third parties and then associated with those students and used for years.

Best Practices:

  • As a best practice, States should consider additional protections for the information of minors in light of the new information that has become available that unambiguously documents the presence of the information of minors in data broker databases.
  • New York State’s Education Department has adopted an amendment, which specifically prohibits the sale of personally identifiable student data. This is a policy best practice, and is the kind of structural protection from onward transfer of student data is needed as a best practice. Student directory information that parents or students did not opt out of also needs protections.
  • Schools should review all contracts with third parties, including vendors. If a vendor is utilizing student directory information, schools should take steps to ensure that directory information is specified as restricted in its use by the vendor and restricted from onward uses. Directory information does not enjoy the same levels of protection as protected student information under FERPA. Note: All types of directory information need to be considered, including photos if a school has made them directory information. (See the discussion of risks regarding student photographs, including some yearbook photographs, in the discussion of biometrics in this report.)
  • Schools should take great care to not release directory information subject to opt out restrictions to third parties. Schools should review contracts and procedures to ensure directory information that is subject to restrictions (opt out) is secured and only released per the regulations.
  • Because data brokers can acquire information from some school web sites through web scraping, it is a best practice for schools at all levels to utilize anti-scraping software and techniques to protect student information posted on school websites. Student photographs, names, and other information can be and are being scraped from school websites unless schools take active steps to restrict this activity. Scraped data can be used for many years. Protections include placing all student data and photographs in a protected area of the webs site and only allowing authenticated access to that area.
  • Directory information should follow a minimum necessary rule. Schools are not required to share directory information. Whenever possible, this should be the norm, not the exception.

Further Recommendations:

Schools, parents, and students should take steps to educate themselves about data broker activities and to protect student directory information.

We also urge the Department of Education, Congress, Attorneys Generals, and State legislatures to take steps to ensure student directory information is not being acquired from schools for unrestricted uses.

Vermont Data Broker Registry Active Registrations

Companies that answered “Yes” to “Does the data broker have actual knowledge that it possesses the brokered personal information of minors:”

(Active registrations as of February 2020, last checked April 2020)

Name

Provide a statement detailing the data collection practices, databases, sales activities, and opt-out policies that are applicable to the brokered personal information of minors:

ACCUDATA INTEGRATED MARKETING, INC.

AccuData does not actively collect consumer data nor do we market consumer products and services to minors. Our third-party providers are responsible for restricting the collection and distribution of information about minors.

ACXIOM LLC

Acxiom will not knowingly disclose identifiable data on minors under 18 to third parties for use in marketing. We do use data such minor data to identify/remove records from our and our clients’ marketing files. We use such minor data in creating insights solely related to the minor’s adult parent, but we don’t disclose identifiable data about the minor in the insights created. Where permitted by law, we use and disclose minor data for non-marketing uses(e.g, fraud detection/prevention products)

Advertise4Sales LLC

Our services are intended only for those over 18 years of age

Amerilist Inc

We do not collect data. Only broker.

AmRent, Inc.

AmRent may possess brokered personal information of minors where the criminal or traffic case is a matter of public record. AmRent does not possess information on juvenile cases. Information is only disclosed in accordance with the Fair Credit Reporting Act.

ASL MARKETING INC

We will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws. If a parent believes their child under 13 gained access to our site without their permission, there is a link to contact us. We do not market products or services for purchase by children.

backgroundchecks.com LLC (“BGC”)

On occasion, BGC may be asked to provide background screening services in relation to a minor; for example, when a minor has applied for a job. BGC’s practices as they relate to minors are the same as those described in response to question #4.

BLACK KNIGHT DATA & ANALYTICS, LLC

D&A does not knowingly collect any personal information of minors.

Blackbaud, Inc.

The Cooperative Database does not include minors.

CareerBuilder Employment Screening, LLC

Minors follow the same data collection processes as all consumers authorizing the performance of a background check. They are subject to the same opt-out rights as all consumers.

CDK Global, LLC

We have not any brokered personal information of minors.

Civis Analytics, Inc.

We do not collect personal data from any person we know to be under the age of 13, and we will delete any personal data collected that we later know to be from a person under the age of 13. Our site and services are for general audiences and is not targeted to children under 13 years of age. If you believe a child under the age of 13 has disclosed personal data to us, please contact us at dataprotection@civisanalytics.com.

Clarity Services, Inc.

Clarity does not separately track or flag credit files on minors, and, thus, if Clarity receives a valid inquiry for a consumer credit file on a minor, Clarity will provide a credit report.

Clearview AI, Inc.

Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.

COMPACT INFORMATION SYSTEMS

We do not maintain any PII of minors.

CoreLogic Credco of Puerto Rico

Credco accepts requests including but not limited to consumer file disclosure, consumer report copy, disputes, opt-out, security freeze, consumer statement, content of report, extended fraud alert, inquiry trace, and identity theft blocking requests from authorized third parties on behalf of minors or emancipated minors authenticated in accordance with our procedures.

CoreLogic Credco, LLC

Credco accepts requests including but not limited to consumer file disclosure, consumer report copy, disputes, opt-out, security freeze, consumer statement, content of report, extended fraud alert, inquiry trace, and identity theft blocking requests from authorized third parties on behalf of minors or emancipated minors authenticated in accordance with our procedures.

CoreLogic Solutions, LLC

This is not applicable, as CoreLogic Solutions does not knowingly process or provide data to our clients related to minors.

Data Facts, Inc.

Children Under Age 13. Data Facts does not offer services to children under the age of 13, and this website is not directed to children under the age of 13. Data Facts does not knowingly collect information about children under the age of 13.

DataMentors LLC dba V12

V12 does not intentionally collect and is not aware of any data in its possession, custody or control that pertains to any individual under the age of 18. In the event V12 becomes aware of such data, its policy is to delete such data.

DATAX LTD

DataX may receive information from its data furnishers on minors. DataX does not knowingly provide credit reports on minors under 16 to its customers, but if the minor’s age or date of birth are not accurately provided by the data furnisher, it is possible that a minor’s credit report could be created within the database. DataX will allow the parent or guardian of a minor to place a security freeze on the minor’s credit file upon receipt of a valid power of attorney or other documentation specifying guardianship as provided under the protected consumer state security freeze laws.

Drobu Media LLC

None.

Edvisors Network, Inc.

We do not collect, share or sell data on minors under the age of 13. We have processes in place for adherence to COPPA (“Children’s Online Privacy Act”).

eMerges.com, INC

If a public record has birth date indicating the person is less than 18 years old or an indicator such as “junior” on a hunting and fishing license, we suppress that record and do not release it except for Political, law enforcement and government identification or authentication type use.

EQUIFAX INFORMATION SERVICES LLC

Equifax may receive information from its data furnishers or end-users on minors. Equifax takes steps to remove any information on consumers under the age of 21, or consumers for whom no age or date of birth is available, from the Equifax Credit Marketing Database, so that no minor consumer’s credit information is accessed for purposes of prescreening. Equifax does not knowingly provide credit reports on minors under the age of 16 to its customers, but if the minor’s age or date of birth are not provided, it is possible that a minor’s credit report could be issued. Equifax does allow the parent or guardian of a minor under the age of 16 to place a security freeze on the minor’s credit file, subject to the proof of identity and proof of authority requirements of the FCRA.

Experian Data Corp

RentBureau does not knowingly collect minor data.

Experian Fraud Prevention Solutions, Inc.

Experian Fraud Prevention Solutions does not knowingly collect minor data.

Experian Information Solutions, Inc.

Experian collects personal information of a minor (under the age of 18) if a parent or guardian contacts Experian with a request to place a freeze on a minor file pursuant to Section 301(j) of the Economic Growth, Regulatory Relief and Consumer Protection Act. Following such a request, Experian creates a credit file and places a credit freeze for the minor consumer. It also flags the file in the database as minor file which means that the file will not be displayable until consumer reaches 18.

Experian Marketing Solutions, LLC

Due to character limitations within the online application, question 7 response has been provided below.

7. Where the data broker has actual knowledge that it possesses the brokered personal information of minors, provide a statement detailing the data collection practices, databases, sales activities, and opt-out policies that are applicable to the brokered personal information of minors:

  • Experian acquires and maintains the following data elements as they relate to minors within our ConsumerView relational database repository:
    • Parents Name
    • Child’s name if available
    • Child’s Date of Birth (includes full date of birth, month/year, exact age, combined age) o Child’s Person ID
    • Child’s gender
    • Child’s ethnicity
    • 1st child indicator
    • Address

Experian uses this data to create a modeled probability score and data elements that indicate the presence of children within prescribed age ranges in a household. Experian licenses this presence of children indicator to third parties to market to a household or parents, with use of presence of children indicators representing children three years old or younger requires prior Experian review and approval. Experian does not release the children’s data elements listed above to any external third parties.

  • Experian also collects and maintains the following data elements as they relate to minors in our Social Security Administration Death Master File:
    • Child’s name
    • Child’s Social Security Number o Child’s Date of Birth
    • Child’s Date of Death
    • Verification Code

Experian licenses the Death Master File from the Social Security Administration. We use the file for fraud prevention and for legitimate business purposes in compliance with applicable law, rule, regulation or fiduciary duty.

FIRST ORION CORPORATION

First Orion does not knowingly collect personal information from minors. If a minor submits personal information to First Orion and it learns that the personal information is about a minor, it will delete the information as quickly as possible.

General Information Solutions LLC (“GIS”)

On occasion, GIS may be asked to provide background screening services in relation to a minor; for example, when a minor has applied for a job. GIS’s practices as they relate to minors are the same as those described in response to question #4.

ID Analytics, LLC

Technical controls are in place to highlight instances when the request is determined to be on a minor.

InCheck Inc

InCheck only conducts background checks on minor applicants if authorization is obtained by the minor’s parent(s) or legal guardian(s). InCheck collects personal information of minors from court documents only if the court proceeding occurred in a non-juvenile criminal court. Per the Fair Credit Reporting Act, InCheck does not collect personal information associated with any juvenile cases/sealed cases.

Inflection Risk Solutions, LLC

Inflection does, in limited cases, provide customers the ability to perform background checks on minors older than 13. In these rare cases, the minor’s parental consent is obtained. Juvenile records are not reported. Minors who are the subject of background checks are subject to the same collection, database, sales, and opt-out policies as those provided to adult data subjects. More information may be found at www.goodhire.com/privacy and https://www.inflection.com/privacy-polic.

Insurance Services Office, Inc.

This data is captured as part of insurance information that is provided to ISO from insurers, and other similar third-parties, and includes information concerning youthful drivers and workers/employees, as well as youthful victims of motor vehicle and homeowner accidents.

IQ Data Systems, Inc. dba Backgrounds Online

We do not produce consumer reports for minors unless a parent or guardian first provides written authorization. This may occur when a minor applies for part-time employment.

L2, Inc.

L2 does not knowingly acquire or maintain any information on minors.

LEXISNEXIS RISK SOLUTIONS INC. AND AFFILIATES

LexisNexis Risk Solutions does not specifically seek brokered information of minors for collection, but in the process of collecting brokered information generally, does receive such information. LexisNexis does not have specific data collection practices, databases, sales activities or opt-out policies that are applicable to the brokered personal information of minors. Many LexisNexis Risk Solutions products filter out records if the record indicates a date of birth suggesting a minor.

NATIONAL STUDENT CLEARINGHOUSE

There are rare cases in which the Clearinghouse has actual knowledge that it possesses such information on minors who are or who have been enrolled in postsecondary education. We collect, maintain, and protect this data with the same robust policies we apply to all student data, and respect the same FERPA directory information opt-out rights as we do for non-minors enrolled in postsecondary education. See our privacy policy at: https://www.studentclearinghouse.org/privacy-policy/.

NFocus Consulting, Inc.

While NFocus Consulting possesses BPI about a household it does not maintain PII of minors. Data elements are used to build insights concerning an adult parent, a household and even a geographical unit. This information is then used to identify target audiences for marketing efforts. Orders include records for a household or an adult residing in a household. NFocus does not maintain names or identifying numbers for minors nor can data elements present be reasonably linked to a specified minor.

Nuwber Inc

Nuwber does not knowingly acquire and possess the brokered personal information of minors.

Oracle America, Inc. (Oracle Data Cloud)

The ODC does not intentionally collect personal information from, and does not tailor any services to, children under 16 years of age. Further, we prohibit our ODC partners from providing Oracle with personal information from sites directed to children under the age of 16 or from consumers whose age these companies know to be under the age of 16. If we become aware of data on children under 16 years of age, we take steps to remove the data from our databases.

Path2Response

We do not have any information on minors that we are aware of.

Project Applecart LLC

Not applicable

Refinitiv US LLC

Refinitiv’s products are not directed to minors. In the limited circumstances where Refinitiv obtains and uses brokered personal information of minors (for example, because they are the children of a politically exposed person), Refinitiv applies appropriate controls in accordance with industry guidelines and applicable laws.

Rental Property Solutions, LLC

The system will not process data requests for consumers under the age of 18.

Riv Data Corp. dba Carpe Data

Because Carpe Data receives requests from insurance carriers for data about individuals who could be the subject of an insurance claim, it is possible that data on minors is included at times. However, Carpe Data does not always receive DOB from its customers.

SageStream LLC

As discussed above, SageStream delivers credit risk scores and attributes to clients in accordance with the FCRA and VFCRA. In certain circumstances, the FCRA allows a consumer reporting agency to generate a consumer report on a minor (e.g., prescreen purposes) subject to certain requirements and limitations (see 15 U.S.C. §1681b(c)(1)(B)(iv). Technical controls are in place to highlight responses when the request is determined to be a minor.

Speedeon Data, LLC

Speedeon Data does not knowingly possess nor distribute any data of minors and will remove any data if it is identified as such. Speedeon requires its customers to warrant compliance with all laws, including those related to marketing to minors.

TALX CORPORATION [Author’s note: also known as The Work Number ]

TALX may receive information from its data furnishers on minors. TALX does allow parents or guardians to place a security freeze on a minor’s consumer report if a valid power of attorney or other documentation specifying guardianship is provided as required under the protected consumer state security freeze laws.

Teletrack, LLC

Teletrack does not maintain databases of personal information of consumers who are under 17 years of age.

TransUnion

TransUnion does not knowingly solicit or collect information from children and does not knowingly include them in its products and services. TransUnion does not use TransUnion data to target or market to children and does not provide personal information of children to any third parties.

West Publishing Corporation

To the extent that we can identify any minors in our databases we proactively exclude them from our collections.

WhitePages, Inc.

Data Broker does not display or sell information of minors when it has actual knowledge that the information belongs to minors and, to the extent possible, it identifies and suppresses this information when integrating new data sets into its products. Data Broker does not knowingly purchase brokered personal information of minors.

63 In this report, we are using the definition of “data broker” used in the Vermont data broker statute. See: Act No. 171. An act relating to data brokers and consumer protection. Chapter 62, Subchapter I. §2430, (4)(A): “Data broker” means a business, or unit or units of a business, separately or together, that knowingly collects and sells or licenses to third parties the brokered personal information of a consumer with whom the business does not have a direct relationship.” Available at: https://legislature.vermont.gov/Documents/2018/Docs/ACTS/ACT171/ACT171%20As%20Enacted.pdf.

64 Data Brokers: A call for transparency and accountability. U.S. Federal Trade Commission, May 2014. Available at: https://www.ftc.gov/system/files/documents/reports/data-brokers-call-transparency-accountability-report-federal-trade-commission-may-2014/140527databrokerreport.pdf. See Page vii.

65 See Pam Dixon and Robert Gellman, The Scoring of America, World Privacy Forum, April 2, 2014. Available at: https://www.worldprivacyforum.org/2014/04/wpf-report-the-scoring-of-america-how-secret-consumer-scores-threaten-your-privacy-and-your-future/. See also WPF’s Congressional Testimony regarding data brokers in 2011, 2013, 2015, and 2019. See also: Robert Gellman and Pam Dixon, Data Brokers and the Federal Government, 2013, World Privacy Forum. Available at: https://www.worldprivacyforum.org/category/report-data-brokers-and-the-federal-government/. See also: Testimony of Pam Dixon, Data Brokers and Their Impact on Financial Data Privacy, Credit, Insurance, and Housing, US Senate Committee on Banking, Housing, and Urban Affairs, Tuesday June 11, 2019, Available at: https://www.banking.senate.gov/hearings/data-brokers-and-the-impact-on-financial-data-privacy-credit-insurance-employment-and-housing. See also WPF Testifying at Key FTC Consumer Privacy Hearing Re: Privacy Frameworks, Data Brokers, and Potential Solutions, April 10, 2019. Available at: https://www.worldprivacyforum.org/events/wpf-testifying-at-key-ftc-consumer-privacy-hearing-re-privacy-frameworks-data-brokers-and-potential-solutions/. See also, Testimony of Pam Dixon Before the US Senate Committee on the Judiciary, Subcommittee on Privacy, Technology, and the Law, Data Brokers – is Consumer’s Information Secure? November 3, 2015. Available at: https://www.judiciary.senate.gov/imo/media/doc/11-3-15%20Dixon%20Testimony.pdf. See also: Testimony of Pam Dixon before the US Senate Committee on Commerce, Science, and Transportation, What Information Do Data Brokers Have on Consumers, and How do They Use It? December 18, 2013. Available at: https://www.commerce.senate.gov/2013/12/what-information-do-data-brokers-have-on-consumers-and-how-do-they-use-it.

66 See Pam Dixon and Robert Gellman, The Scoring of America, World Privacy Forum, April 2, 2014. Available at: https://www.worldprivacyforum.org/2014/04/wpf-report-the-scoring-of-america-how-secret-consumer-scores-threaten-your-privacy-and-your-future/.

67 Nextmark Consumer List Search, all channels, “high school.” Nextmark. Search conducted at: https://lists.nextmark.com/market. This same keyword search was repeated throughout the research period to assess the availability of lists on the topic.

68 A data card is a short description of the information available in a data broker list.

69 Applications and Deadlines – High School Students Approaching Graduation Mailing List, Nextmark, #349837, Available at: https://lists.nextmark.com/market?page=order/online/datacard&id=349837.

70 High School Students Across The US Email/Postal/Phone Mailing List, Nextmark, #350243 , Available at: https://lists.nextmark.com/market?page=order/online/datacard&id=350243.

71 High School Students Across The US Email/Postal/Phone Mailing List, Nextmark, #350243 , Available at: https://lists.nextmark.com/market?page=order/online/datacard&id=350243.

72 Data Brokers: A call for transparency and accountability. U.S. Federal Trade Commission, May 2014. Available at: https://www.ftc.gov/system/files/documents/reports/data-brokers-call-transparency-accountability-report-federal-trade-commission-may-2014/140527databrokerreport.pdf.

73 N. Cameron Russell, Professor Joel R. Reidenberg, et al. Transparency and the Market for Student Data, Fordham University, 2018. The Fordham CLIP testimony in Vermont was influential in creating awareness of the need to address the impact of data brokers on minors. WPF also testified at the Vermont hearing.

74 Devin Coldewey, Vermont passes first law to crack down on data brokers, TechCrunch, May 27, 2018. Available at: https://techcrunch.com/2018/05/27/vermont-passes-first-first-law-to-crack-down-on-data-brokers/.

75 Data Brokers: A call for transparency and accountability. U.S. Federal Trade Commission, May 2014. Available at: https://www.ftc.gov/system/files/documents/reports/data-brokers-call-transparency-accountability-report-federal-trade-commission-may-2014/140527databrokerreport.pdf.

76 N. Cameron Russell, Professor Joel R. Reidenberg, et al. Transparency and the Market for Student Data, Fordham University, 2018. Available at: https://www.fordham.edu/info/23830/research/10517/transparency_and_the_marketplace_for_student_data/1.

77 California Data Broker Registry, California Attorney General’s Office. Available at: https://www.oag.ca.gov/data-brokers. The registry in California is active.

78 Vermont Data Broker Registry Search, Vermont Secretary of State, Corporations Division. Available at: https://www.vtsosonline.com/online/DataBrokerInquire.

79 Act No. 171 (H.764). Commerce and trade; consumer protection An act relating to data brokers and consumer protection, (9 V.S.A. ch. 62, subch. 5).

80 Vermont Data Broker Registry Search, Vermont Secretary of State, Corporations Division. Available at: https://www.vtsosonline.com/online/DataBrokerInquire.

81 National Student Clearinghouse, Data Broker Registration, Vermont, 2/11/2019, Registration ID 353284, Filing number 0002513425. Available at: https://www.vtsosonline.com/online/DataBrokerInquire/FilingHistory?businessID=353284. The National Student Clearinghouse works directly with schools to provide services. See About the Clearinghouse, Available at: https://www.studentclearinghouse.org/about/how-we-serve-the-k-20-to-workforce-continuum/. The NSC has signed a K-12 Privacy Pledge, available at https://www.studentclearinghouse.org/about/how-we-serve-the-k-20-to-workforce-continuum/. The NSC has signed a K-12 Privacy Pledge, available at https://studentprivacypledge.org/privacy-pledge/.

82 National Student Clearinghouse, Data Broker Registration, Vermont, 2/11/2019, Registration ID 353284, Filing number 0002513425. Available at: https://www.vtsosonline.com/online/DataBrokerInquire/FilingHistory?businessID=353284. The U.S. Department of Education provided guidance to the National Student Clearinghouse in 1993. Letter to Daniel R. Boehmer, U.S. Department of Education, April 19, 1993. Available at: https://studentprivacy.ed.gov/sites/default/files/resource_document/file/ferpa-nsc.pdf.

83 Acxiom, Data Broker Registration, Registration ID 352752

Vermont 1/30/2019, Filing number 0002506353. Available at: https://www.vtsosonline.com/online/DataBrokerInquire/DataBrokerInformation?businessID=352752.

84 Vermont Statutes Annotated, Title 33, Chapter 59.

85 Filing of Experian Marketing, Registration ID 367915, Jan. 31 2020, Vermont Data Broker Registry, Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367915.

86 To view the Experian Marketing addendum, after accessing https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367915, click on filing history, then click on Data Broker Registration. Scroll down to the last page, and a letter containing the information is available as an attachment to the filing.

87 Filing of Clearview AI, Registration ID 367103, January 14, 2020, Vermont Data Broker Registry. Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367103. See: Response to Question 7: “Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.”

88 Anna Merlan, Here’s the file Clearview AI has been keeping on me, and probably on you too, Vice, Feb. 28, 2020. Available at: https://www.vice.com/en_us/article/5dmkyq/heres-the-file-clearview-ai-has-been-keeping-on-me-and-probably-on-you-too. The author of this article used the California Consumer Protection Act (CCPA) to request the information that Clearview AI held on her. She found that the company had collected, or “scraped,” photos of her from MySpace, Twitter, Instagram, and other websites.

89 “Publicly released” is defined in FERPA under disclosure. “Disclosure means to permit access to or the release, transfer, or other communication of personally identifiable information contained in education records by any means, including oral, written, or electronic means, to any party except the party identified as the party that provided or created the record.” 34 CFR Part §99.3.

90 The U.S. Government Accountability Office described web scraping in the data broker context in this way: “Federal laws generally do not govern the methods resellers may use to collect personal information for marketing or look-up purposes. Examples of such methods include “web scraping”—sometimes called data extraction or web data mining—in which resellers, advertisers, and other parties use software to search the web for information about an individual or individuals, and extract and download bulk information from a particular website that contains consumer information.” Information Resellers, U.S. Government Accountability Office, September 2013. Available at: https://www.gao.gov/products/GAO-13-663.

91 Amendment to the Regulations of the Commissioner of Education, Pursuant to Education Law sections 2-d, 101, 207 and 305, a new Part 121 shall be added effective upon adoption to read as follows: Part 121, Strengthening Data Privacy and Security in NY State Educational Agencies to Protect Personally Identifiable Information. The amendment is available at: New York State Education Department, http://www.nysed.gov/common/nysed/files/programs/student-data-privacy/proposed-part-121-for-pii.pdf.

III. Student Biometric Data and FERPA Directory Information →

Biometric data is included in the definition of personally identifiable information under FERPA. This means that biometric information held by schools is considered protected information under FERPA, and may only be released by schools with consent. FERPA defines biometrics as:
“Biometric record,” as used in the definition of “personally identifiable information,” means a record of one or more measurable biological or behavioral characteristics that can be used for automated recognition of an individual. Examples include fingerprints; retina and iris patterns; voiceprints; DNA sequence; facial characteristics; and handwriting.92</px-3 Blockquote> Prior consent is required before a school can release the student biometric data that it holds. Most schools are cautious about the student biometric data they hold, and currently, there is a debate about whether or not schools can or should use biometrics to identify students for attendance purposes, or for identifying students in the school lunch context. This debate is important. But a major biometric threat that schools have overlooked is what is happening to student directory information.

Research for this report documents unambiguously that some facial recognition companies are “scraping” web sites to collect images from those sties, and at least one such company has scraped images of minors for use in one or more of its biometric products. It is no longer unreasonable to surmise that school web sites, which are potential sources for concentrated images of the faces of minors, can be among the sites targeted to be scraped.

Research for this report also found that some yearbook companies are using face recognition software in creating school yearbooks. The privacy policies of these companies vary widely.

What the Research Found:

  • The research also found that even if schools do not specifically designate photographs as directory information, many of the schools studied have posted student photographs online in some form, for example, on a social media site, a school web site, or in a newsletter posted online.
  • Digital photographs posted online on a school website under a directory information exemption are public data.
  • WPF found face recognition test databases that include the images of children that were found in the public domain online. For example, test databases such as MegaFace contain the images of children. MegaFace images were taken from Flickr posts.93
  • WPF found that some companies providing yearbook services to schools now utilize face recognition on student photos. When schools designate student photographs as directory information, yearbook companies do not have to get parental or student consent before making a face recognition template of a student’s photo, because photographs that have been designated as directory information are public information.

49 percent of studied schools include student photographs in directory information that can be released without prior consent.

Educational institutions have been grappling with issues and concerns about biometrics, especially face recognition systems and fingerprinting systems.94 Much of the discussion around school biometrics to date has been focused on face recognition or fingerprinting that the schools themselves are conducting.95 The debate has led to state laws that ensure students will not be asked to provide a biometric without consent, among other protections.96 These are important aspects of the biometrics debate. But this is only one aspect of the discussion. Two major risk points exist: scraping of student photos posted online, and yearbook companies that are using face recognition on student photos.

Risks Related to Scraped Student Photographs

An important point of risk that has been widely overlooked at schools is that students whose photographs are designated as directory information and are then posted publicly can have their images “scraped” and used in commercial biometric identification systems that students don’t know about, and may have no control over.

For background, web scraping activities can collect images posted publicly on web sites.97 If students’ images were posted by schools using the directory information exemption, then those images, if scraped, were scraped without prior consent from parents or eligible students.

The reason image scraping in particular is happening is because face recognition systems need large volumes of photographic, or image, data to train face recognition algorithms and accomplish other tasks. Digital images are the “raw resource” for such systems, and this has created a demand for images of people of all ages, including minors.98 One well-known database contains 26,580 photos of 2,284 subjects, including minors, whose images were “in the wild,” i.e., in the public domain.99

Additional public data sets of scraped images exist,100 and include the large Labeled Faces in the Wild (LFW) dataset101 and the CASIA-Web Face dataset.102 The CASIA dataset contains 494,414 images of 10,575 subjects. The LFW dataset, also public, contains 13,233 images of 5,749 subjects, some of whom are children. The VGGFace2 database has 3.31 million face images or 9131 subjects across age ranges.103 The demand for face images must not be underestimated — some biometric companies have negotiated partnerships with the governments of countries in part to acquire the rights to use photographs of their citizenry for training face recognition systems.104

Recently, news reports in 2020 have disclosed that even larger datasets of faces now exist from web scraping activities. One company named Clearview AI has reportedly scraped 3 billion images from websites and social media sites to acquire images for use in face recognition products.105 The scraping has been independently confirmed.106 This same company has specifically disclosed in the Vermont Data Broker registry in January of 2020 that it collects the publicly available images of minors for its use:

“Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.” 107

Did this company scrape images on school websites? The filing does not indicate a yes or a no answer to this question. Have any other face recognition companies scraped school websites? We do not have documentation of this. Have students’ images posted by schools on school social media web sites been scraped? We don’t know for certain, yet. But we do know that social media websites have been scraped. It is important that regulators, parents, students, and schools get answers to these questions and find out if student images have been scraped from school websites or school social media web sites. The scraping of students’ photographs posted online for facial recognition databases and products needs to be addressed as soon as possible.

By itself, the demand for photographs of minors for use in face recognition systems should be of ample concern. An additional concern is that face recognition performed on children has been well documented to have high error rates relative to adults.108 This is an additional factor that can drive higher demand for images of minors — including very young children — in order to test and correct for age-related challenges in face recognition systems.

Biometric systems can persist for many years and be used in contexts far beyond what a school faculty or staff member ever imagined when innocently posting a photograph of an honor roll student, or the winner of a contest on the school’s public web site. FERPA specifically regulates students’ biometric information that schools hold. But FERPA is silent on the risk of the use of students’ photographs designated as directory information as providing raw material for the testing, development, and use of biometric systems, including face recognition systems.

The public has become increasingly aware of the use of scraped photographs to train face recognition systems.109 But schools are still designating photographs as directory information, and many schools are still posting images of students online. The risk of web scraping of images is an important issue to address. Schools as a best practice should not include photographs in directory information. After being designated as directory information and made public information, schools and students will have no control over how the photographic information is used or disclosed.

Risks relating to yearbook companies using facial recognition software

For some time now, there has been an interest in utilizing facial recognition technologies in the yearbook context. Already, school yearbooks from the “majority of U.S. schools” from 1890 to 1979 have been analyzed and have had facial recognition applied to them so they could be easily searched.110 But it isn’t just old yearbook photos that are being analyzed; some yearbook companies are utilizing face recognition on current student photographs.111

This is an issue that is not widely known or discussed, but it needs to be. While biometric data that schools themselves hold is regulated under FERPA, face recognition performed by yearbook companies may not be covered, depending on a variety of implementation factors. To address the potential privacy impacts, all schools should conduct a careful analysis of their yearbook policies and yearbook company, and determine if any face recognition is being utilized on student photographs at any time or point in the yearbook process. If so, then schools need to conduct an analysis and understand how all of the policies interact and what it means for privacy, parents, and students.

No matter what the analysis yields, parents and students need to be informed clearly and directly of facial recognition use when it occurs in the school context, including yearbooks. Schools that do not designate student photographs as directory information may have more control over these kinds of issues. Schools, for their part, should ensure that yearbook companies only use student photographs for creating the school yearbook and do not utilize the photos for anything else. Any onward sharing or use of student data for marketing or other purposes should be restricted.

Facial recognition is a controversial technology, and with the controversy comes a divergence of views. In this situation, it is a best practice to ask for consent prior to the use of facial recognition, even if by an outside vendor. If consent is given, there should still be clear boundaries on how the photographs may be used, and for how long.

Solutions exist for schools. Not including images in directory information is a first step. Another is to reassess and refine school policy regarding images of students, including publicly posted photos and yearbook photo policies. Schools can also explore technical solutions – such as creating scrape-proof areas of school web sites where images can be responsibly posted.

Another solution is for schools to utilize “anti-scraping” tools and techniques. For example, an “image cloaking” technique that helps prevent image scraping has been developed that is promising.112 Schools can explore these and other techniques as they seek ways to protect their students from unconsented face recognition being performed on student images.

If schools do not take action, and continue to publicly post student images in a way that allows scraping, or include student images and videos in directory information, one solution for parents and students is to restrict directory information sharing by opting out of such sharing. It can be a difficult choice, because students often want to participate in school yearbooks and events and have a photographic record of their time at the school. It is incumbent on schools to modernize their approaches to directory information, especially regarding images of students and the new risks they pose regarding collection for use in biometric systems.

Best Practices:

  • Schools should not designate photographs or images of students as directory information. Web site scraping for the potential inclusion of student images in face recognition test databases and products has been a significantly overlooked risk by schools.
  • Schools should not post photographs of students on publicly accessible websites that can be scraped. We recognize that it is not much fun to omit student images from communications about school activities. A balance needs to be found due to the risks involved with public posting of students’ images.
    • Newsletters that contain the images of students under the age of 18 can be emailed directly to parents and students instead of being publicly posted. Special awards and honors ceremonies can be posted at very low image quality, so that biometric measurements of such photographs will be rendered ineffective.
    • Schools can post messages that contain student photographs behind password-protected areas of the school website.
    • Schools can and should explore anti-web-scraping technologies and techniques. It is a best practice that any image posted publicly of a student be protected by anti-scraping technology.
  • It is a best practice that schools require yearbook companies that use facial recognition in any of their process to never sell or share that information, and should require specific consent for the use of facial recognition. Further, schools should ensure that student images and/or biometric templates from the images, are not used in any further way beyond what the school expressly allows.
  • In general, it is a best practice to avoid making photographs of students under the age of 18 widely available online.

Further recommendations:

There should be an express prohibition on the use of minor students’ photographs for training face recognition systems by anyone.

Schools that still decide to designate student photographs as directory information need to restrict those photographs from becoming available to third parties to “scrape” or otherwise utilize in training databases for biometric systems.

Schools should ensure they have a clear school biometric policy in place that applies to both biometric information the school holds, and also addresses the risk that student images can potentially be utilized to create biometric templates and products by third parties known or unknown to the school, parents, or eligible students. Each school will have its own context for a biometric policy.

Lawmakers are expressing concerns about biometrics in schools. Legislatures have already passed laws that apply specifically to the use of biometrics in educational settings. For some examples, see the chart in this section that presents key examples of school-related biometric laws in the U.S. These laws may have different definitions of biometrics than FERPA, and may have additional interactions with FERPA. Most of the risks of face recognition and biometrics in schools have been articulated as coming from within the schools, and scant attention has been paid to the risk from outside the schools. For example, from web scraping of student images posted without prior consent under the directory information exemption.

It is important for educational institutions to educate themselves on the risks regarding release of student photographs as “public information” relevant to biometric systems.113 Biometric systems can be persistent, and many parents and students would want to know if their images had been included and analyzed in a biometric system that is in active use outside of the educational context.

The best way for schools to avoid the risks of web scraping of student images is to ensure that no student photos are posted online in a public area of the school web site. The best way for schools to ensure that there are no surprises regarding yearbook companies utilizing facial recognition on student photos is to have a discussion with the company and be very clear about how or if that would happen. There should be no biometric surprises for any student or parent.

State-Level Biometric Laws Focused on Educational Institutions

State

Year enacted or status

Bill name

What the bill does

Arizona

2008

Biometric Student Information

Provides that a school in a school district or a charter school shall not collect biometric information from a pupil unless the pupil’s parent or guardian gives written permission.

Arkansas

2015

Student Online Personal Information

Adopts the Student Online Personal Information Protection Act, relates to web sites, includes test results, special education data, discipline records juvenile dependency records, medical or health records, Social Security number, biometric information, socioeconomic information, political affiliations, religious information, student identifiers, voice recordings and geolocation information, prohibits targeted advertising based on covered information or sale of a student’s covered information.

Colorado

2014

Student Data Privacy Act

Requires the Board of Education to publish an inventory and dictionary or index of the individual student-level data currently in the student data system, requires Board to develop policies and procedures to comply with the Family Educational Rights and Privacy Act and other privacy laws and policies, prohibits the collection of criminal records, medical records, social security numbers, and student biometric information, prohibits the Board from transferring student data to any entity outside of the state.

Florida

2014

Education Data Privacy

Relates to education data privacy, requires notice to K-12 students and parents regarding education record rights, provides a remedy in circuit court regarding education records, provides limitations on collection and disclosure of confidential and exempt student records, relates to biometric information, including fingerprints, student social security numbers and student identification numbers, prohibits information on parent or sibling biometrics, voting history, religion or political affiliation.

Illinois

2007

Student Biometric Information

Regarding schools with meal counting system that uses fingerprints, hand geometry, voice or facial recognition, or any other student biometric information, this law requires school districts to adopt a policy with the following items:

Written permission to collect biometric information from the individual who has legal custody of the student, or from the student if he or she has reached the age of 18.

Failure to provide this written consent must not be the basis for refusal of any services otherwise available to the student.

The discontinuation of use of a student’s biometric information when the student graduates or withdraws from the school district; or if a written request for discontinuation is provided to the school by the individual who has legal custody of the student, or by the student if he or she has reached the age of 18.

The destruction of all of a student’s biometric information within 30 days after the biometric information is discontinued through graduation, withdrawal, or a written request for discontinuation.

The use of biometric information solely for identification or fraud prevention.

A prohibition on the sale, lease, or other disclosure of biometric information to another person or entity, unless consent is obtained from the individual who has legal custody of the student, or from the student if he or she has reached the age of 18, or the disclosure is required by court order. The storage, transmittal, and protection of all biometric information from disclosure.

Kentucky

2014

Security Breach of Informaiton Held by Public Agencies

Regulates security of personal information held by public agencies, counties, school districts and municipal corporations, requires public agencies and nonaffiliated third parties to implement and update security procedures, including encryption and corrective action against security breaches, includes breach investigation procedures in contracts with nonaffiliated third parties, includes biometrics, Social Security numbers, credit and debit card numbers, passport, driver license and health information.

Louisiana

2010

Acts 2010, No. 498, §1, eff. June 24, 2010

Regulates collection of student biometric information, requires written permission from parent, guardian, or the student if age 18 or older, prior to the collection of any biometric information, provides that such information shall only be used for identification or fraud prevention, requires written permission for disclosure to a third party unless required by a court order, provides for secure storage and transmission of such information, prohibits denial of services due to refusal to provide consent.

Nevada

2015

Provisions Governing Records of Criminal History

Revises provisions governing records of criminal history, provides that such information may be request of and received from the Federal Bureau of Investigation by the submission of a complete set of fingerprints, or other biometric identifier which is defined as a fingerprint, palm print, scar, bodily mark, tattoo, voiceprint, facial image, retina image or iris image of a person, requires the Central Repository to adopt regulations governing biometric identifiers and the information derived therefrom.

New York

Not enacted – Active as of 2020

5140—A

Directs the commissioner of education to conduct a study on the use of biometric identifying technology; prohibits the use of biometric identifying technology in schools until July 1, 2022.

Oklahoma

2013

Student Data Accessibility, Transparency and Accountability Act

The Student Data Accessibility, Transparency and Accountability Act, requires public reporting of which student data are collected by the state, mandates creation of a statewide student data security plan, and limits the data that can be collected on individual students and how that data can be shared. It establishes new limits on the transfer of student data to federal, state, or local agencies and organizations outside Oklahoma. It also restricts the state from requesting delinquency records, criminal records, medical and health records, social security numbers and biometric information as part of student data collected from local schools and districts.

Tennessee

2014

Parental Inspection of School Records

Allows parents to review all instructional materials used in the classroom of the parent’s child, mandates that a local educational agency shall allow parents access to review all teaching materials, instructional materials, handouts and other teaching aids, provides for parental review of all surveys, analyses and evaluations prior to being administered to the child, with the option to opt out of student participation, requires written consent for collection of biometric data.

Figure 23. This chart summarizes a selection of the key state-level biometric laws in the US pertaining to educational institutions. More laws exist; these are exemplars. As of 2020 there is increased momentum toward the creation of additional laws regulating biometrics at the state level, including more controls on the use of student biometrics.

92 U.S. Department of Education, Glossary, Definition of Biometric. Available at: https://studentprivacy.ed.gov/glossary#header-for-B.

93 Kashmir Hill and Aaron Krolik. How photos of your kids are powering surveillance technology. New York Times, October 11, 2019. Available at: https://www.nytimes.com/interactive/2019/10/11/technology/flickr-facial-recognition.html.

94 Zak Doffman, Why facial recognition in schools seems to be an aimless recipe for disaster. Forbes, Nov. 7, 2018. Available at: https://www.forbes.com/sites/zakdoffman/2018/11/07/why-facial-recognition-in-schools-seems-to-be-an-aimless-recipe-for-disaster/#464a99241a83.

95 Victor Skinner, Illinois school district installs fingerprint scanner in cafeteria, EAG, July 15, 2016. Available at: http://eagnews.org/illinois-school-district-installs-fingerprint-scanner-in-cafeteria/.

96 State of Illinois 105 ILCS 5/10-20.40, Sec. 10-20.40, Student biometric information. Available at: http://www.ilga.gov/legislation/ilcs/documents/010500050K10-20.40.htm.

97 The U.S. Government Accountability Office described web scraping in its Data Resellers report: “… Examples of such methods include “web scraping”—sometimes called data extraction or web data mining—in which resellers, advertisers, and other parties use software to search the web for information about an individual or individuals, and extract and download bulk information from a particular website that contains consumer information.” Information Resellers, U.S. Government Accountability Office, September 2013. Available at: https://www.gao.gov/products/GAO-13-663. Photographs of students can be scraped from school websites unless specific preventive steps are taken.

98 IBM developing huge public dataset to help eliminate bias from facial recognition, Find Biometrics, June 27, 2018. Available at: https://findbiometrics.com/ibm-help-eliminate-bias-from-facial-recognition-506276/. “Perhaps more importantly, IBM is going to release a dataset of 36,000 facial images that will be equally distributed across a range of ethnicities, genders, and ages. This will primarily be for evaluation purposes, a tool to help developers eliminate bias from their facial recognition systems.”

99 See: Face Image Project. Available at: https://talhassner.github.io/home/projects/Adience/Adience-data.html.

See also: Eran Eidinger, Roee Enbar, and Tal Hassner, Age and Gender Estimation of Unfiltered Faces, Transactions on Information Forensics and Security (IEEE-TIFS), special issue on Facial Biometrics in the Wild, Volume 9, Issue 12, pages 2170 – 2179, Dec. 2014 Face Image Project, The Open University of Israel.

100 Many such databases exist. See, for example, Cole Calistra, 60 facial recognition databases, May 7, 2015. Available at: https://www.kairos.com/blog/60-facial-recognition-databases.

101 Labeled Faces in the Wild, University of Massachussets. Available at: http://vis-www.cs.umass.edu/lfw/#resources.

102 The creators of the CASIA scraped dataset explain the methodology of the creation of the dataset in an academic paper: Dong Yi, Zhen Lei, Shengcai Liao and Stan Z. Li, Learning Face Representation from Scratch, Center for Biometrics and Security Research & National Laboratory of Pattern Recognition Institute of Automation, Chinese Academy of Sciences (CASIA).Available at: https://arxiv.org/pdf/1411.7923.pdf.

103 VGGFace2, A large scale image dataset available for face recognition. Available at: http://www.robots.ox.ac.uk/~vgg/data/vgg_face2/. See: Qiong Cao, Li Shen, Weidi Xie, Omkar M. Parkhi and Andrew Zisserman, VGGFace2: A dataset for recognising faces across pose and age, Visual Geometry Group, Department of Engineering Science, University of Oxford. Available at: http://www.robots.ox.ac.uk/~vgg/publications/2018/Cao18/cao18.pdf.

104 Facial recognition technology partnership with China risks compromising privacy rights, Media Institute for Southern Africa Zimbabwe, May 29 2018, Kubatana.net. Original source material available at: https://zimbabwe.misa.org/2018/05/29/digest-facial-recognition-technology-privacy-rights/. See also: Spandana Singh and Hanna Wetters, The technology space is rapidly evolving in Africa, and it’s not all good news. Fair Observer, November 23, 2018. Available at: https://www.fairobserver.com/region/africa/africa-tech-boom-techonoly-policy-data-protection-news-33281.

105 Kashmir Hill, The secretive company that might end privacy as we know it, The New York Times, January 20, 2020. Available at: https://www.nytimes.com/2020/01/18/technology/clearview-privacy-facial-recognition.html. See also: Louise Matsakis, Scraping the web is a powerful tool, Clearview AI abused it, Wired, January 25, 2020. Available at: https://www.wired.com/story/clearview-ai-scraping-web/.

106 Anna Merlan, Here’s the file Clearview AI has been keeping on me, and probably on you too, Vice, Feb. 28, 2020. Available at: https://www.vice.com/en_us/article/5dmkyq/heres-the-file-clearview-ai-has-been-keeping-on-me-and-probably-on-you-too. The author of this article used the California Consumer Protection Act (CCPA) to request the information that Clearview AI held on her. She found that the company had collected, or “scraped,” photos of her from MySpace, Twitter, Instagram, and other websites.

107 Filing of Clearview AI, Registration ID 367103, January 14, 2020, Vermont Data Broker Registry. Vermont Secretary of State. Available at: https://www.vtsosonline.com/online/DatabrokerInquire/DataBrokerInformation?businessID=367103. See: Response to Question 7: “Clearview AI Inc. collects publicly available images. This collection includes publicly available images of minors. We provide collected images in a searchable format to users. We actively work to remove all images of California-resident minors from all datasets. Clearview AI, Inc. processes all opt-out requests in a manner compliant with the relevant local laws, including opt-out requests related to minors.”

108 Patrick Grother, Mei Ngan, Kayee Hanaoka. Face Recognition Vendor Test (FRVT) Part 3: Demographic Effects in Facial Systems, NIST, December 2019. Available at: https://nvlpubs.nist.gov/nistpubs/ir/2019/NIST.IR.8280.pdf. “We found elevated false positives in the elderly and in children; the effects were larger in the oldest adults and youngest children, and smallest in middle aged adults. The effects are consistent across country-of-birth, datasets and algorithms but vary in magnitude.” See pages 8, 17 and associated technical material.

109 Kashmir Hill and Aaron Krolik. How photos of your kids are powering surveillance technology. New York Times, October 11, 2019. Available at: https://www.nytimes.com/interactive/2019/10/11/technology/flickr-facial-recognition.html.

110 Maksym Chernopolsky, Face recognition and OCR processing of 300 million records from US yearbooks, Medium. Sept. 6, 2019. Available at: https://medium.com/myheritage-engineering/face-recognition-and-ocr-processing-of-300-million-records-from-us-yearbooks-a95d55c6ac58. See also: Mike Mansfield, Discover your family in school yearbooks. MyHeritage webinar. Available at: https://familytreewebinars.com/download.php?webinar_id=787.

111 See for example, Jostens, https://www.jostens.com/yearbooks/ybk_lp_prospects.html. In its privacy policy, Josten notes in its Categories of Personal Information Collected in last 12 months: “Identifiers; Personal Information described in the California Customer Records Statute; Characteristics of protected classifications under California or federal law; Commercial Information; Biometric data; Internet or other electronic network activity; Professional or employment information; Geolocation data; Sensory information; Non-public Education Information.” See also: App, ReplayIt.com, https://www.replayit.com/#/home.

112 Shawn Shan, Emily Wenger, Jiayun Zhang, Huiying Li, Fawkes: Protecting personal privacy against unauthorized deep learning models, arXiv preprint, arXiv:2002.08327 (In Submission). Available at: https://arxiv.org/pdf/2002.08327.pdf. This paper is an important contribution and presents a helpful review of key techniques for reducing biometric scraping. The paper’s primary contribution is in its description of the Fawkes technique of algorithmically cloaking images. This technique is a promising model. The techniques could potentially be adapted for broader use.

113 One of the authoritative experts regarding children and biometrics is Professor Anil Jain. See: Anil Jain, Biometric Recognition of Children, Challenges and Opportunities. Michigan State University, June 7, 2016. Available at: http://biometrics.cse.msu.edu/Presentations/AnilJain_UIDAI_June7_2016.pdf. Another expert in this area is Clarkson University Endowed Professor in Engineering Science and CITeR Director and Stephanie Shuckers. See: Chris Burt, CITer Director talks research to inform dialogue on children’s biometrics and privacy. Biometric Update, December 3, 2019. Available at: https://www.biometricupdate.com/201912/citer-director-talks-research-to-inform-dialogue-on-childrens-biometrics-and-privacy.

IV. Recommendations for Private Schools, or any Educational Institution not covered under FERPA Regulations →

FERPA usually does not apply to primary and secondary private schools. Private postsecondary institutions, however, are usually covered by FERPA in some way.114 Given that there are 34,576 private schools, as last tallied by the National Center for Education Statistics,115 a significant swath of students and parents lack the protections and rights that FERPA provides.

Schools not subject to FERPA should nevertheless take steps to protect student privacy. First, schools not covered by FERPA need to develop their own comprehensive modern privacy program, ideally a program that addresses the gaps in FERPA and that includes the best practices identified in this report. Second, these schools should pay particular attention to student health data. The release of this data can affect a student, the student’s family, and even the student’s children forever.

A. Creating controls for personally identifiable information and other student data that would otherwise be classified as an educational record under FERPA

States have a plethora of laws applicable to educational institutions. The National Conference of State Legislatures has identified at least 17 significant privacy laws applicable to educational institutions at the State level.116 The State laws range from ensuring that biometrics collected at schools for school lunches or other purposes require consent, to requiring data breach notification by schools, to setting rules around schools’ relationship with external technology vendors such as for integrated student information systems, or other technologies used for school purposes. No two states have identical privacy requirements for all educational institutions. As such, privacy protections for students at private K-12 schools may differ markedly from State to State.117

To be responsive to the increasing and high profile concerns about student privacy, private schools need to understand the State privacy laws applicable to them.

Private schools can make use of a privacy tool called a Privacy Impact Assessment118 to conduct a thorough review of school data and data practices to identify gaps and to set a sound privacy policy that complies with applicable laws. Many resources and examples of Privacy Impact Assessments (PIA) exist. In particular, see the U.S. Department of Education’s PIAs.119 Some school districts have good materials on their approach to PIAs.120 It may also be helpful for some private schools to think thorough a Data Privacy Impact Assessment (DPIA)121 to further identify gaps and risks, even though it is not a requirement.

A PIA should ideally document how non-FERPA schools can achieve privacy protections for students and parents that are the same as (or better than) protections for students in schools subject to FERPA. Students in private schools should not be second-class citizens when it comes to privacy. Parents of those students should demand privacy rights and protections.

B. Risks related to health data held at non-FERPA-covered primary and secondary schools

Of particular concern at non-FERPA covered schools are legal protections for student health records. At the postsecondary level, most information held by schools is covered under FERPA or in some cases, under HIPAA. But some student health data has neither HIPAA122 nor FERPA protections when held at a private K-12 educational institution that is not a FERPA-covered entity.123

The intersection of HIPAA and FERPA is complex. The Department of Education and the Department of Health and Human Services released new joint guidance regarding the intersection of HIPAA and FERPA in 2019. It should be required reading for all school personnel, even if neither law applies. 124

C. Resources

Several high-quality resources are available that may be helpful, including:

The Privacy Handbook for Student Information Online: A Toolkit for Schools and Parents, is an essential resource.125 Fordham University developed the Handbook under Professor Joel R. Reidenberg’s direction.126 The toolkit includes resources for school boards, administrators, teachers, and parents. Another resource is the FerpaSherpa Resource Center.127

Private schools should take into account their own activities, contexts, and applicable laws, when developing privacy rules that serve students’ and parents’ present and future needs. This work needs to be undertaken sooner rather than later. Private schools, particularly if they are nimble, might even compete on privacy, for example, by establishing rules that exceed the requirements of those found in public schools. We would love to see a “race to the top” for privacy standards among private schools.

Best Practices:

  • It is a best practice for private schools or other non-FERPA covered entities to conduct a Privacy Impact Assessment (PIA). Pay particular attention to sensitive information such as student health data.
  • It is a best practice to understand the State privacy laws that apply to your educational situation.
  • Create procedural and administrative rules to manage the information that would, in other settings, be held under FERPA.
  • Review the recommendations regarding student directory information, data brokers, and biometrics. Many of the concerns about implications and impacts of public dissemination of student data will apply to student information in a non-FERPA context.

114 Most postsecondary institutions such as colleges and universities both public and private, including medical, law, and other professional schools are covered by FERPA by virtue of how the mechanics of Federal student grant and assistance programs work under Title IV. Educational institutions that receive funding from one or more of the programs under Title IV are covered by FERPA as a whole, even if just a constituent part of the institution receives the funds. 34 CFR §99.1 (d).

115 U.S. Department of Education, National Center for Education Statistics. (2019). Digest of Education Statistics, 2017 (NCES 2018-070), Table 105.50. The most recent data available is for 2015-2016. The table is available at: https://nces.ed.gov/fastfacts/display.asp?id=84.

116 Student Data Privacy, National Conference of State Legislatures, October 26, 2018. Available at: https://www.ncsl.org/research/education/student-data-privacy.aspx.

117 The National Conference of State Legislatures maintains an up-to-date database that tracks all State education legislation. See: NCLS, Education Legislation Database / Bill Tracking. Available at: https://www.ncsl.org/research/education/education-bill-tracking-database.aspx.

118 A privacy impact assessment is a practical tool that facilitates thinking through privacy risks. There are many types of privacy impact assessments, and the PIA is typically tailored for each specific assessment. See the PIAs at the U.S. Department of Education as exemplars. Privacy Impact Assessments. U.S. Department of Education. Available at: https://www2.ed.gov/notices/pia/index.html.

119 Privacy Impact Assessments. U.S. Department of Education. Available at: https://www2.ed.gov/notices/pia/index.html.

120 See Privacy Impact Assessments, Privacy and Access in Saskatchewan Schools. Available at: https://saskschoolsprivacy.com/central-adminstration/central-administration-summary/privacy-impact-assessments/.

121 Most DPIA templates apply to entities regulated in Europe under European privacy law. Some templates are nevertheless useful as an exercise in generally thinking through data privacy risks. One excellent template is at the UK Information Commissioner’s Office. Sample DPIA Template, UK ICO. Available at: https://ico.org.uk/media/about-the-ico/consultations/2258461/dpia-template-v04-post-comms-review-20180308.pdf.

122 HIPAA, or the Health Insurance Portability and Accountability Act, is a 1996 U.S. federal statute. See Bob Gellman et al, A Patient’s Guide to HIPAA, World Privacy Forum, last updated 2019. Available at: https://www.worldprivacyforum.org/2019/03/hipaa/.

123 Joint Guidance on the Applicability of the Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to Student Health Records, U.S. Department of Education and US Department of Health and Human Services, December 2019. Available at: https://www.hhs.gov/sites/default/files/2019-hipaa-ferpa-joint-guidance-508.pdf.

124 Joint Guidance on the Applicability of the Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to Student Health Records, U.S. Department of Education and US Department of Health and Human Services, December 2019. Available at: https://www.hhs.gov/sites/default/files/2019-hipaa-ferpa-joint-guidance-508.pdf.

125 Joel Reidenberg et al, Privacy Handbook for Student Information Online: A toolkit for schools and parents, Fordham University. Available at: https://www.fordham.edu/info/23830/research/5916/privacy_handbook_for_student_information_online.

126 Professor Reidenberg is regarded as a privacy thought leader in student privacy and related issues.

127 FerpaSherpa, a project of the Future of Privacy Forum. Available at: https://ferpasherpa.org/about/team/.


Part IV. Conclusion: Towards Creating a Culture of Privacy in FERPA- Covered Institutions →

A lesson learned from other areas of data privacy is that law on the books is one thing, but law in practice can be something else entirely. Laws are only as effective as their implementation, and the best implementation should nurture a way of thinking that embodies the needs of students, even if those needs go beyond the words of a law, whether it is out of date or not.

FERPA, with its important protections for student data, is an important cornerstone of student privacy in the U.S. When implemented properly, FERPA can give students some degree of autonomy and choice over information that can affect their lives and opportunities in meaningful ways. Understanding and exercising privacy controls can also give students an education that will serve them well as they navigate privacy issues throughout their lives.

FERPA-covered schools need to develop good, thoughtful, and useful FERPA notices, policies, and opt out forms. These are essential — but these tools operate best in an environment that fosters a “culture of privacy.” This means that privacy is a value that is respected and nurtured within the entire culture of educational institutions. One of the first steps toward creating a culture of privacy is to embrace privacy protection as a positive feature, not to treat it as a bug in the system.

In our modern era, students (and parents) may have many reasons for wanting or needing to utilize FERPA directory information opt out rights. Students may want their personal information such as home address or weight shielded from public eyes. Students who are victims of domestic violence may need enhanced privacy and “data safety,” and restricting information may be essential for them. Parents of students who are active members of law enforcement or the judiciary may also want a FERPA opt out in place.

A culture of privacy will assist and understand the many reasons (or no particular reason) that, in our incredibly complex digital environment, people want to remove personal information from public disclosures. Modern data systems collect personal information and can use it to predict and affect how individuals are treated in the educational, vocational, economic, and other marketplaces. In some cases, this information can affect individuals for the rest of their lives.

FERPA provides local educational institutions with broad discretion to implement certain aspects of the federal privacy rules. For example, a school can limit directory information beyond that allowed by FERPA. In an ideal world, the FERPA framework has the possibility of being flexible and effective, both essential qualities. But in the absence of clear, modern guidance and vigorous leadership focused on student privacy and school privacy concerns, the broad discretion that FERPA allows can and in many cases has devolved, creating significant inconsistencies in local FERPA implementations. For parents and students who are involved with more than one school during the course of a student’s academic life, the diversity in FERPA protections is an additional challenge.

The Department of Education needs to update FERPA policy to reflect the modern understanding that the release of a student’s home address represents a profound safety risk for all children, but especially for vulnerable populations, including victims of crime, survivors of domestic violence, and students who are children of members of law enforcement and the judiciary. Releasing the photographs of minors publicly online without prior consent is also problematic, and this practice needs to be curtailed. These are starting points — additional items such as rewriting model notices and asking schools to post FERPA notices and opt out forms online and without requirements for registration to see these policies would be welcome updates.

FERPA policy must be proactive and smart about ensuring that data scrapers, data brokers, data profilers, and those seeking to cull the data of a new generation cannot do so unless and until parents and eligible students who are well and truly fully aware of all FERPA directory information rules and policies at their local schools choose for the information to be public. And schools, for their part, need to assertively assist parents and students in opting out of directory information sharing when so requested. Schools that make FERPA opt outs difficult for students do not support a culture of privacy.

Solutions to the problems identified in this report exist. And the solutions in many cases are inexpensive and achievable. It is not expensive to post a FERPA policy and a FERPA opt out policy on a school web site. It is not impossible to make it easy for a student or parent to exercise opt out rights by providing a FERPA opt out form and allowing for that form to be turned in throughout the academic year.

What is going to be challenging is to find the willingness and the attention needed to make the changes that can bring modern privacy protections into the educational institutions in the United States. In the past decade, there has been little discussion of the effects of educational institutions’ directory information policies in the modern educational digital ecosystems. It is time to remedy that gap.

To do this, schools can begin by convening parents, students, and other stakeholders to discuss how to update privacy policies in a way that serves the needs of students and parents first and foremost. Schools can survey parents and ask what kind of opt outs are effective for them, and how much time they need to opt out. Schools can listen to the privacy concerns of students and parents who have been touched by crime or who have been made vulnerable in other ways, and can begin to craft FERPA policies at the local level that are sensitive to the real-world privacy problems that parents and students are facing. In doing so, educators can begin to fulfill their obligation to do no harm in the area of student privacy, and to create a safe place for student flourishing by modeling the dignity of treatment of others educators most want to see in their students.


Part V. Documents and Data Related to the Research

I. Printable Best Practices for Educational Institutions →

FERPA Notice

General Best Practices

  • It is a best practice for mandatory FERPA notices to be posted online in a prominent location year round.
  • Although it is not a best practice for general FERPA notice, we recommend institutions provide opt out forms along with the general FERPA notices.

Best practices: Postsecondary institutions

  • It is a best practice for the mandatory annual FERPA notice to be posted online in a prominent location year round.
  • Although it is not mandatory, we recommend institutions provide FERPA opt out forms along with the general FERPA notices.
  • Provide a permanent online repository of policies for the handling of student data, including FERPA. Ensure that all FERPA forms, including opt out, are available on the same webpage. Provide a “One Stop Shop” FERPA hub.
  • Keep responsibility for similar policies in the same office, such as the registrar. There should be a list of school officials who can answer questions from students and parents. Links from the Registrar’s site could easily become a quasi-standard location for postsecondary schools to post FERPA data. This would provide helpful consistency for students.

Best Practices: Primary and Secondary institutions

  • Provide parents, students, and the public with prominent online FERPA notice, and online FERPA opt out forms. In today’s digital world, all FERPA materials online must be available on a public-facing part of the school website. Parents must be able to easily find FERPA materials before they enroll their children in a school. If the school runs a non-public school platform or student portal, the school will still need to ensure that in addition to school portal activity around FERPA, that there is publicly available notice on the website.
  • Prominent FERPA notice entails providing a clearly labeled link from the home page directly to the FERPA annual notice. Or, a search for FERPA in a search box should uncover the pertinent information. Parents and students should not need to click through websites and do investigative searches to find the annual FERPA notice.
  • Use consistent terms: FERPA, directory information opt out, or directory information restriction are the most commonly used terms. It would be helpful for the Department of Education to standardize the terminology so that students and parents see the same terms at all schools.
  • Put all relevant FERPA forms and information in one prominent location online that is publicly available.
  • Notice of FERPA policies and opt out should be prominent and should remain online year-round. Many K-12 schools provide paper forms or email forms to parents. A best practice is to provide FERPA annual notice linked from a prominent place on the home page at all times in addition to the paper forms.
  • Use consistent terms: FERPA, directory information opt out, or directory information restriction are the most commonly used terms. It would be helpful for the Department of Education to standardize the terminology so that students and parents see the same terms at all schools.
  • Put all relevant FERPA forms and information in one prominent location online that is publicly available. Parents and students who are relocating or thinking of a local move need to be able to see FERPA forms readily online.
  • To serve the needs of those who are highly adapted to digital technologies, educational institutions should ensure FERPA notices are readily available online and can be read on mobile devices as well as laptop computers. School web sites are key for providing prominent links to FERPA annual notices that are accessible to the public and students.

Information that is Shared without an Opt Out in Place

  • Directory information should follow a minimum necessary rule. Expansive inclusions of students’ gender, primary language, and place of birth are not necessary. Schools can use this data, but including these data fields in directory information and releasing it to third parties is unnecessary and therefore not a good practice because routinely its inclusion is not required to achieve the goal of the school through disclosure.
  • Home address of a student placed in directory information presents a safety risk for some students and parents. Both schools and the U.S. Department of Education should recognize a modern understanding of safety considerations attached to publicly releasing home address information. Not only is the student potentially put into a dangerous situation, their family members who may also have risks associated with others knowing their home addresses may also be endangered. For example, judges, elected officials, police officers and victims of stalking or other crimes may be put at risk.
  • Photographs of students released through directory information create high risks to all students. Photographs of students are riskier to release because of the possibility of permanent storage and use by commercial and other biometric systems. The photographs may be input for web scraping tools that can undertake biometric analysis. It is a best practice to not include student photographs in directory information.
  • All directory information, prior to being designated, needs to undergo a safety review. Home address, date of birth, gender, and other data are questionable for inclusion in directory information.

Example: One sampled K-12 school district includes a minimal amount of data as directory information.

  • Student’s name
  • Street address
  • Telephone number
  • School attended
  • Grade level.

This is a step in the right direction of a best practice but for the inclusion of street address and, perhaps, telephone number. What this example shows is that directory information can include just a few data elements about each student.

How Much Time Do Parents or Eligible Students Have to Opt Out?

Best Practices for Time Allowed for FERPA Opt Out at all educational institutions:

  • Directory Information Opt Outs should be allowed all year by all institutions covered under FERPA; this is a baseline protection that needs to be updated in the FERPA guidance.
  • Expedited opt outs should be made available for vulnerable people and populations. If in the event that a safety situation, data breach, or a toxic data leak traceable to directory information that has been disclosed, those at risk need to be provided immediate means of masking or hiding their data.

Access to FERPA Opt Out Forms

Best Practices for Access to Opt Out Forms:

  • It is a best practice for educational institutions to post a FERPA opt out form online.
  • It is crucial that all educational institutions post FERPA opt out forms online in a way that is publicly accessible and does not require a password or registration.
  • FERPA opt out forms should be posted prominently, and should be labeled clearly. Parents and students should be able to access the form from the search function on the web site. If the web site does not have a search function, the FERPA opt out notices and policies should be posted with a prominent link on the home page of the school web site.
  • Ideally, the FERPA opt out forms will be posted in the context of FERPA annual notice, and other FERPA-related information.
  • Paper opt out forms should be made available for individuals who do not have online access.
  • For postsecondary institutions, the FERPA opt out form should have a publicly available “home base,” preferably the registrar’s page.
  • For primary and secondary institutions, the FERPA opt out form should be accessible to the public, even if a platform is in use at the school web site.
  • FERPA opt out processes need to specifically accommodate individuals with disabilities or limitations.

Is the FERPA Opt Out Process Known?

Best Practices for Notification of Opt out Procedures:

  • It is a best practice for schools to provide information about how to opt out on the annual FERPA notice.
  • It is a best practice for schools to provide a permanent online home for information about FERPA opt out procedures and make that accessible to the public.
  • Primary and secondary schools in particular noted to WPF researchers that they communicate FERPA opt out procedures directly to parents via email. Direct notification exceeds FERPA standards, but for school districts that are resource-scarce or in the midst of transitioning to electronic systems, direct emails to ensure notification are a good practice. The practice may not be sustainable at very large institutions, but it is a sustainable practice for very small or small institutions or districts.
    • It is a best practice to notify students regarding accommodations for opting out for individuals who may not have the capacity to write their own letter. This appears to be an overlooked issue. Not all parents or eligible students will be comfortable figuring out what a FERPA opt out letter should say, or even where to start. Not providing an opt out form may prove to be an insurmountable opt out form for some students. This should be considered as part of the institution’s decision-making process regarding opt out procedures.

Content of FERPA Opt Outs

Best Practices

  • It is a best practice to provide more choices for selecting categories of directory information on FERPA opt out notices.
  • It is a best practice to revise, if possible, “all-or-nothing” FERPA opt out notices to provide granular choices (Yes / No) about individual data categories designated by the school for inclusion in directory information.
  • It is a best practice to provide detailed categories that students can choose to opt out of. Our research indicated that integrated student information systems, particularly at the postsecondary level, may offer very granular and extensive opt outs compared to standard FERPA opt out forms. It is a best practice to use integrated systems and platforms to make FERPA opt out more accessible and more adaptive.

Does the FERPA opt out contain nudges?

Best Practices:

  • Students should not be discouraged from utilizing their rights under FERPA by the use of subtle or overt negative language or “nudges.”
  • Schools need to consider that some students want FERPA opt outs because of serious safety considerations. Schools should ensure that they present a balanced view of FERPA opt outs.

Online Student Directories:

Best Practices:

  • Because of the potential risks to student safety, it is a best practice for educational institutions to publish their online student directories privately. Only authenticated users (e.g., faculty, staff, and students) should have access,
  • It is a best practice to require knowledge of a student’s last name for searching, even if the directory requires authentication and is not open to the public.
  • Every effort must be made to prevent “site scraping” of student contact information in online student directories. Schools need to utilize strong anti-scraping software and techniques as a preventive security measure.

Data Brokers and the Acquisition and Use of Students’ FERPA Directory Information

Best Practices:

  • As a best practice, States should consider additional protections for the information of minors in light of the new information that has become available that proves the presence of the information of minors in data broker databases.
    • New York State’s Education Department has adopted an amendment, which specifically prohibits the sale of personally identifiable student data. This is a policy best practice, and is the kind of structural protection from onward transfer of student data is needed as a best practice to protect directory information that parents or students did not opt out of. Directory information does not have the same restrictions as protected student record information does under FERPA.
  • Schools should review all contracts with third parties, including vendors. If a vendor is utilizing student directory information, schools should take steps to ensure that directory information is specified as restricted in its use by the vendor and restricted from onward uses. Directory information does not enjoy the same levels of protection as protected student information under FERPA.
  • Schools should take great care to not release directory information subject to opt out restrictions to third parties. Schools should review contracts and procedures to ensure directory information that is subject to restrictions (opt out) is secured and only released per the regulations.
  • Because data brokers can acquire information from school web sites, it is a best practice for schools at all levels to utilize anti-scraping software and techniques to protect student information posted on school websites. Student photographs, names, and other information can be and are being scraped from school websites unless schools take active steps to restrict this activity. Scraped data can be used for many years. Protections include placing all student data and photographs in a protected area of the webs site and only allowing authenticated access to that area.
  • Directory information should follow a minimum necessary rule. Schools are not required to share directory information. Whenever possible, this should be the norm, not the exception.

Student Biometric Data and FERPA

Best Practices:

  • Schools should not designate photographs of students as directory information. This has, to date, been a significantly overlooked risk by schools.
  • Schools should not post photographs of children on publicly accessible websites that can be scraped for inclusion in biometric test databases. We recognize that it is not much fun to omit student images from communications about school activities. A balance needs to be found due to the very real risks involved with public posting of images.
    • Newsletters that contain the images of students under the age of 18 can be emailed directly to parents and students.
    • Special awards and honors ceremonies can be posted at very low image quality, so that biometric measurements of such photographs will be rendered ineffective.
    • Schools can post their messages that contain student photographs behind password-protected areas of the school website.
  • In general, it is a best practice to avoid making photographs of students under the age of 18 widely available online.

Recommendations for Private Schools, or any Educational Institution not covered under FERPA Regulations

Best Practices:

  • It is a best practice for private schools or other non-FERPA covered entities to conduct a data privacy impact assessment (DPIA). Conduct the DPIA regarding student information, and pay particular attention to sensitive information such as student health data.
  • It is a best practice to understand the State privacy laws that apply to your educational situation.
  • Create procedural and administrative rules to manage the information that would, in other settings, be held under FERPA.
  • Review the recommendations regarding student directory information, data brokers and biometrics- the same concerns about implications and impacts of dissemination of student data will apply to student information in a non-FERPA context.

II. Printable FERPA Opt Out Form →

FERPA Directory Information Opt out Form

name (printed) ____________________________________ student id: ___________________________

Notice of Directory Information Opt Out

In accordance with the Family Educational Rights and Privacy Act of 1974 (FERPA), as amended, a student’s education records are maintained as confidential and, except for a limited number of special circumstances listed in that law, will not be released to a third party without the parent/student’s prior written consent. The law, however, does allow schools to release student “directory information” without obtaining the prior consent of the parent/student. If you do not want the release of certain types of directory information without your prior consent, you may choose to “opt out” of this FERPA exception by signing the Form below. Directory information of a student who has opted-out from the release of directory information, in accordance with this policy/procedure for opting out, will remain flagged until the student requests that the flag be removed by completing and submitting a revocation of the opt out to the School.

to: [school name] _____________________________

I request the withholding of the following personally-identifiable information identified as Directory Information under FERPA. I understand that upon submission of this Form, the information checked cannot be released to third parties without my written consent or unless the School is required by law or permitted under FERPA to release such information without my prior written consent; and that the checked directory information will not otherwise be released from the time the School receives my Form until my opt- out request is rescinded. I understand that I may not opt out of use of my student ID number because it is necessary identifying information for the School. I further understand that if directory information is released prior to the School receiving my opt- out request, the School may not be able to stop the disclosure of my directory information. I understand that I may request and challenge how my directory information is used by contacting the School.

____ Check here to opt out of all directory information identified below

or Check the individual boxes below to selectively opt out of information sharing

____ Name

____ Telephone listing(s)

____ Photograph

____ Date of birth

____ Place of birth

____ Permanent or home address

____ E-mail address

____ Dates of attendance

____ Most recent institution attended

____ Weight / height

____ EnrollmentStatus (e.g. full-time,part-time)

____ Class standing (e.g. sophomore)

____ Most recent educational agency or institution attended

____ Participation in officially recognized activities and sports

____ Degree(s) received

____ Awards and honors received

signature: _____________________________________ date: ________________________

If under 18, a parent or guardian must sign to opt the student out.

III. Examples of FERPA Web Sites and Notices →

A. Postsecondary Institutions: Best practice examples.

1. Best Practice: University of Tennessee, Knoxville.

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:ferpa_pk_english combined form .pdf

2. Best Practice: PennState

B. Primary / Secondary Institutions, Best practices

1. The District of Columbia has an excellent FERPA Notice, and included in the notice package, is a granular opt out form. The District of Columbia includes its opt out form online and on its digital registration system. These are all best practices.

The form is available at: https://dcps.dc.gov/sites/default/files/dc/sites/dcps/publication/attachments/Notifications%20and%20Disclosures%20SY%2018-19.pdf.

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:District of Columbia Notifications and Disclosures SY 18-19.pdf

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:District of Columbia Notifications and Disclosures SY 18-19.pdf

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:District of Columbia Notifications and Disclosures SY 18-19.pdf

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:District of Columbia Notifications and Disclosures SY 18-19.pdf

2. Seattle Public Schools have a PreK-8 combined FERPA annual notice and FERPA opt out form. This particular form also gives notice of other items. It’s a good example of a form designed with utility for parents in mind.

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:ferpa_pk_english combined form .pdf

Macintosh HD:Users:pamdixon:Library:Mobile Documents:com~apple~CloudDocs:ferpa_pk_english combined form .pdf

IV. Examples of FERPA Opt Out Forms →

The following forms are very good examples of quite typical forms that schools are using for their FERPA implementations.

A. Postsecondary Forms

The Arizona State University FERPA opt form is excellent. The university provides three opt out choices in its form below. ASU also gives students the option of submitting the FERPA opt out form electronically through DocuSign. These are best practices. The DocuSign forms are delivered automatically to the registrar.

Rutgers State University of New Jersey has an excellent FERPA opt out form. It is well-designed to be clear and understandable, and includes full contact information for students who need help with the form, which is a best practice.

Missouri State University’s FERPA opt out form has good detail and it offers some choices. The form includes specific advice for students who have safety concerns. This is a best practice.

B. Primary / Secondary Forms

This is an example of a FERPA opt out form located in a handbook. It is not unusual to find FERPA information in student handbooks. This particular FERPA form was in an online handbook, integrated into the surrounding text, making parents’ practical ability to utilize the handbook form to make a readily printable FERPA opt out form challenging.

This FERPA form allows for specific opt out regarding photos and videos. This is a best practice.

The Houston Independent School District privacy code offers granular FERPA opt out, which is a best practice.

This opt out form can be completed online. This is a best practice.

V. Resources for Schools, Students, and Parents →

This list of resources is for parents, students, and educators. This list includes key education-related organizations, FERPA guidance, as well as resources regarding health privacy, including in emergency situations.

Key Education-Related Agencies, Associations, Organizations, Commissions:

U.S. Department of Education

https://www.ed.gov

The Office for Civil Rights (OCR) at the U.S. Department of Education

https://www2.ed.gov/about/offices/list/ocr/index.html

National Association of State Boards of Education

See in particular NASBE resources on privacy

http://www.nasbe.org and http://www.nasbe.org/project/education-data-privacy/nasbe-resources/

Council of Chief State School Officers

https://ccsso.org

National Governors Association

https://www.nga.org

and the NGA’s Best Practices for Education at: https://www.nga.org/bestpractices/divisions/education/

Individuals with Disabilities Education Act (IDEA)

IDEA is a law that makes a free and appropriate “public education available to eligible children with disabilities throughout the nation and ensures special education and related services to those children.” IDEA has a strong focus on protecting the rights of students and parents. The Department of Education maintains the IDEA web site.

https://sites.ed.gov/idea/

Federal Commission on School Safety

https://www.ed.gov/school-safety

Key Resources for Student and Parent Privacy at Schools

Privacy Technical Assistance Center (PTAC)

The Privacy Technical Assistance Center (PTAC) is part of the Department of Education. PTAC maintains numerous resources regarding FERPA and privacy, and they will also respond to questions.

https://studentprivacy.ed.gov/request-ptac-training-or-technical-assistance

Department of Education’s Student Privacy Policy Office (SPPO)

(The SPPO administers FERPA.)

Contact:

https://www.ed.gov/policy/gen/guid/fpco/index.html

1- 855-249-3072

https://studentprivacy.ed.gov/contact

Most Requested Privacy-Related Documents of Department of Education:

https://studentprivacy.ed.gov/most-requested-documents

Where to File a Complaint / Ask a Question

General:

Filing a Complaint with the US Department of Education:

Complaints are filed at the Office of Civil Rights at the U.S. Department of Education.

https://www2.ed.gov/about/offices/list/ocr/complaintintro.html

Discrimination in Education:

Department of Education OCR’s Outreach, Prevention, Education and Non-discrimination (OPEN) Center:

Contact: OPEN@ed.gov

(800) 421-3481 (TDD: 800-877-8339)

You may also fill out a complaint form online: https://www.ed.gov/ocr/complaintintro.html

Privacy:

Complaints, or Questions:

File a complaint about a problem with FERPA or ask a question about FERPA.

https://studentprivacy.ed.gov/contact

Resources for Issues Related to School Emergencies and Exceptional Circumstances, General

Schools regulated under FERPA have rules and processes in place for significant national emergencies such as major hurricanes, earthquakes, and pandemics.

Readiness and Emergency Management for Schools (REMS)

REMS is a part of the Department of Education that addresses a variety of biological hazards within K-12 schools. Issues include Coronavirus, or COVID 19, contaminated food outbreaks, other infectious diseases, toxic materials, and other biological hazards.

https://rems.ed.gov/Resources_Hazards_Threats_Biological_Hazards.aspx

Resources Specific to COVID-19 and other Health-Related Emergencies at Schools

Schools regulated under FERPA have rules and processes in place for significant national emergencies such as major hurricanes, earthquakes, and pandemics. This section is focused on health, privacy, and student and parent rights related to COVID-19.

FERPA and the Coronavirus Disease 2019 (COVID-19)

https://studentprivacy.ed.gov/resources/ferpa-and-coronavirus-disease-2019-covid-19

COVID-19 Emergency Fact Sheet: Addressing the Risk of COVID-19 in Schools While Protecting the Civil Rights of Students

U.S. Department of Education: https://www2.ed.gov/about/offices/list/ocr/docs/ocr-coronavirus-fact-sheet.pdf

Providing Services to Students with Disabilities During the COVID-19 Outbreak:

https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/qa-covid-19-03-12-2020.pdf

A Selection of additional Resources from REMS:


Appendix A: Research Spreadsheet Fields: Postsecondary Schools Covered Under FERPA →

The fields for the research conducted for this report at the postsecondary level included the following queries:

State Rural Actual Location of Opt out Form Opt out in student system?
State Urban FERPA Release Form URL (Chronological Data Pull for Public Universities) Date URL Accessed
[Date] Contact updates re: Forms not Found Phone 2nd Date URL Accessed
School Waiver? Information Shared without Opt out: [List]
First Result When Searching “FERPA” Waiver print copy? Public Student Directory – Yes indicates student email
FERPA Opt out on Registrar Page? Yes or No? Opt out? Note if in digital system Notes
Both Forms Downloadable Online Outside Student System? Opt out print copy?

Appendix B: Research Spreadsheet Fields: Primary and Secondary Schools Covered Under FERPA →

The following fields were included in the research for the data analyzed in this report for primary and secondary educational institutions covered under FERPA.

State Rural First Result When Searching FERPA Information Shared Without Opt Out: List of elements
State Urban FERPA opt out Form URL Called for Form: Y/N and Call Notes
School District Name and Associated Schools Form on Site: Y/N Notes from Site Research
Phone Opt out Process Known: Y/N
Website Date URL Accessed

Appendix C: Methodology →

Initial scoping

In the initial scoping for the research, a sample of primary, secondary, and postsecondary institutions were selected to represent exemplars of urban and rural educational institutions across 50 U.S. states. Care was taken to utilize census data and data from National Center for Education Statistics to understand demographic differences and ensure there was, as much as possible, a sample set that was representative, and that the selected schools were FERPA-covered entities. 101 primary/secondary school districts were selected, half rural districts and half urban districts, with 5,145 schools +/- 15 in the dataset. At the postsecondary level, 102 schools were selected, again balancing urban and rural as much as was possible, across all states.

The number of schools within some districts at the primary/secondary level changed during the research. Some schools closed, some districts added schools, and some schools merged or changed grades served. For the fourth and final pass of the research, our data was accurate up to October 2019. Changes may have taken place since that time. The numbers at that time were accurate to +/- 15 at the primary/secondary level, +/- 5 at the postsecondary level.

Sampling

The sampling collected multiple fields, including the FERPA notice, FERPA opt out form, when available, policy for photographs, and fields relating to title of the FERPA opt out notice and location of the notice, among other fields. The final sampling methodologies are included in Appendix A and B.

Initial results

Postsecondary. The first pass of the research for postsecondary schools provided a baseline for the study, and it was approximately within expectations. Most postsecondary schools provided FERPA notice in some format. Some post FERPA forms in paper format at a registrar’s office, or in some cases an IT office. Forms that are online are usually linked from the home page of the school or the registrar’s page, and are usually prominent, to varying degrees. The fact check for the first pass of the postsecondary research required further contact of schools when FERPA forms could not be located, and this research was also within expectations.

Primary/secondary. The first pass of the research for primary and secondary schools, as well as the school district web sites for those schools presented many challenges. It was not possible, despite persistent and significant efforts over time, to collect a full and complete representative sample of all of the FERPA notices and opt out forms in our sampled schools using online methods only. While much was learned about FERPA implementation, the incomplete online information left gaps in the early data.

FERPA notices and/ or opt out forms were not always posted online at the K-12 level. When they were posted, it was not always in a consistent, clear or prominent way. Some schools gave notice by handing out printed paper FERPA notices at the beginning of the year. Other schools delivered the FERPA notice in a school handbook. The variety of allowable notice methods made it difficult to consistently locate the information across the study sample.

When FERPA notices and forms were unavailable or could not easily be found online, WPF researchers contacted schools. In this process of talking with people across multiple states, it became clear that FERPA is not just about FERPA forms. It is about a culture within educational institutions that understands, values, and promotes parents’ and eligible students’ FERPA rights.

Overall aspects of first research pass. In the process of asking for FERPA information, researchers experienced a range of responses in the first research pass.

  • Some primary and secondary institutions exhibited good understanding of FERPA, and took many steps to notify parents and educate staff.
  • Some primary and secondary institutions did not appear to know what directory information was, nor what a directory information or FERPA opt out was.
  • When contacted, most institutions worked very hard to help locate the relevant information. However, it was not unusual for the process of inquiring at the schools to require multiple phone calls and take several days to weeks to complete as the right person was located. At the end of some of these interchanges, the form that was sent was, in the end, not the proper form, despite the well-intentioned efforts of the school.

Not all institutions would cooperate with questions about FERPA forms. Some institutions would not give a copy of the FERPA form or notice to researchers in some instances that because they were not students or parents at the school. Some school personnel hung up on researchers who asked if the institution could email a copy of the FERPA form, as researchers could not locate the form online.

Second and third research passes

For the second and third passes of the research, the methodology was streamlined and the sampling was re-evaluated to see if there were improvements that could be made. After making slight adjustments and receiving very similar results in the research and learning a great deal about FERPA implementation across the US, a final and fourth sampling was conducted.

Fourth research pass

For the fourth sampling, researchers took a different approach to the model. It became clear through the initial research passes that there were certain systemic challenges in conducting the research at the primary and secondary level. There were separate challenges that emerged from reviewing FERPA implementation at the postsecondary level. The fourth research pass built on the knowledge we gained from the first three passes.

For the fourth sampling, which is what is analyzed in this report, we designed the research by asking a different set of questions. We did not focus on compliance with FERPA, because strictly looking at baseline FERPA compliance did not uncover answers or practices that would solve the problems the research had uncovered. With understanding from earlier research passes, we focused on implementations, and what were the key risks to student privacy relative to directory information, and what practices or changes would create improved privacy outcomes for students?

  • How could schools communicate best today about directory information rights and risks to students and parents, and how could parents and students genuinely assess rights and informational risks?
  • How would a modern parent or student look for FERPA information?
  • Given modern advances in privacy legislation and thought, how could FERPA, if written today, adapt to current issues regarding directory information?
  • How would parents and students who had disabilities, were living in poverty, had limited language abilities, had safety considerations, were homeless, or who experienced other forms of marginalization, best be able to understand and effectuate their FERPA rights?

It was the fourth research pass that provided the most insight into FERPA implementation at the local level. This research, to our knowledge, has not been conducted before.

Transparency

We have endeavored to provide as much transparency as possible regarding our methodology while still keeping results deidentified. We will continue to do so. We understand that researchers may be interested in conducting a larger study, or a related study. If a qualified academic researcher has a question, or wants further detail regarding this research, please contact WPF at info@worldprivacyforum.org, or through our additional contact information listed on our website.

Appendix D: Exceptions to requirement of consent prior to release of personally identifiable information held in educational records →

FERPA contains 16 exceptions to the rules regarding the necessity of prior consent to disclose information held in educational records. The exceptions are nuanced, and the regulations that describe the exceptions are included in full below.

Note: The full text of the FERPA regulations is available at: https://www2.ed.gov/policy/gen/guid/fpco/pdf/2012-final-regs.pdf

Family Educational Rights and Privacy Act

Subpart D-May an Educational Agency or Institution disclose Personally Identifiable Information from Education Records?

§ 99.30 Under what conditions is prior consent required to disclose information?

(a) The parent or eligible student shall provide a signed and dated written consent before an educational agency or institution discloses personally identifiable information from the student’s education records, except as provided in § 99.31.

(b) The written consent must:
(1) Specify the records that may be disclosed;</px-3 Blockquote> (2) State the purpose of the disclosure; and</px-3 Blockquote> (3) Identify the party or class of parties to whom the disclosure may be made.</px-3 Blockquote> (c) When a disclosure is made under paragraph (a) of this section:
(1) If a parent or eligible student so requests, the educational agency or institution shall provide him or her with a copy of the records disclosed; and</px-3 Blockquote> (2) If the parent of a student who is not an eligible student so requests, the agency or institution shall provide the student with a copy of the records disclosed.</px-3 Blockquote> (d) “Signed and dated written consent” under this part may include a record and signature in electronic form that-
(1) Identifies and authenticates a particular person as the source of the electronic consent; and</px-3 Blockquote> (2) Indicates such person’s approval of the information contained in the electronic consent.</px-3 Blockquote> (Authority: 20 U.S.C. 1232g (b)(1) and (b)(2)(A))

§ 99.31 Under what conditions is prior consent not required to disclose information?

(a) An educational agency or institution may disclose personally identifiable information from an education record of a student without the consent required by § 99.30 if the disclosure meets one or more of the following conditions:

(1)(i)(A) The disclosure is to other school officials, including teachers, within the agency or institution whom the agency or institution has determined to have legitimate educational interests.
(B) A contractor, consultant, volunteer, or other party to whom an agency or institution has outsourced institutional services or functions may be considered a school official under this paragraph provided that the outside party—</px-3 Blockquote> (1) Performs an institutional service or function for which the agency or institution would otherwise use employees;</px-3 Blockquote> </px-3 Blockquote> (2) Is under the direct control of the agency or institution with respect to the use and maintenance of education records; and</px-3 Blockquote> </px-3 Blockquote> (3) Is subject to the requirements of</px-3 Blockquote> </px-3 Blockquote> § 99.33(a) governing the use and redisclosure of personally identifiable information from education records.

(ii) An educational agency or institution must use reasonable methods to ensure that school officials obtain access to only those education records in which they have legitimate educational interests.

An educational agency or institution that does not use physical or technological access controls must ensure that its administrative policy for controlling access to education records is effective and that it remains in compliance with the legitimate educational interest requirement in paragraph (a)(1)(i)(A) of this section.

(2) The disclosure is, subject to the requirements of § 99.34, to officials of another school, school system, or institution of postsecondary education where the student seeks or intends to enroll, or where the student is already enrolled so long as the disclosure is for purposes related to the student’s enrollment or transfer.

Note: Section 4155(b) of the No Child Left Behind Act of 2001, 20 U.S.C. 7165(b), requires each State to assure the Secretary of Education that it has a procedure in place to facilitate the transfer of disciplinary records with respect to a suspension or expulsion of a student by a local educational agency to any private or public elementary or secondary school in which the student is subsequently enrolled or seeks, intends, or is instructed to enroll.

(3) The disclosure is, subject to the requirements of § 99.35, to authorized representatives of-
(i) The Comptroller General of the United States;</px-3 Blockquote> (ii) The Attorney General of the United States;</px-3 Blockquote> (iii) The Secretary; or</px-3 Blockquote> (iv) State and local educational authorities.</px-3 Blockquote> (4)(i) The disclosure is in connection with financial aid for which the student has applied or which the student has received, if the information is necessary for such purposes as to:
(A) Determine eligibility for the aid;</px-3 Blockquote> (B) Determine the amount of the aid;</px-3 Blockquote> (C) Determine the conditions for the aid; or</px-3 Blockquote> (D) Enforce the terms and conditions of the aid.</px-3 Blockquote> (ii) As used in paragraph (a)(4)(i) of this section,”financial aid” means a payment of funds provided to an individual (or a payment in kind of tangible or intangible property to the individual) that is conditioned on the individual’s attendance at an educational agency or institution.

(Authority: 20 U.S.C. 1232g(b)(1)(D))

(5)(i) The disclosure is to State and local officials or authorities to whom this information is specifically-
(A) Allowed to be reported or disclosed pursuant to a State statute adopted before November 19, 1974, if the allowed reporting or disclosure concerns the juvenile justice system and the system’s ability to effectively serve the student whose records are released; or</px-3 Blockquote> (B) Allowed to be reported or disclosed pursuant to a State statute adopted after November 19, 1974, subject to the requirements of § 99.38.</px-3 Blockquote> (ii) Paragraph (a)(5)(l) of this section does not prevent a State from further limiting the number or type of State or local officials to whom disclosures may be made under that paragraph.

(6)(i) The disclosure is to organizations conducting studies for, or on behalf of, educational agencies or institutions to:
(A) Develop, validate, or administer predictive tests;</px-3 Blockquote> (B) Administer student aid programs; or (C) Improve instruction.</px-3 Blockquote> (ii) Nothing in the Act or this part prevents a State or local educational authority or agency headed by an official listed in paragraph (a)(3) of this section from entering into agreements with organizations conducting studies under paragraph (a)(6)(i) of this section and redisclosing personally identifiable information from education records on behalf of educational agencies and institutions that disclosed the information to the State or local educational authority or agency headed by an official listed in paragraph (a)(3) of this section in accordance with the requirements of § 99.33(b).

(iii) An educational agency or institution may disclose personally identifiable information under paragraph (a)(6)(i) of this section, and a State or local educational authority or agency headed by an official listed in paragraph (a)(3) of this section may redisclose personally identifiable information under paragraph (a)(6)(i) and (a)(6)(ii) of this section, only if –
(A) The study is conducted in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization that have legitimate interests in the information;</px-3 Blockquote> (B) The information is destroyed when no longer needed for the purposes for which the study was conducted; and</px-3 Blockquote> (C) The educational agency or institution or the State or local educational authority or agency headed by an official listed in paragraph (a)(3) of this section enters into a written agreement with the organization that –</px-3 Blockquote> (1) Specifies the purpose, scope, and duration of the study or studies and the information to be disclosed;</px-3 Blockquote> </px-3 Blockquote> (2) Requires the organization to use personally identifiable information from education records only to meet the purpose or purposes of the study as stated in the written agreement;</px-3 Blockquote> </px-3 Blockquote> (3) Requires the organization to conduct the study in a manner that does not permit personal identification of parents and students, as defined in this part, by anyone other than representatives of the organization with legitimate interests; and</px-3 Blockquote> </px-3 Blockquote> (4) Requires the organization to destroy all personally identifiable information when the information is no longer needed for the purposes for which the study was conducted and specifies the time period in which the information must be destroyed.</px-3 Blockquote> </px-3 Blockquote> (iv) An educational agency or institution or State or local educational authority or Federal agency headed by an official listed in paragraph (a)(3) of this section is not required to initiate a study or agree with or endorse the conclusions or results of the study.

(v) For the purposes of paragraph (a)(6) of this section, the term “organization” includes, but is not limited to, Federal, State, and local agencies, and independent organizations.

(7) The disclosure is to accrediting organizations to carry out their accrediting functions.

(8) The disclosure is to parents, as defined in § 99.3, of a dependent student, as defined in section 152 of the Internal Revenue Code of 1986.

(9)(i) The disclosure is to comply with a judicial order or lawfully issued subpoena.

(ii) The educational agency or institution may disclose information under paragraph (a)(9)(i) of this section only if the agency or institution makes a reasonable effort to notify the parent or eligible student of the order or subpoena in advance of compliance, so that the parent or eligible student may seek protective action, unless the disclosure is in compliance with-
(A) A Federal grand jury subpoena and the court has ordered that the existence or the contents of the subpoena or the information furnished in response to the subpoena not be disclosed;</px-3 Blockquote> (B) Any other subpoena issued for a law enforcement purpose and the court or other issuing agency has ordered that the existence or the contents of the subpoena or the information furnished in response to the subpoena not be disclosed; or</px-3 Blockquote> (C) An ex parte court order obtained by the United States Attorney General (or designee not lower than an Assistant Attorney General) concerning investigations or prosecutions of an offense listed in 18 U.S.C. 2332b(g)(5)(B) or an act of domestic or international terrorism as defined in 18 U.S.C. 2331.</px-3 Blockquote> (iii) (A) If an educational agency or institution initiates legal action against a parent or student, the educational agency or institution may disclose to the court, without a court order or subpoena, the education records of the student that are relevant for the educational agency or institution to proceed with the legal action as plaintiff.

(B) If a parent or eligible student initiates legal action against an educational agency or institution, the educational agency or institution may disclose to the court, without a court order or subpoena, the student’s education records that are relevant for the educational agency or institution to defend itself.

(10) The disclosure is in connection with a health or safety emergency, under the conditions described in § 99.36.

(11) The disclosure is information the educational agency or institution has designated as “directory information,” under the conditions described in

§ 99.37.

(12) The disclosure is to the parent of a student who is not an eligible student or to the student.

(13) The disclosure, subject to the requirements in § 99.39, is to a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense. The disclosure may only include the final results of the disciplinary proceeding conducted by the institution of postsecondary education with respect to that alleged crime or offense. The institution may disclose the final results of the disciplinary proceeding, regardless of whether the institution concluded a violation was committed.

(14)(i) The disclosure, subject to the requirements in § 99.39, is in connection

with a disciplinary proceeding at an institution of postsecondary education. The institution must not disclose the final results of the disciplinary proceeding unless it determines that
(A) The student is an alleged perpetrator of a crime of violence or non-forcible sex offense; and</px-3 Blockquote> (B) With respect to the allegation made against him or her, the student has committed a violation of the institution’s rules or policies.</px-3 Blockquote> (ii) The institution may not disclose the name of any other student, including a victim or witness, without the prior written consent of the other student.

(iii) This section applies only to disciplinary proceedings in which the final results were reached on or after October 7, 1998.

(15)(i) The disclosure is to a parent of a student at an institution of postsecondary education regarding the student’s violation of any Federal, State, or local law, or of any rule or policy of the institution, governing the use or possession of alcohol or a controlled substance if-
(A) The institution determines that the student has committed a disciplinary violation with respect to that use or possession; and</px-3 Blockquote> (B) The student is under the age of 21 at the time of the disclosure to the parent.</px-3 Blockquote> (ii) Paragraph (a)(15) of this section does not supersede any provision of State law that prohibits an institution of postsecondary education from disclosing information.

(16) The disclosure concerns sex offenders and other individuals required to register under section 170101 of the Violent Crime Control and Law Enforcement Act of 1994, 42 U.S.C. 14071, and the information was provided to the educational agency or institution under 42 U.S.C. 14071 and applicable Federal guidelines.

(b)(1) De-identified records and information. An educational agency or institution, or a party that has received education records or information from education records under this part, may release the records or information without the consent required by § 99.30 after the removal of all personally identifiable information provided that the educational agency or institution or other party has made a reasonable determination that a student’s identity is not personally identifiable, whether through single or multiple releases, and taking into account other reasonably available information.

(2) An educational agency or institution, or a party that has received education records or information from education records under this part, may release de- identified student level data from education records for the purpose of education research by attaching a code to each record that may allow the recipient to match information received from the same source, provided that—
(i) An educational agency or institution or other party that releases de-identified data under paragraph (b)(2) of this section does not disclose any information about how it generates and assigns a record code, or that would allow a recipient to identify a student based on a record code;</px-3 Blockquote> (ii) The record code is used for no purpose other than identifying a de- identified record for purposes of education research and cannot be used to ascertain personally identifiable information about a student; and</px-3 Blockquote> (iii) The record code is not based on a student’s social security number or other personal information.</px-3 Blockquote> (c) An educational agency or institution must use reasonable methods to identify and authenticate the identity of parents, students, school officials, and any other parties to whom the agency or institution discloses personally identifiable information from education records.

(d) Paragraphs (a) and (b) of this section do not require an educational agency or institution or any other party to disclose education records or information from education records to any party except for parties under paragraph (a)(12) of this section.

(Authority: 20 U.S.C. 1232g(a)(5)(A), (b), (h), (i), and (j))

Appendix E: Model Notification of Rights, Department of Education →

Model Notification of Rights under FERPA for Elementary and Secondary Schools

The Family Educational Rights and Privacy Act (FERPA) affords parents and students who are 18 years of age or older (“eligible students”) certain rights with respect to the student’s education records. These rights are:

1. The right to inspect and review the student’s education records within 45 days after the day the [name of school (“school”)] receives a request for access.

Parents or eligible students who wish to inspect their child’s or their education records should submit to the school principal [or appropriate school official] a written request that identifies the records they wish to inspect. The school official will make arrangements for access and notify the parent or eligible student of the time and place where the records may be inspected.

2. The right to request the amendment of the student’s education records that the parent or eligible student believes are inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.

Parents or eligible students who wish to ask the [school] to amend their child’s or their education record should write the school principal [or appropriate school official], clearly identify the part of the record they want changed, and specify why it should be changed. If the school decides not to amend the record as requested by the parent or eligible student, the school will notify the parent or eligible student of the decision and of their right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the parent or eligible student when notified of the right to a hearing.

3. The right to provide written consent before the school discloses personally identifiable information (PII) from the student’s education records, except to the extent that FERPA authorizes disclosure without consent.

One exception, which permits disclosure without consent, is disclosure to school officials with legitimate educational interests. The criteria for determining who constitutes a school official and what constitutes a legitimate educational interest must be set forth in the school’s or school district’s annual notification for FERPA rights. A school official typically includes a person employed by the school or school district as an administrator, supervisor, instructor, or support staff member (including health or medical staff and law enforcement unit personnel) or a person serving on the school board. A school official also may include a volunteer, contractor, or consultant who, while not employed by the school, performs an institutional service or function for which the school would otherwise use its own employees and who is under the direct control of the school with respect to the use and maintenance of PII from education records, such as an attorney, auditor, medical consultant, or therapist; a parent or student volunteering to serve on an official committee, such as a disciplinary or grievance committee; or a parent, student, or other volunteer assisting another school official in performing his or her tasks. A school official typically has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibility.

[optional] Upon request, the school discloses education records without consent to officials of another school or school district in which a student seeks or intends to enroll, or is already enrolled if the disclosure is for purposes of the student’s enrollment or transfer. [NOTE: FERPA requires a school or school district to make a reasonable attempt to notify the parent or student of the records request unless it states in its annual notification that it intends to forward records on request or the disclosure is initiated by the parent or eligible student.]

4. The right to file a complaint with the U.S. Department of Education concerning alleged failures by the [school] to comply with the requirements of FERPA. The name and address of the Office that administers FERPA are:

Family Policy Compliance Office

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202

[note: In addition, a school may want to include its directory information public notice, as required by § 99.37 of the regulations, with its annual notification of rights under ferpa.]

[optional] See the list below of the disclosures that elementary and secondary schools may make without consent.

FERPA permits the disclosure of PII from students’ education records, without consent of the parent or eligible student, if the disclosure meets certain conditions found in § 99.31 of the FERPA regulations. Except for disclosures to school officials, disclosures related to some judicial orders or lawfully issued subpoenas, disclosures of directory information, and disclosures to the parent or eligible student, § 99.32 of the FERPA regulations requires the school to record the disclosure. Parents and eligible students have a right to inspect and review the record of disclosures. A school may disclose PII from the education records of a student without obtaining prior written consent of the parents or the eligible student –

  • To other school officials, including teachers, within the educational agency or institution whom the school has determined to have legitimate educational interests. This includes contractors, consultants, volunteers, or other parties to whom the school has outsourced institutional services or functions, provided that the conditions listed in § 99.31(a)(1)(i)(B)(1) – (a)(1)(i)(B)(3) are met. (§ 99.31(a)(1))
  • To officials of another school, school system, or institution of postsecondary education where the student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer, subject to the requirements of § 99.34. (§ 99.31(a)(2))
  • To authorized representatives of the U. S. Comptroller General, the U. S. Attorney General, the U.S. Secretary of Education, or State and local educational authorities, such as the State educational agency (SEA) in the parent or eligible student’s State. Disclosures under this provision may be made, subject to the requirements of § 99.35, in connection with an audit or evaluation of Federal- or State-supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs. These entities may make further disclosures of PII to outside entities that are designated by them as their authorized representatives to conduct any audit, evaluation, or enforcement or compliance activity on their behalf, if applicable requirements are met. (§§ 99.31(a)(3) and 99.35)
  • In connection with financial aid for which the student has applied or which the student has received, if the information is necessary for such purposes as to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid. (§ 99.31(a)(4))
  • To State and local officials or authorities to whom information is specifically allowed to be reported or disclosed by a State statute that concerns the juvenile justice system and the system’s ability to effectively serve, prior to adjudication, the student whose records were released, subject to § 99.38. (§ 99.31(a)(5))
  • To organizations conducting studies for, or on behalf of, the school, in order to: (a) develop, validate, or administer predictive tests; (b) administer student aid programs; or (c) improve instruction, if applicable requirements are met. (§ 99.31(a)(6))
  • To accrediting organizations to carry out their accrediting functions. (§ 99.31(a)(7))
  • To parents of an eligible student if the student is a dependent for IRS tax purposes. (§ 99.31(a)(8))
  • To comply with a judicial order or lawfully issued subpoena if applicable requirements are met. (§ 99.31(a)(9))
  • To appropriate officials in connection with a health or safety emergency, subject to § 99.36. (§ 99.31(a)(10)
  • Information the school has designated as “directory information” if applicable requirements under § 99.37 are met. (§ 99.31(a)(11))
  • To an agency caseworker or other representative of a State or local child welfare agency or tribal organization who is authorized to access a student’s case plan when such agency or organization is legally responsible, in accordance with State or tribal law, for the care and protection of the student in foster care placement. (20 U.S.C. § 1232g(b)(1)(L))
  • To the Secretary of Agriculture or authorized representatives of the Food and Nutrition Service for purposes of conducting program monitoring, evaluations, and performance measurements of programs authorized under the Richard B. Russell National School Lunch Act or the Child Nutrition Act of 1966, under certain conditions. (20 U.S.C. § 1232g(b)(1)(K))

Available at: https://www2.ed.gov/policy/gen/guid/fpco/index.html

Model Notice for Directory Information

[Note: Per 34 C.F.R. § 99.37(d), a school or school district may adopt a limited directory information policy. If a school or school district does so, the directory information notice to parents and eligible students must specify the parties who may receive directory information and/or the purposes for which directory information may be disclosed.]

The Family Educational Rights and Privacy Act (FERPA), a Federal law, requires that [school or school district], with certain exceptions, obtain your written consent prior to the disclosure of personally identifiable information from your child’s education records. However, [school or school district] may disclose appropriately designated “directory information” without written consent, unless you have advised the [school or school district] to the contrary in accordance with [school or school district] procedures. The primary purpose of directory information is to allow the [school or school district] to include information from your child’s education records in certain school publications. Examples include:

  • A playbill, showing your student’s role in a drama production;
  • The annual yearbook;
  • Honor roll or other recognition lists;
  • Graduation programs; and
  • Sports activity sheets, such as for wrestling, showing weight and height of team members.

Directory information, which is information that is generally not considered harmful or an invasion of privacy if released, can also be disclosed to outside organizations without a parent’s prior written consent. Outside organizations include, but are not limited to, companies that manufacture class rings or publish yearbooks. In addition, two federal laws require local educational agencies (LEAs) receiving assistance under the Elementary and Secondary Education Act of 1965, as amended (ESEA) to provide military recruiters, upon request, with the following information – names, addresses and telephone listings – unless parents have advised the LEA that they do not want their student’s information disclosed without their prior written consent. [Note: These laws are Section 9528 of the ESEA (20 U.S.C. § 7908) and 10 U.S.C. § 503(c).]

If you do not want [school or school district] to disclose any or all of the types of information designated below as directory information from your child’s education records without your prior written consent, you must notify the [school or school district] in writing by [insert date]. [school district] has designated the following information as directory information: [Note: an LEA may, but does not have to, include all the information listed below.]

  • Student’s name
  • Address
  • Telephone listing
  • Electronic mail address
  • Photograph
  • Date and place of birth
  • Major field of study
  • Dates of attendance
  • Grade level
  • Participation in officially recognized activities and sports
  • Weight and height of members of athletic teams
  • Degrees, honors, and awards received
  • The most recent educational agency or institution attended
  • Student ID number, user ID, or other unique personal identifier used to communicate in electronic systems but only if the identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the user’s identity, such as a PIN, password, or other factor known or possessed only by the authorized user
  • A student ID number or other unique personal identifier that is displayed on a student ID badge, but only if the identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the user’s identity, such as a PIN, password, or other factor known or possessed only by the authorized user.

Available at: https://www2.ed.gov/policy/gen/guid/fpco/index.html

These notices are the US Department of Education model notices for FERPA.

Appendix F: Roster of Schools →

This is a list of the schools studied. We were not able to include the postsecondary schools, as the sample size and nature of the research findings did not allow for sufficient deidentification. During the research period, the postsecondary schools did not change. At the primary and secondary level, there was change. Some schools were closed, some opened, some merged, and some changed grade levels. As a result, there were some adjustments we had to make to the n. We are allowing a +/- 15 schools on primary/secondary non-aggregate statistics to accommodate these changes over time.


Anderson Elementary
Anne Wien Elementary
Arctic Light Elementary
Crawford Elementary
Denali Elementary
Hunter Elementary
Joy Elementary
Ladd Elementary
Midnight Sun Elementary
Nordale Elementary
North Pole Elementary
Pearl Creek Elementary
Salcha Elementary
Ticasuk Brown Elementary
Two Rivers K-8
University Park Elementary
Weller Elementary
Woodriver Elementary
Ketchikan Charter School
Tongass School of Arts and Sciences
Houghtaling
Fawn Mountain
Point Higgins
Ketchikan High School
Revilla
Schoenbar Middle School
Baker High
Blount High
Alma Bryant High
Citronelle High
Davidson High
LeFlore High
Montgomery High
Murphy High
Rain High
Theodore High
Vigor High
Williamson High
Addison Elementary School
Addison High School
Lynn Elementary School
Lynn High School
Meek Elementary School
Meek High School
Double Springs Elementary School
Double Springs Middle School
Winston County High School
Winston Career Academy
Booneville High School
Booneville Junior High School
Booneville Elementary School
Bethune
Capitol
Dunbar
Edison
Emerson
Faith North Preschool
Garfield
Heard
Herrera
Kenilworth
Lowell
Magnet Traditional School
Shaw Montessori
Whittier
Globe high school,
High Desert Middle School,
Copper Rim Elementary School
Canyon Ridge High School
Career & Adult Education School
Hesperia Community Day School
Hesperia High School
Mojave High School
Oak Hills High School
Shadow Ridge School
Sultana High School
Cedar Middle School
Hesperia Jr. High School
Ranchero Middle School
Carmel Elementary School
Cottonwood Elementary School
Cypress School of the Arts
Eucalyptus Elementary School
Hollyvale Innovation Academy
Joshua Circle Elementary School
Juniper Elementary School
Kingston Elementary School
Krystal School
Lime Street Elementary School
Maple Elementary School
Mesa Grande Elementary School
Mesquite Trails Elementary School
Mission Crest Elementary School
Topaz Preparatory Academy
Beech Street Pre-School
Kemper Elementary School
Lewis – Arriola Elementary School
Manaugh Elementary School
Mesa Elementary School
Montezuma – Cortez High School
Montezuma-Cortez Middle School
Pleasant View Elementary
Battlerock Charter School
Southwest Open School
Children’s Kiva Montessori School
Pomperaug HS,
Memorial Middle School,
Rochambeau Middle School,
Gainfield Elementary School,
Long Meadow Elementary School,
Middlebury Elementary School,
Pomperaug Elementary school
Christina Early Education Center
Stubbs Early Education Center
Brader Elementary School
Brookside Elementary School
Downes Elementary School
Gallaher Elementary School
Jones Elementary School
Keene Elementary School
Leasure Elementary School
Maclary Elementary School
Marshall Elementary School
McVey Elementary School
Oberle Elementary School
Smith Elementary School
West Park Place Elementary School
Wilson Elementary School
The Bancroft School
The Bayard School
Gauger-Cobbs Middle School
Kirk Middle School
Shue-Medill Middle School
Christiana High School
Glasgow High School
Newark High School
Brennen School
Christina Adult Programs
Delaware School for the Deaf
Douglass School
Middle School Honors Academy at Christiana High School
Montessori Academies at Christina
Networks School for Employability Skills
REACH Program
Sarah Pyle Academy
Cape Henlopen High School[1]
Beacon Middle School
Mariner Middle School
Joseph S. Elementary School
H.O. Brittingham Elementary School
Milton Elementary School
Rehoboth Elementary School
Richard A. Shields Elementary School
Sussex Consortium
Kate Smith Elementary School
Vernon Elementary School
Roulhac Middle School
Vernon Middle School
Chipley High School
Vernon High School (Vernon, Florida)
Delta Innovative School
Brooks County High School
Brooks County Middle School
Quitman Elementary School
North Brooks Elementary School
Brooks County Early Learning Center
Highland Elementary,
Highland Middle School,
Highland High School
Adams Elementary School
Air Quality Procedures
Amity Elementary School
Boise Evening School
Boise High School
Borah High School
Capital High School
Collister Elementary School
Cynthia Mann Elementary School
Dennis Technical Education Center
East Junior High School
Fairmont Junior High School
Frank Church High School
Garfield Elementary School
Grace Jordan Elementary School
Hawthorne Elementary Schools
Hidden Springs Elementary School
Highlands Elementary School
Hillcrest Elementary School
Hillside Junior High School
Horizon Elementary School
Jefferson Elementary School
Koelsch Elementary School
Les Bois Junior High School
Liberty Elementary School
Longfellow Elementary School
Lowell Elementary School
Madison Early Childhood Center
Maple Grove Elementary School
Marian Pritchett School
Monroe Elementary School
Morley Nelson Elementary School
Mountain View Elementary School
North Junior High School
Owyhee Elementary School
Pierce Park Elementary School
Riverglen Junior High School
Riverside Elementary School
Roosevelt Elementary School
School Boundaries
School Feeder Elementary School
South Junior High School
Taft Elementary School
Timberline High School
Trail Wind Elementary School
Treasure Valley Math & Science Center
Valley View Elementary School
Washington Elementary School
West Junior High School
White Pine Elementary School
Whitney Elementary School
Whittier Elementary Schoolhart
Shadow Hills Elementary
Aberdeen Elementary,
Aberdeen Middle School,
Aberdeen High School
Mulberry Grove Elementary,
Mulberry Grove Middle/High School
Arlington Community High School
Arsenal Technical High School
Crispus Attucks Medical Magnet High School
Emmerich Manual High School
George Washington Community High School
Northwest High School
Thomas Carr Howe Community High School
Beech Grove High School
Decatur Central High School
Franklin Central High School
Franklin Township Middle School West
Franklin Township Middle School East
Lawrence Central High School
Lawrence North High School
Perry Meridian High School
Southport High School
Pike High School
Speedway Senior High School
Warren Central High School
North Central High School
Ben Davis High School
Andrews Elementary School
Flint Springs Elementary School
Horace Mann Elementary School
Lincoln Elementary
Roanoke Elementary School
Salamonie School
Crestview Middle School
Riverview Middle School
Huntington North High School
Jefferson west elementary, middle, high school
Belfry High School
East Ridge High School
Phelps High School
Pike County Central High School
Shelby Valley High School
Belfry Middle
Belfry Elementary
Bevins Elementary
Dorton Elementary
Elkhorn City Elementary
Feds Creek Elementary
Johns Creek Elementary
Kimper Elementary
Milliard School
Mullins School
Northpoint Academy
Phelps Day Treatment
Phelps Elementary
Shelby Valley Day Treatment
Valley Elementary
Baskin School
Crowville School
Fort Necessity School
Franklin Parish High School
Gilbert School
Winnsboro Elementary School
Sekonk HS,
Kevin Hurley Middle School,
Mildred Aitkin Elementary,
George Martin Elementary
Chapel District Elementary School
Easton Elementary School
St. Michaels Elementary School
Tilghman Elementary School
White Marsh Elementary School
Easton High School
St. Michaels Middle/High School
Easton Middle School
Cliff Island School
East End Community School
Rowe Elementary School
Longfellow Elementary School
Lyseth Elementary School
Ocean Avenue School
Peaks Island Elementary School
Presumpscot Elementary School
Reiche Elementary School
Riverton Elementary School
King Middle School
Lincoln Middle School
Lyman Moore Middle School
Casco Bay High School
Deering High School
Portland Arts and Technology High School
Portland High School
William H Rowe School,
Yarmouth Elementary School,
Frank H Harrison Middle School,
Yarmouth HS
Fitzgerald Early Childhood,
Westview Lower Elementary,
Mound Park Upper Elementary,
Chatterton Middle School,
Fitzgerald HS,
Fitzgerald Virtual Academy
Monticello High School,
Monticello Middle School,
Little Mountain Elementary,
Pinewood Elementary,
Eastview Education Center
Lafayette High School (Grades 9-12)
Lafayette Middle School (Grades 6-8)
Lafayette Upper Elementary School (Grades 3-5)
Lafayette Lower Elementary School (Grades K-2)
Emily Dickinson Elementary School
Hawthorne Elementary School
Hyalite Elementary School
Irving Elementary School
Longfellow Elementary School
Meadowlark Elementary School
Morning Star Elementary School
Whittier Elementary School
Bozeman High School
Bridger Charter Academy
Chief Joseph Middle School
Sacajawea Middle School
Buckland Elementary School
Gatesville Elementary School
T.S. Cooper Elementary School
Central Middle School
Gates County High School
BM Hanson Elementary School
Harvey High School
Leyton Elementary, Leyton Middle School, Leyton High School
Bakersville
Beech
Gossler
Green Acres
Hallsville
Highland-Goffe’s Falls
Jewett
McDonough
Northwest
Parker-Varney
Smyth Road
Webster
Weston
Wilson
Hillside
McLaughlin
Parkside
Southside
Central
Memorial
MST
West
Monadnock Regional Middle High School
Cutler Elementary School
Emerson Elementary School
Gilsum STEAM Academy
Mount Caesar Elementary School
Troy Elementary School
Elwood Kindle Elementary School
Memorial Elementary School
Pitman High School
Pitman Middle School
W.C.K. Walls Elementary School
Blanco Elementary
Bloomfield Early Childhood Center
Bloomfield High School
Central Primary
Charlie Y. Brown High School
Mesa Alta Jr. High
Naaba Ani Elementary
Humboldt County School District
Albert M. Lowry High School
Winnemucca Junior High School
French Ford Middle School
Grass Valley Elementary School
Sonoma Heights Elementary School
Winnemucca Grammar School
McDermitt Combined Schools
HCSD Rural Remote Schools
Innovations Distance Education Academy
Iroquois HS,
Iroquois Middle School,
Elma Primary,
Marilla Primary,
Wales Primary
Evergreen High School
Evergreen Junior High School
Evergreen Elementary School
Crooked Oak Elementary, Middle School, High School
Deer Creek Elementary,
Prarie Vale Elementary,
Rose Union Elementary,
Grove Valley Elementary,
Spring Creek Elementary,
Deer Creek Intermediate,
Deer Creek Middle,
Deer Creek HS
Sweet Home Junior High
Foster Elementary
Hawthorne Elementary
Holley Elementary
Oak Heights Elementary
Portage Elementary,
Portage Junion/Senior High School
Cedar Hill Elementary
E.T. Wyman Elementary
Greenwood Elementary
Holliman Elementary
Hoxsie Elementary
Lippitt Elementary
Norwood Elementary
Oakland Beach Elementary
Park Elementary
Robertson Elementary
Scott Elementary
Sherman Elementary
Warwick Early Learning Center
Warwick Neck Elementary
Veterans Middle School
Winman Middle School
Pilgrim High School
Toll Gate High School
Warwick Area Career & Technical Center
White Lake Elementary School
White Lake Junior High School
White Lake High School
Birch Creek,
Canyon,
Cedar Ridge,
Greenville,
Heritage,
Lewiston,
Lincoln,
Millville,
Mountainside,
Nibley,
North Park,
Providence,
River Heights,
Summit,
Sunrise,
Wellsville,
White Pine,
North Cache,
South Cache,
Spring Creek,
Green Canyon,
Mountain Crest,
Ridgeline,
Sky View,
Cache High
Abingdon Elementary School »
Greendale Elementary School »
High Point Elementary School »
Meadowview Elementary School »
Rhea Valley Elementary School »
Valley Institute Elementary School »
Watauga Elementary School »
Abingdon High School »
Holston High School »
John S. Battle High School »
Patrick Henry High School »
Washington County CTE Center »
Damascus Middle School »
E.B. Stanley Middle School »
Glade Spring Middle School »
Wallace Middle School »
Burlington High School
Burlington Tech Center
Champlain Elementary
C.P. Smith Elementary
Early Education
Edmunds Elementary
Edmunds Middle School
Hunt Middle School
Integrated Arts Academy
J.J. Flynn Elementary
Sustainability Academy
Expanded Learning
Horizons Alternative Program
OnTop Alternative Program
South Whidbey Elementary 1,
South Whidbey Elemenatry 2,
South Whidbey Middle 1,
South Whidbey High School Academy
Dodgeville Elementary,
Ridgeville Elementary,
Dodgeville Middle School,
Dodgeville High School
Mountan View Elementary,
Mountain View Middle School,
James Monroe High School/Monroe Tech Center,
Peterstown Elementary School,
Peterstown Middle School
Bondurant Elementary School
Pinedale Elementary School,
Pinedale Middle School,
Pinedale High School,
Skyline Academy High School
Central International Studies High School
Hall High School
East McClellan Magnet High School
Parkview Arts and Science Magnet High School
J. A. Fair Systems Magnet High School
Adult Education Center
Accelerated Learning Center
Metropolitan Career-Technical Center
W. D. Hamilton Learning Academy
Felder Academy
Bale Elementary School
Baseline Elementary School
Booker Arts and Science Magnet Elementary School
Brady Elementary School
Carver Basic Skills Math-Science Magnet Elementary School
Chicot Primary School
David O. Dodd Elementary School
Don R. Roberts Elementary School
Fair Park Early Childhood Center
Forest Park Elementary School
Franklin Communication Technology Elementary School
Franklin Alternative Environment
Fulbright Elementary School
Gibbs Magnet School of International Studies and Foreign Languages
Jefferson Elementary School
Dr. Martin Luther King, Jr. Interdistrict Magnet Elementary School
Mabelvale Elementary School
McDermott Elementary School
Meadowcliff Elementary School
Otter Creek Elementary School
Pulaski Heights Elementary School
Rockefeller Early Childhood Magnet Elementary School
Romine Computer Science and Basic Skills Interdistrict Elementary School
Stephens Elementary School
Terry Elementary School
Wakefield Elementary School
Washington Basic Skills Math-Science Interdistrict Magnet Elementary School
Watson Intermediate School
Western Hills Elementary School
Williams Traditional Magnet Elementary School
Wilson Elementary School
Woodruff Early Childhood Center
Central Los Angeles New Learning Center
Middle School/High School
Sherman Oaks Center for Enriched Studies
Caroldale Learning Community
Ellen Ochoa Learning Center
Hesby Oaks School
Pio Pico Span School
Porter Ranch Community School
South Region Span K–8 1
Sylmar Leadership Academy
Utah Street Span School
Academia Semillas del Pueblo
Magnolia Science Academy
Los Angeles Center for Enriched Studies
Maywood Center for Enriched Studies (2017)
Robert Fulton College Preparatory School
Magnolia Science Academy
Eagle Rock High School
Rancho Dominguez Preparatory School
Arleta High School
Fairfax High School
Hamilton High School
Palisades Charter High School
Panorama High School
University High School
Venice High School
Dr. Maya Angelou Community High School
Arleta High School
Phineas Banning High School Wilmington,
Bell High School
Belmont High School
Helen Bernstein High School
Birmingham High School
Canoga Park High School
Carson High School
Cesar Chavez High School
Chatsworth High School
Grover Cleveland High School
Miguel Contreras Learning Complex
Crenshaw High School
Susan Miller Dorsey High School
Mervyn M. Dymally High School
East Valley High School
El Camino Real High School
Esteban Torres High School
Fairfax High School
Benjamin Franklin High School
John C. Fremont High School
Gardena High School
James A. Garfield High School
Granada Hills Charter High School
Ulysses S. Grant High School
Harbor Teacher Preparation Academy
Hollywood High School
Alexander Hamilton High School
Hamilton Humanities Magnet
Augustus F. Hawkins High School
Huntington Park High School
Thomas Jefferson High School
David Starr Jordan High School
John F. Kennedy High School
Robert F. Kennedy Community Schools
Abraham Lincoln High School
Alain Leroy Locke College Preparatory Academy
Los Angeles High School
Los Alamitos Pastoral College
Manual Arts High School
Linda Esperanza Marquez High School,
John Marshall High School
Felicitas and Gonzalo Mendez High School
James Monroe High School
Narbonne High School
North Hollywood High School
Northridge Academy High School
Palisades Charter High School
Panorama High School
John H. Francis Polytechnic High School
Ramon C. Cortines School of Visual and Performing Arts
Reseda High School
Diego Rivera Learning Complex
Roosevelt High School
Edward R. Roybal Learning Center
San Fernando High School
San Pedro High School
San Pedro High School Olguin Campus
Santee Education Complex
Sonia M. Sotomayor Learning Academies
South East High School
South Gate High School
Sylmar High School
William Howard Taft High School
University High School
Valley Academy of Arts and Sciences
Van Nuys High School
Venice High School
Verdugo Hills High School
Washington Preparatory High School
West Adams Preparatory High School
Westchester High School
Wilson High School
Abraham Lincoln Academia
Ana Marie Sandoval Asbury Elementary
Barnum Elementary School
Bradley International School
Bromwell Elementary School
Brown International Academy
Bruce Randolph School
Bryant-Webster Dual Language School
Career Education Center Early College
Carson Elementary School
Castro Elementary School
Cheltenham Elementary School
CMS Community School
Colfax Elementary School
College View Elementary School
Columbian Elementary School
Columbine Elementary School
Contemporary Learning Academy HS
Cory Elementary School
Cowell Elementary School
DELTA High School
Denison Montessori
Denver Center For International Studies
Denver Online High School
Denver School of the Arts
Dora Moore School
Doull Elementary School
Eagleton Elementary School
East High School
Edison Elementary School
Ellis Elementary School
Emily Griffith High School
Escalante-Biggs Academy
Fairview Elementary School
Farrell B. Howell School
Florence Crittenton High School
Florida Pitt Waller School
Force Elementary School
Garden Place Academy
George Washington High School
Gilliam School Grant Ranch ECE-8 School
Gust Elementary
Hallett Academy
Hamilton Middle School
Hill Campus of Arts & Sciences
Holm Elementary
John F. Kennedy
Johnson Elementary School
Kaiser Elementary School
Knapp Elementary School
Kunsmiller Creative Arts Academy
ES Lake International School
Lena Archuleta Lincoln Elementary
Lowry Elementary School
Marie L. Greenwood Academy
Marrama Elementary School
Math and Science Leadership Academy
Maxwell Elementary School
McKinley-Thatcher Elementary School
McMeen Elementary School
Montbello Career and Technical High School
Munroe Elementary School
Newlon Elementary School
Noel Community Arts
North High School
North High School Engagement Center P.R.E.P. Academy
Palmer Elementary School
Park Hill School
Pascual LeDoux Academy
Place Bridge Academy
Polaris Elementary School
Respect Academy
Sabin World School
Samuels Elementary School
Sandra Todd-Williams Academy
Slavens K-8 School
Skinner Middle School
Smith South High School
Southmoor Steck Elementary School
Stedman Elementary School
Steele Elementary School
Stephen Knight Center for Early Education
Swansea Elementary School
Teller Elementary School
Thomas Jefferson High School
Traylor Academy
University Park Elementary School
Westerly Creek Elementary
William (Bill) Roberts Achievement First
Hartford Academy
Elementary Achievement
First Hartford Academy
Middle Achievement First
Hartford High
Academy Achievement
First Summit Middle
Alfred E. Burr Elementary
Asian Studies Academy at Bellizzi Betances
STEM Magnet Breakthrough Magnet School,
North Breakthrough Magnet School,
South Bulkeley High
Burns Latino Studies Academy
Capital Preparatory
Magnet Classical
Magnet Culinary Arts Academy
Dr. James H Naylor/CCSU Leadership Academy
Dr. Joseph S. Renzulli Gifted and Talented Academy
Dr. Michael D. Fox School
E. B. Kennelly School
Environmental Sciences Magnet School Expeditionary Learning Academy at Moylan School
Global Communications Academy
Great Path Academy at Manchester Community College
Hartford Magnet Trinity College Academy
Hartford Pre-K Magnet High School, Inc:
Hartford’s Insurance & Finance Academy
HPHS Academy of Engineering & Green Technology
HPHS Academy of Nursing and Health Sciences
HPHS Law & Government Academy Journalism & Media Academy
Maria C. Colon Sanchez Elementary
Martin Luther King Jr. Elementary School
McDonough Middle School
Montessori Magnet Moylan
Montessori Magnet School at Annie Fisher Museum Academy at Wish
Noah Webster MicroSociety Magnet
OPPortunity High School
Parkville Community School
Pathways Academy of Technology and Design
R.J. Kinsella Magnet School of Performing Arts
Ramon E. Betances Early Reading Lab
S.A.N.D. School
Sarah J. Rawson Elementary (STEM) Magnet School
Thurman Milner School University High School of Science and Engineering
West Middle
Woodrow Wilson High School
Eastern High School
Anacostia High School
Ballou High School
Calvin Coolidge High School
Dunbar High School
Eastern High School
H.D. Woodson Senior High School
Theodore Roosevelt Senior High School
Woodrow Wilson High School
Benjamin Banneker Academic High School
Bell Multicultural High School
Duke Ellington School of the Arts
McKinley Technology High School
Phelps Architecture, Construction, and Engineering High School
School Without Walls High School
Alice Deal Middle School
Brookland Middle School
Eliot-Hine Middle School
Hardy Middle School
Hart Middle School
Jefferson Middle School Academy
John Hayden Johnson Middle School
Kelly Miller Middle School
Kramer Middle School
MacFarland Middle School
McKinley Middle School
Sousa Middle School
Stuart-Hobson Middle School
Ida B. Wells Middle School
Aiton Elementary School
Amidon-Bowen Elementary School
Bancroft Elementary School
Barnard Elementary School
Beers Elementary School
Brent Elementary School
Bruce-Monroe Elementary School
Bunker Hill Elementary School
Burroughs Elementary School
Burrville Elementary School
Cleveland Elementary School
C.W. Harris Elementary School
Drew Elementary School
John Eaton Elementary School
Garfield Elementary School
Garrison Elementary School 253 Prekindergarten (3) 5th
H.D. Cooke Elementary School 416 Prekindergarten (3) 5th
Hearst Elementary School
Hendley Elementary School
Houston Elementary School
Van Ness Elementary School
Watkins Elementary School
Wilson Elementary School
Brightwood Education Campus
Browne Education Campus
Cardozo Education Campus
Columbia Heights Education Campus (CHEC)
LaSalle-Backus Education Campus
Leckie Education Campus
Raymond Education Campus
School Without Walls at Francis-Stevens
Takoma Education Campus
Truesdell Education Campus
Walker-Jones Education Campus
West Education Campus
Wheatley Education Campus
Whittier Education Campus
Access Charter
Aloma Elementary
Aloma High Charter
Amikids Orlando
Andover Elementary
Apopka Elementary
Apopka High
Apopka Middle
Arbor Ridge K-8
Aspire Academy Charter
Audubon Park K-8
Avalon Elementary
Avalon Middle
Azalea Park Elementary
Benjamin E. Mays High School
BEST Academy High School
Booker T. Washington High School
Coretta Scott King Young Women’s Leadership Academy High School
Daniel McLaughlin Therrell High School
Frederick Douglass High School
Henry W. Grady High School
Maynard H. Jackson High School
The New Schools at Carver
Early College
School of the Arts
School of Health Sciences & Research
School of Technology
North Atlanta High School
South Atlanta High School
Inman Middle School
BEST Academy Middle School
Coretta Scott King Young Women’s Leadership Academy Middle School
Crawford Williamson Long Middle School
Jean Childs Young Middle School
Joseph Emerson Brown Middle School
Luther Judson Price Middle School
Martin Luther King Jr. Middle School
Ralph Johnson Bunche Middle School
Samuel M. Inman Middle School
Sylvan Hills Middle School
Willis Sutton Middle School
Adamsville Elementary School
Barack & Michelle Obama Academy
Beecher Hills Elementary School
Benteen Elementary School
Bethune Elementary School
Bolton Academy
Boyd Elementary School
Brandon Elementary School
Burgess/Peterson Elementary School
Cascade Elementary School
Centennial Place Elementary School
Cleveland Avenue Elementary School
Connally Elementary School
Continental Colony Elementary School
Deerwood Academy
Dobbs Elementary School
Dunbar Elementary School
Fain Elementary School
Fickett Elementary School
Finch Elementary School
Frank Lebby Stanton Elementary School
Fred A. Toomer Elementary School
Flat Rock Elementary School
Garden Hills Elementary School
Gideons Elementary School
Grove Park Intermediate Elementary School
Harper-Archer Elementary School
Heritage Academy
Hope-Hill Elementary School
Humphries Elementary School
Hutchinson Elementary School
Jackson Elementary School
Kimberly Elementary School
M. Agnes Jones Elementary School
Mary Lin Elementary School
Miles Elementary School
Morningside Elementary School
Oglethorpe Elementary School
Parkside Elementary School
Perkerson Elementary School
Peyton Forest Elementary School
Pine Ridge Elementary School
Rivers Elementary School
Sarah Smith Elementary School
Scott Elementary School
Slater Elementary School
Springdale Park Elementary School
Sycamore Elementary School
Thomasville Heights Elementary School
Towns Elementary School
Bazoline E. Usher Collier Heights Elementary School
Venetian Hills Elementary School
West Manor Elementary School
Whitefoord Elementary School
Woodson Primary Elementary School
Alonzo A. Crim Open Campus High School
APS/Community Education Partnership (CEP) School
The New School of Atlanta
West End Academy
The B.E.S.T. Academy at Benjamin S. Carson (Business, Engineering, Science, and Technology)
The Coretta Scott King Young Women’s Leadership Academy
Atlanta Classical Academy
Atlanta Neighborhood Charter School
Centennial Academy
Charles R. Drew Charter School
The Kindezi School
KIPP Vision Academy
KIPP Vision Primary
KIPP West Atlanta Young Scholars Academy
The Latin Academy
University Community Academy,
Wesley International Academy
Westside Atlanta Charter School
Ahrens Elementary
Ahuimanu Elementary
Aiea Elementary
Aiea High
Aiea Intermediate
Aikahi Elementary
Aina Haina Elementary
Ala Wai Elementary
Aliamanu Elementary
Aliamanu Middle
Aliiolani Elementary
Baldwin High
Barbers Point Elementary
Campbell High
Castle High
Central Middle
DeSilva Elementary
Dole Middle
Eleele Elementary
Enchanted Lake Elementary
Ewa Beach Elementary
Ewa Elementary
Ewa Makai Middle
Farrington High
Fern Elementary
Haaheo Elementary
Hahaione Elementary
Haiku Elementary
Haleiwa Elementary
Hana High and Elementary
Hanalei Elementary
Hauula Elementary
Hawai`i School for the Deaf and the Blind
Heeia Elementary
Helemano Elementary
Hickam Elementary
Highlands Intermediate
Hilo High
Hilo Intermediate
Hilo Union Elementary
Hokulani Elementary
Holomua Elementary
Holualoa Elementary
Honaunau Elementary
Honokaa Elementary
Honokaa High and Intermediate
Honowai Elementary
Hookele Elementary
Hookena Elementary
Iao Intermediate
Iliahi Elementary
Ilima Intermediate
Inouye Elementary
Iroquois Point Elementary
Jarrett Middle
Jefferson Elementary
Kaaawa Elementary
Kaahumanu Elementary
Kaala Elementary
Kaelepulu Elementary
Kaewai Elementary
Kahakai Elementary
Kahala Elementary
Kahaluu Elementary
Kahuku Elementary
Kahuku High and Intermediate
Kahului Elementary
Kailua Elementary
Kailua High
Kailua Intermediate
Kaimiloa Elementary
Kaimuki High
Kaimuki Middle
Kainalu Elementary
Kaiser High
Kaiulani Elementary
Kalaheo Elementary
Kalaheo High
Kalakaua Middle
Kalama Intermediate
Kalani High
Kalanianaole Elementary and Intermediate
Kaleiopuu Elementary
Kalihi Elementary
Kalihi Kai Elementary
Kalihi Uka Elementary
Kalihi Waena Elementary
Kamakahelei Middle
Kamalii Elementary
Kamehameha III Elementary
Kamiloiki Elementary
Kaneohe Elementary
Kanoelani Elementary
Kapaa Elementary
Kapaa High
Kapaa Middle
Kapalama Elementary
Kapiolani Elementary
Kapolei Elementary
Kapolei High
Kapolei Middle
Kapunahala Elementary
Kau High
Pahala Elementary
Kauai High
Kauluwela Elementary
Kaumana Elementary
Kaumualii Elementary
Kaunakakai Elementary
Kawananakoa Middle
Ke Kula O Ehunuikaimalino Keaau Elementary
Keaau High
Keaau Middle
Kealakehe Elementary
Kealakehe High
Kealakehe Intermediate
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Ecole Bilingue de la Nouvelle-Orleans: Scholarship Program
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Noble Minds Institute for Whole Child Learning
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Success Prep/Thurgood Marshall
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Academy of the Sacred Heart: Little Hearts
Akili Academy of New Orleans
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Audubon Charter School: Gentilly
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Audubon Charter School: Uptown French
Audubon Charter School: Uptown French Tuition-Based PK Program
Audubon Charter School: Uptown Montessori
Audubon Charter School: Uptown Montessori Tuition-Based PK Program
Audubon Primary Academy
Auntie B Preschool and Daycare Center (CCAP)
Because Wee Care Learning Academy (CCAP)
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Benjamin Franklin Elementary Mathematics and Science School: Gifted & Talented
Bricolage Academy
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Carrollton-Dunbar Head Start (Head Start)
Castle Kids (CCAP)
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Coloring House Christian Academy (CCAP)
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Creative Kidz East
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McKinley Preparatory High School
New Mission High School
Newcomers Academy
Snowden International School at Copley
Urban Science Academy
West Roxbury Academy
Carter Development Center
Dr. William W. Henderson K-12 Inclusion School
John D. O’Bryant School of Mathematics & Science
Boston Latin School
Boston Latin Academy
Abbottston Elementary School
Alexander Hamilton Elementary School
Arundel Elementary School
Belmont Elementary School
Brehms Lane Public Charter School
Callaway Elementary School
Cecil Elementary School
Charles Carroll Barrister Elementary School
Creative City Public Charter School
Dallas F. Nicholas, Sr., Elementary School
Dorothy I. Height Elementary School
Dr. Bernard Harris, Sr., Elementary School
Edgecombe Circle Elementary School
Edgewood Elementary School
Eutaw-Marshburn Elementary School
Federal Hill Preparatory Academy
Frederick Elementary School
Furley Elementary School
Furman Templeton Preparatory Academy
Gardenville Elementary School
George Washington Elementary School
Gilmor Elementary School
Govans Elementary School
Green School of Baltimore
The Gwynns Falls Elementary
School Harford Heights Elementary School
Hilton Elementary School
Historic Samuel Coleridge-Taylor Elementary School,
The James Mosher Elementary School
Johnston Square Elementary School
Liberty Elementary School
Lockerman Bundy Elementary School
Mary Ann Winterling Elementary School at Bentalou
Mary E. Rodman Elementary School
Matthew A. Henson Elementary School
Medfield Heights Elementary School
Moravia Park Elementary School
Northwood Appold Community Academy
Northwood Elementary School
Robert W. Coleman Elementary School
Roots and Branches School
Sarah M. Roach Elementary School
Sharp-Leadenhall Elementary School
Sinclair Lane Elementary School
Steuart Hill Academic
William Paca Elementary School
Wolfe Street Academy
Yorkwood Elementary School
Arlington Elementary/Middle School
Armistead Gardens Elementary/Middle School
Baltimore Collegiate School for Boys
Baltimore International Academy
Baltimore Montessori Public Charter School
Barclay Elementary/Middle School
Bay-Brook Elementary/Middle School
Beechfield Elementary/Middle School
Calverton Elementary/Middle School
Calvin M. Rodwell Elementary/Middle School
Cherry Hill Elementary/Middle School
City Neighbors Charter School
City Neighbors Hamilton City Springs Elementary/Middle School
Collington Square Elementary/Middle School
Commodore John Rodgers Elementary/Middle School
Cross Country Elementary/Middle School
Curtis Bay Elementary/Middle School
Dickey Hill Elementary/Middle School
Dr. Martin Luther King, Jr., Elementary/Middle School
Dr. Nathan A. Pitts-Ashburton Elementary/Middle School
Elementary/Middle Alternative Program
Elmer A. Henderson
Fallstaff Elementary/Middle School
Fort Worthington Elementary/Middle School
Francis Scott Key Elementary/Middle School
Franklin Square Elementary/Middle School
Garrett Heights Elementary/Middle School
Glenmount Elementary/Middle School
Graceland Park/O’Donnell Heights Elementary/Middle School
Guilford Elementary/Middle School
Hamilton Elementary/Middle School
Hampden Elementary/Middle School
Hampstead Hill Academy
Harlem Park Elementary/Middle School
Hazelwood Elementary/Middle School
Highlandtown Elementary/Middle School
Highlandtown Elementary/Middle School
Holabird Elementary/Middle School
James McHenry Elementary/Middle School
John Ruhrah Elementary/Middle School
KIPP Harmony Academy
Lakeland Elementary/Middle School
Leith Walk Elementary/Middle School
Lillie May Carroll Jackson School
Lois T. Murray Elementary/Middle School
Maree G. Farring Elementary/Middle School
Margaret Brent Elementary/Middle School
Midtown Academy Monarch Academy
Public Charter School
Montebello Elementary/Middle School
Morrell Park Elementary/Middle School
Mount Royal Elementary/Middle School
New Song Academy
North Bend Elementary/Middle School
Patterson Park Public Charter School
Pimlico Elementary/Middle School
Roland Park Elementary/Middle School
Rosemont Elementary/Middle School
Southwest Baltimore Charter School
Tench Tilghman Elementary/Middle School
The Mount Washington School
Thomas Jefferson Elementary/Middle School
Thomas Johnson Elementary/Middle School
Tunbridge Public Charter School
Violetville Elementary/Middle School
Walter P. Carter Elementary/Middle School
Elementary/Middle School
Westport Academy
Wildwood Elementary/Middle School
William Pinderhughes Elementary/Middle School
Windsor Hills Elementary/Middle School
Woodhome Elementary/Middle School
Afya Public Charter School
Angela Y. Davis Leadership Academy
Banneker Blake Academy of Arts and Sciences
Booker T. Washington Middle School Crossroads School,
The Stadium School
Vanguard Collegiate Middle School
Academy for College and Career Exploration
Baltimore Design School
Baltimore Leadership School for Young Women
Bluford Drew Jemison STEM Academy
West Claremont School,
Baltimore ConneXions: A Community Based Arts School
Eager Street Academy
Excel Academy at Francis M. Wood High School
Green Street Academy
Joseph C. Briscoe Academy
NACA Freedom and Democracy Academy II
National Academy Foundation
School Achievement Academy/Harbor City High School
Augusta Fells Savage Institute of Visual Arts
Baltimore City College
Baltimore Polytechnic Institute
Baltimore School for the Arts
Bard High School
Benjamin Franklin High School
Career Academy
Carver Vocational Technical High School City
Neighbors High School
Coppin Academy
Digital Harbor High School
Edmondson-Westside High School
Forest Park High School
Frederick Douglass High School
Independence School Local I High School
Mergenthaler Vocational-Technical High School
New Era Academy
P-TECH at Carver Vocational-Technical High
P-TECH at New Era Academy
P-TECH at Paul Laurence Dunbar High
Patterson High School
Paul Laurence Dunbar High School
The Reach! Partnership School
Reginald F. Lewis High School Renaissance Academy
Success Academy
Vivien T. Thomas Medical Arts Academy
Western High School
Youth Opportunity Academy
Lakewood Elementary School
William S. Baer School
Academy of the Americas
Detroit International Academy for Young Women
Boykin Continuing Education Center
Douglass Academy for Young Men
Central High School
Frank Cody High School
Denby Technical & Preparatory High School
East English Village Preparatory Academy
Ford High School
Dr. Martin Luther King, Jr. High School
Mumford High School
Northwestern High School
Pershing High School
Southeastern High School
Western International High School
Barsamian Preparatory Center
Cass Technical High School
Communication & Media Arts High School
Crosman Alternative High School
Davis Aerospace High School
Detroit City High School
Detroit High School for Technology
Detroit School of Arts
Millennium School
Osborn High School
Renaissance High School
Trombly Alternative High School
West Side Academy Alternative Education
Davison Elementary-Middle School
Ann Arbor Trail Magnet School
Bates Academy
Mary McLeod Bethune Elementary/Middle School
Blackwell Institute
Bow Elementary/Middle School
Mary McLeod Bethune Elementary/Middle School
Beulah Brewer Academy
Ronald Brown Academy
Ralph J. Bunche Preparatory Academy
Burns Elementary School
Burton International School
Butzel Elementary/Middle School
Cartsens Elementary/Middle School
Carver Elementary School
Clark J.E. Preparatory Academy
Davison Elementary School
Dixon Educational Learning Academy
Earheart Elementary/Middle School
Fisher Magnet Academy
Fisher Magnet Lower Academy
Fisher Magnet Upper Academy
Fitzgerald Elementary School
Garvey Academy
Golightly Education Center Gompers Elementary/Middle School
Greenfield Union Elementary School
Henderson Academy
A.L. Holmes Academy of Blended Learning
Hutchinson Elementary/Middle School
John R. King Academic and Performing Arts Academy
Law Elementary School
Mackenzie Elementary/Middle School
Thurgood Marshall Elementary School
Mark Twain School for Scholars
Marquette Elementary/Middle School
Neinas Dual Language Learning Academy
Noble Elementary School
Nolan Elementary/Middle School
Palmer Park Preparatory Academy
Priest Elementary/Middle School
Pulaski Elementary/Middle School
Robeson Malcolm X Academy
Sherrill Elementary School
Charles L. Spain Elementary/Middle School
Stewart Elementary School
Westside Multicultural Academy
Academy of The Americas
Brebda Scott Academy
Edward ‘Duke’ Ellington Consevatory of Music & Art at Beckham Academy
Ann Arbor Trail Magnet Middle School
Burns Elementary/Middle School
Dossin Elementary/Middle School
Durfee Elementary/Middle School
Earhart Elementary/Middle School
Lessenger Elementary/Middle School
Frank Murphy Elementary/Middle School
Munger Elementary/Middle School
Nichols Elementary School
Nolan Elementary School
Thirkell Elementary/Middle School
Trix Elementary School
Vetal Elementary School
Edward (Duke) Ellington Conservatory of Music/Art
Moses Field Center
Foreign Language Immersion
Hancock Preparatory Center
Langston Hughes Academy
MacDowell Preparatory Academy
Farwell Middle School
Erma Henderson Upper School
Clippert Multicultural Honors Academy
Ludington Magnet Middle School
Barbour Magnet Middle School
Cerveny Middle School
Columbus Middle School
McNair Middle School
Robinson Middle School
Brenda Scott Middle School
Hally Magnet Middle School
Heilmann Park Middle School
No. 1 John R King
Bagley Elementary School
Ronald Brown Academy
Cooke STEM Academy
Dossin Elementary School
MacDowell Preparatory Academy
Thurgood Marshall Elementary School
Pasteur Elementary School
Schulze Academy for Technology and Arts
Vernor Elementary School
Cooke Elementary School
Pasteur Elementary School
Bennett Elementary School
Carleton Elementary School
Roberto Clemente Learning Academy
Emerson Elementary School
Gompers Elementary School
Maybury Elementary School
Wayne Elementary School
Coleman A. Young Elementary School
Chrysler Elementary School
Gardner Elementary School
Harms Elementary School
Duke Ellington @Beckingham
Armatage Community & Montessori School
Bancroft Community School
Bethune Community School
Bryn Mawr Community School
Burroughs Community School
Cityview Community School
Dowling Urban Environmental Learning Center
Emerson Spanish Immersion Learning Center
Hale Elementary School (K–4)
Hall International Elementary School
Hiawatha Community School
Jenny Lind School
Kenny Community School
Kenwood Community School
Lake Harriet Lower (K–3)
Lake Nokomis Lower (K–3)
Loring School
Lyndale Community School
Northrop Elementary School
Pillsbury School
Pratt Community School
Waite Park Community School
Whittier International Elementary School
Andersen United Community School
Anishinabe Academy
Barton Open School
Bryn Mawr Elementary School
Field Community School (5–8)
Folwell Performing Arts Magnet(PreK-8)
Green Central Park School
Hmong International Academy
Jefferson Community School
Lake Harriet Upper (4–8)
Lake Nokomis Community School
Lucy Craft Laney at Cleveland Park Community School
Marcy Open School
Nellie Stone Johnson Community School
Seward Montessori School
Sheridan Elementary School
Sullivan Communication Center
Windom Spanish Dual Immersion and Open School
Field Middle School
Anthony Middle School
Anwatin Middle School
Franklin Middle School
Justice Page Middle School
Northeast Middle School
Olson Middle School
Sanford Middle School
Edison High School
North Community High School
Patrick Henry High School
Roosevelt High School
South High School
Southwest High School
Washburn High School
Wellstone International High School
Central High School
East High School
Northeast High School
Southeast High School
Lincoln College Preparatory Academy
Paseo Academy
African-Centered College Preparatory Academy
Manual Career Tech
Central Middle School
Northeast Middle School
Banneker
Garcia
Garfield
Gladstone
Hartman
Hale Cook
James
Martin Luther King Elementary School
Longfellow
Melcher
Wendell Phillips K-8
Pitcher
J. A. Rogers
Success Academy at Knotts
Trailwoods
Troost
Wheatley
Whittier
Carver Dual Language
Border Star Montessori
Faxon Montessori
Foreign Language Academy
Holliday Montessori
Woodland Early Learning Center
Richardson Early Learning Center
MS-Urban
Jackson Public School District
Baker Elementary School
Barack H. Obama Magnet School
Barr Elementary School
Bates Elementary School
Boyd Elementary School
Casey Elementary School
Clausell Elementary School
Dawson Elementary School
Galloway Elementary School
Green Elementary School
Isable Elementary School
John Hopkins Elementary School
Johnson Elementary School
Key Elementary School
Lake Elementary School
Lee Elementary School
Lester Elementary School
Marshall Elementary School
McLeod Elementary School
McWillie Elementary School
North Jackson Elementary School
Oak Forest Elementary School
Pecan Park Elementary School
Power APAC Elementary School
Raines Elementary School
Smith Elementary School
Spann Elementary School
Sykes Elementary School
Timberlawn Elementary School
Van Winkle Elementary School
Walton Elementary School
Watkins Elementary School
Wilkins Elementary School
Bailey APAC Middle School
Blackburn Laboratory Middle School
Brinkley Middle School
Cardozo Middle School
Chastain Middle School
Hardy Academy of Career Exploration
Kirksey Middle School
Northwest Jackson Middle School
Peeples Middle School
Powell Academy of Military Science
Siwell Academy of Leadership
Whitten Preparatory Middle School
Callaway High School
Forest Hill High School
Jim Hill High School
Lanier High School
Murrah High School
Provine High School
Wingfield High School
Capital City Alternative School
Career Development Center
Early College High School
Re-Engaging in Education for All to Progress (REAP)
Alkali Creek
Beartooth
Bench
Bitterroot
Broadwater
Eagle Cliffs
Highland
McKinley
Miles Avenue
Rose Park
Sandstone
Arrowhead
Big Sky
Boulder
Burlington
Central Heights
Meadowlark
Newman
Orchard
Poly Drive
Ponderosa
Washington
Castle Rock
Lewis & Clark
Medicine Crow
Ben Steele
Riverside
Will James
Senior
Skyview
West
Career Center
Albemarle Road Elementary
Allenbrook Elementary School
Ashley Park Pre K-8 School
Bain Elementary School
Ballantyne Elementary School
Barnette Elementary School
Barringer Academic Center
Berewick Elementary School
Berryhill School
Beverly Woods Elementary School
Billingsville Elementary School
Blythe Elementary School
Briarwood Academy
Bruns Avenue Elementary
Chantilly Montessori School
Charlotte East Language Academy
Clear Creek Elementary School
Collinswood Language Academy
Cornelius Elementary School
Cotswold Elementary School
Croft Community School
Crown Point Elementary School
David Cox Road Elementary School
Davidson K-8 Devonshire Elementary School
Dilworth Elementary School: Latta
Dilworth Elementary School: Sedgefield
Dorothy J. Vaughan Academy of Technology
Druid Hills Academy
E. E. Waddell Language Academy
Eastover Elementary School
Elizabeth Lane Elementary School
Elizabeth Traditional Elementary School
Elon Park Elementary School
Endhaven Elementary School
First Ward Creative Arts Academy
Governors’ Village STEM Academy (Lower)
Governors’ Village STEM Academy (Upper)
Grand Oak Elementary School
Greenway Park Elementary School
Hawk Ridge Elementary School
Hickory Grove Elementary School
Hidden Valley Elementary School
Highland Creek Elementary School
Highland Mill Montessori Elementary School
Highland Renaissance Academy
Hornets Nest Elementary School
Huntersville Elementary School
Huntingtowne Farms Elementary School
Idlewild Elementary School
Irwin Academic Center
J.H. Gunn Elementary School
J.V. Washam Elementary School
Joseph W. Grier Academy
Lake Wylie Elementary School
Lansdowne Elementary School
Lawrence Orr Elementary School
Lebanon Road Elementary School
Long Creek Elementary School
Mallard Creek Elementary School
Marie G. Davis Matthews Elementary School
McAlpine Elementary School
McKee Road Elementary School
Merry Oaks International Academy
Montclaire Elementary
Mountain Island Lake Academy
Myers Park Traditional Elementary School
Nations Ford Elementary School
Newell Elementary School
Oakdale Elementary School
Oakhurst STEAM Academy
Oaklawn Language Academy
Olde Providence Elementary School
Palisades Park Elementary
Park Road Montessori School
Parkside Elementary School
Paw Creek Elementary School
Pineville Elementary School
Pinewood Elementary School
Piney Grove Elementary School
Polo Ridge Elementary School
Providence Spring Elementary School
Rama Road Elementary School
Reedy Creek Elementary School
Reid Park Academy
Renaissance West STEAM Academy
River Gate Elementary School
River Oaks Academy
Selwyn Elementary School
Shamrock Gardens Elementary School
Sharon Elementary School
Smithfield Elementary School
Starmount Academy of Excellence
Statesville Road Elementary School
Steele Creek Elementary School
Sterling Elementary School
Stoney Creek Elementary School
Thomasboro Academy
Torrence Creek Elementary School
Trillium Springs Montessori School
Tuckaseegee Elementary School
University Meadows Elementary School
University Park Creative Arts School
Villa Heights Elementary
Walter G. Byers School
Westerly Hills Academy
Whitewater Academy
Winding Springs Elementary School
Windsor Park Elementary School
Winget Park Elementary School
Winterfield Elementary School
Albemarle Road Middle School
Alexander Graham Middle School
Ashley Park Pre K-8 School
Bailey Middle School
Berryhill School
Carmel Middle School
Chantilly Montessori School
Cochrane Collegiate Academy
Collinswood Language Academy
Community House Middle School
Coulwood STEM Academy
Crestdale Middle School
Davidson K-8
Druid Hills Academy
E. E. Waddell Language Academy
Eastway Middle School
Francis Bradley Middle School
Governors’ Village STEM Academy (Upper)
J.M. Alexander Middle School
James Martin Middle School
Jay M. Robinson Middle School
John Taylor Williams Secondary
Montessori Kennedy Middle School
Marie G. Davis
Martin Luther King, Jr. Middle School
McClintock Middle School
Mint Hill Middle School
Mountain Island Lake Academy
Northeast Middle School
Northridge Middle School
Northwest School of the Arts
Oaklawn Language Academy
Piedmont Middle School
Quail Hollow Middle School
Randolph Middle School
Ranson Middle School
Ridge Road Middle School
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South Charlotte Middle School
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Thomasboro Academy
Walter G. Byers School
WhiteWater Middle School
Wilson STEM Academy
Ardrey Kell High School
Butler High School
Cato Middle
College High School
Charlotte Engineering Early College
Charlotte Teacher Early College
Charlotte-Mecklenburg Virtual High School
East Mecklenburg High School
Garinger High School
Harding University High School
Harper Middle College High School
Hawthorne Academy of Health Sciences
Hopewell High School
iMeck at Cochrane
Independence High School
John Taylor Williams Secondary
Montessori Levine Middle
College High
Mallard Creek High School
Merancas Middle
College @ CPCC
Military and Global Leadership Academy
Myers Park High School
North Mecklenburg High School
Northwest School of the Arts
Olympic High School
Performance Learning Center
Phillip O. Berry Academy of Technology
Providence High School
Rocky River High School
South Mecklenburg High School
West Charlotte High School
West Mecklenburg High School
William Amos Hough High School
Zebulon B. Vance High School
Fargo Davies High School
Fargo North High School
Fargo South High School
Woodrow Wilson High School
Ben Franklin Middle School
Carl Ben Eielson Middle School
Discovery Middle School
Bennett Elementary School
Centennial Elementary School
Clara Barton Elementary School
Eagles Elementary school
Ed Clapp Elementary school
Hawthorne Elementary School
Horace Mann Elementary School
Jefferson Elementary School
Kennedy Elementary School
Lewis and Clark Elementary School
Lincoln Elementary School
Longfellow Elementary School
Madison Elementary School
McKinley Elementary School
Roosevelt Elementary School
Washington Elementary School
Adams Elementary
Ashland Park/Robbins Elementary School
Bancroft Elementary School
Beals Elementary School
Belle Ryan Elementary School
Belvedere Elementary School
Thomas Elementary
Benson West Elementary School
Boyd Elementary School
Castelar Elementary School
Catlin Arts Magnet Center
Central Park Elementary School
Chandler View Elementary School
Columbian Elementary School
Conestoga Magnet Center
Crestridge Magnet Center
Dodge Elementary School
Druid Hill Elementary School
Dundee Elementary School
Edison Elementary School
Field Club Elementary School
Florence Elementary School
Fontenelle Elementary School
Franklin Elementary School
Fullerton Magnet Center
Gateway Elementary
Gifford Park PK-6
Gilder Elementary School
Gomez-Heritage Elementary School
Harrison Elementary School
Hartman Elementary School
Highland Elementary School
Indian Hill Elementary School
Jackson Elementary School
Jefferson Elementary School
Joslyn Elementary School
Kellom Elementary School
Kennedy Elementary School
King Elementary School
King Science and Technology Magnet Center
Liberty Elementary School
Lord Elementary School
Lothrop Magnet Center
Marrs Magnet School
Masters Elementary School
Miller Park Elementary School
Minne Lusa Elementary School
Mount View Elementary School
Oak Valley Elementary School
Omaha Alice Buffett Middle School
Pawnee Elementary School
Picotte Elementary School
Pinewood Elementary School
Ponca Elementary School
Prairie Wind Elementary School
Rose Hill Elementary School
Saddlebrook Elementary
Saratoga Elementary School
Sherman Elementary School
Skinner Magnet Center
Spring Lake Magnet Center
Springville Elementary School
Standing Bear Elementary School
Sunny Slope Elementary School
Wakonda Elementary School
Walnut Hill Elementary School
Washington Elementary School
Western Hills Magnet Center
Omaha Benson High School Magnet
Bryan Sr. High School
Burke High School
Central High School
North High Magnet
Northwest High Magnet
South High Magnet
Career Center 10-12
Westside High School
Blackburn B
Blackburn High
Parrish
Wilson
Yates
Abraham Lincoln Elementary School
Brown Park Elementary School
Cass School
Central Elementary School
Clifton Hill
Comenius
Dodge School
Dupont School
East School
Fairfax School
Farnam School
Forest School
Gibson School
Hartman’s Addition
Izard School
Jackson Street School
Lake School
Jungmann School
Leavenworth School
Lincoln School
Long School
Mason School
Monmouth Park School
Omaha High School
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Pacific School
Park School
Pershing School
Pleasant School
Robbins School
Rosewater School
Saunders School
El Museo Latino Technical High School
Train School
Vinton School
Webster School
Windsor School
Abington Avenue School
American History High School
Ann Street School
Ann Street Annex
Arts High School
Avon Avenue Elementary School
Bard Early College High School
Barringer High School
Belmont Runyon School
Benjamin Franklin School
Branch Brook School
Bruce Street School
Camden Street School 281
Central High School
Chancellor Avenue School
Cleveland Elementary School
Dr. E. Alma Flagg School
Dr. Marion A. Bolden Student Center
Dr. William H. Horton School
Eagle Academy for Young Men Early Childhood Center
Early Childhood Center – North
Early Childhood Center – South
Early Childhood Center – West
East Side High School
East Ward Elementary School
Elliott Street School
First Avenue School
Fourteenth Avenue School
George Washington Carver School
Harriet Tubman School
Hawkins Street School
Hawthorne Avenue School
Home Instruction
Ivy Hill Elementary School
John F. Kennedy School
Lafayette Street School
Lafayette Street School – Annex
Lafayette Street School – Annex at St. James
Lincoln School
Louise A. Spencer School
Luis Muñoz Marin School
Malcolm X Shabazz High School
McKinley Elementary School
Mount Vernon School
NJ Regional Day
Newark Evening High School
Newark Vocational High School
Oliver Street School
Park Elementary School
Peshine Avenue School
Quitman Street School
Rafael Hernandez Elementary School
Ridge Street School
Roberto Clemente Elementary School
Salomé Ureña Elementary School
Science Park High School
South 17th Street School
South Street School
Speedway School
Sussex Avenue School
Technology High School
Thirteenth Avenue School
University High School
Uplift Academy
Weequahic High School
West Side High School
Wilson Avenue School
7 Bar
A. Montoya
Adobe Acres
Alameda
Alamosa
Alvarado
Apache
Armijo
Arroyo Del Oso
Atrisco Elementary
Bandelier
Barcelona Elementary
Bel-Air
Bellehaven
Carlos Rey
Chamiza
Chaparral
Chelwood
Cochiti
Collet Park
Comanche
Coronado Dual Language Magnet
Corrales
Dennis Chavez
Dolores Gonzales
Double Eagle
Duranes
E. G. Ross
East San Jose
Edward Gonzales
Emerson
Eugene Field
Georgia O’Keeffe
Governor Bent
Griegos
Hawthorne
Helen Cordero
Hodgin
Hubert Humphrey
Inez Science and Technology Magnet
Janet Kahn School of Integrated Arts Magnet
John Baker
Kirtland
Kit Carson
La Luz
La Mesa
Lavaland
Lew Wallace
Longfellow
Dual Language Magnet
Los Padillas
Los Ranchos
Lowell
M. A. Binford
MacArthur
Manzano Mesa
Marie M. Hughes
Mark Twain
Matheson Park
McCollum
Mission Avenue STEM Magnet
Mitchell
Monte Vista
Montezuma
Mountain View
Navajo North Star
Onate
Osuna
Painted Sky
Pajarito
Petroglyph
Reginald Chavez
Rudolfo Anaya
S. R. Marmon
S. Y. Jackson
San Antonito STEM Magnet
Sandia Base
Sierra Vista
Sombra Del Monte
Sunset View
Tierra Antigua
Tomasita
Valle Vista
Ventana Ranch
Wherry
Whittier
Zia
Zuni Technology and Communication Magnet
Aztec Complex
Cleveland
Desert Ridge
Eisenhower
Ernie Pyle
Garfield STEM Magnet
Grant
Harrison
Hayes Dual Language Magnet
Hoover
Jackson
James Monroe
Jefferson
Jimmy Carter
John Adams
Juvenile Detention Center Educational Unit
Kennedy
L.B. Johnson
Madison
McKinley
Polk
Roosevelt
Taft
Taylor
Tony Hillerman
Truman
Van Buren
Vision Quest Alternative
Washington
Wilson
Coyote Willow Family Magnet School
Desert Willow Family Magnet School
George I. Sánchez Collaborative Community School
Tres Volcanes Community Collaborative
Albuquerque
Atrisco Heritage Academy
Career Enrichment Center & Early College Academy Magnet
Cibola College and Career Magnet
Del Norte
eCADEMY Magnet
Eldorado
Freedom Magnet
Highland
La Cueva
Manzano
New Futures
Nex+Gen Academy Magnet
Rio Grande
Sandia School on Wheels Magnet
Transition Services
Valley
Volcano Vista
West Mesa
21st Century Public Academy
ABQ Charter Academy
ACE Leadership High School
Albuquerque Talent Development Academy
Alice King Community
Christine Duncan Heritage Academy
Cien Aguas International
Coral Community Charter School
Corrales International School
Cottonwood Classical
Digital Arts and Technology Academy
East Mountain High School
El Camino Real Academy
Gilbert L. Sena Charter High School
Gordon Bernell
Health Leadership High School
International School at Mesa del Sol
La Academia de Esperanza Charter School
Los Puentes Charter School
Mark Armijo Academy
Montessori of the Rio Grande
Mountain Mahogany
Native American Community Academy
New America School – New Mexico
New Mexico International
Public Academy for Performing Arts
Robert F Kennedy Siembra Leadership High School
South Valley Academy
Technology Leadership High School
William W. & Josephine Dorn Community
NV-Urban
Sandra B. Abston Elementary School
Kirk L. Adams Elementary School
O. K. Adcock Elementary School
Tony Alamo Elementary School
Dean Lamar Allen Elementary School
Lee Antonello Elementary School
Sister Robert Joseph Bailey Elementary School
Shirley A. Barber Elementary School
Selma F. Bartlett Elementary School
John C. Bass Elementary School
Kathy L. Batterman Elementary School
John R. Beatty Elementary School
Will Beckley Elementary School
Rex Bell Elementary School
Patricia A. Bendorf Elementary School
William G. Bennett Elementary School
Shelley Berkley Elementary School
James H. Bilbray Elementary School
Blue Diamond Elementary School
John W. Bonner Elementary School
Kermit R. Booker Sr. Interactive Elementary School
Bowler, Grant Elementary School
Bowler, Joseph L. Elementary School
Bozarth, Henry and Evelyn Elementary School
Walter Bracken Elementary School
Eileen B. Brookman Elementary School
Lucille Bruner Elementary School
Bryan, Richard Elementary School
Bryan, Roger Elementary School
Berkley L. Bunker Elementary School
Marion E. Cahlan Elementary School
Arturo Cambeiro Elementary School
Kay Carl Elementary School
Kit Carson Elementary School
Roberta C. Cartwright Elementary School
M. J. Christensen Elementary School
Eileen Conners Elementary School
Manuel J. Cortez Elementary School
Cox, Clyde Elementary School
Cox, David Elementary School
Steve and Linda Cozine Elementary School
Lois Craig Elementary School
Crestwood Elementary School
Paul E. Culley Elementary School
Cynthia Cunningham Elementary School
Jack Dailey Elementary School
Marshall Darnell Elementary School
Laura Dearing Elementary School
C. H. Decker Elementary School
Herbert A. Derfelt Elementary School
Ruthe Deskin Elementary School
Ollie Detwiler Elementary School
Ruben P. Diaz Elementary School
Dusty “D.L.” Dickens Elementary School
P.A. Diskin Elementary School Kenneth Divich Elementary School
Harvey N. Dondero Elementary School
John A. Dooley Elementary School
Ruby Duncan Elementary School
Ira J. Earl Elementary School
Marion B. Earl Elementary School
Elbert Edwards Elementary School
Dorothy Eisenberg Elementary School
Raul P. Elizondo Elementary School
Robert and Sandy Ellis Elementary School
William E. Ferron Elementary School
Mark L. Fine Elementary School
H.P. Fitzgerald Elementary School
Wing & Lilly Fong Elementary School
Robert L. Forbuss Elementary School
Doris French Elementary School
Charles & Phyllis Frias Elementary School
Fay Galloway Elementary School
Edith Garehime Elementary School
Roger D. Gehring Academy of Science and Technology
James Gibson Elementary School
C.V.T. Gilbert Magnet School of Communication and Creative Arts
Linda Rankin Givens Elementary School
Daniel Goldfarb Elementary School
Goodsprings Elementary School
Judy & John L. Goolsby Elementary School
Theron and Naomi Goynes Elementary School
Oran K. Gragson Elementary School
R. Guild Gray Elementary School
E.W. Griffith Elementary School
Addeliar D. Guy Elementary School
Doris Hancock Elementary School
Harley A. Harmon Elementary School
George E. Harris Elementary School
Hayden, Don E. Elementary School
Keith C. And Karen W. Hayes Elementary School
Lomie G. Heard Elementary School
Howard Heckethorn Elementary School
Helen Herr Elementary School
Fay Herron Elementary School
Halle Hewetson Elementary School
Liliam Lujan Hickey Elementary School
Charlotte Hill Elementary School
Edna F. Hinman Elementary School
Mabel Hoggard Math and Science Magnet School
Howard Hollingsworth Elementary School
John R. Hummel Elementary School
Indian Springs Elementary School
Mervin Iverson Elementary School
Walter Jacobson Elementary School
Jay W. Jeffers Elementary School
Earl N. Jenkins Elementary School
Jan Jones Blackhurst Elementary School
Helen M. Jydstrup Elementary School
Marc A. Kahre Elementary School
Edythe and Lloyd Katz Elementary School
Charlotte and Jerry Keller Elementary School
Matt Kelly Elementary School
Lorna Kesterson Elementary School
Frank Kim Elementary School
Martha P. King Elementary School
Robert E. Lake Elementary School
Frank Lamping Elementary School
Lincoln Elementary School
Walter V. Long Elementary School
Mary & Zel Lowman Elementary School
William R. Lummis Elementary School
Lundy Elementary School
Robert Lunt Elementary School
Ann Lynch Elementary School
Nate Mack Elementary School
Jo Mackey Academy of Leadership and Global Communications
J. E. Manch Elementary School
Reynaldo Martinez Elementary School
Dr. Beverly S. Mathis Elementary School
Ernest J. May Elementary School
Quannah McCall Elementary School
Gordon M. McCaw Elementary School
Estes McDoniel Elementary School
James B. McMillan Elementary School
J. T. McWilliams Elementary School
John F. Mendoza Elementary School
Sandy Searles Miller Academy for International Studies
Andrew Mitchell Elementary School
William Moore Elementary School
Sue H. Morrow Elementary School
Mountain View Elementary School
Joseph Neal Elementary School
Ulis Newton Elementary School
Thomas O’Roarke Elementary School
D’Vorre and Hal Ober Elementary School
Dennis Ortwein Elementary School
Paradise Elementary School
John S. Park Elementary School
Claude & Stella Parson Elementary School
Dr. Claude G. Perkins Elementary School
Ute V. Perkins Elementary School
Dean Petersen Elementary School
Clarence Piggott Elementary School
Vail Pittman Elementary School
Richard Priest Elementary School
Red Rock Elementary School
Doris Reed Elementary School
Carolyn S. Reedom Elementary School
Harry Reid Elementary School
Aldeane Comito Ries Elementary School
Betsy A. Rhodes Elementary School
Lucille S. Rogers Elementary School
C. C. Ronnow Elementary School
Bertha Ronzone Elementary School
Dr. C. Owen Roundy Elementary School
Lewis E. Rowe Elementary School
Richard J. Rundle Elementary School
Sandy Valley Elementary School
William & Mary Scherkenbach Elementary School
Steven G. Schorr Elementary School
Jesse D. Scott Elementary School
C.T. Sewell Elementary School
Eva G. Simmons Elementary School
James E. & Alice Rae Smalley Elementary School
Hal Smith Elementary School
Helen Smith Elementary School
Don and Dee Snyder Elementary School
William E. Snyder Elementary School
C. P. Squires Elementary School
Stanford Elementary School
Ethel Winterheimer Staton Elementary School
Judith D. Steele Elementary School
Josh Stevens Elementary School
Evelyn Stuckey Elementary School
Sunrise Acres Elementary School
Wayne N. Tanaka Elementary School
Sheila R. Tarr Elementary School
John Tartan Elementary School
Myrtle Tate Elementary School
Glen C. Taylor Elementary School
Robert L. Taylor Elementary School
Joseph E. Thiriot Elementary School
Ruby S. Thomas Elementary School
Sandra L. Thompson Elementary School
Jim Thorpe Elementary School
R.E. Tobler Elementary School
Bill Y. Tomiyasu Elementary School
Harriet Treem Elementary School
Vincent L. Triggs Elementary School
Twin Lakes Elementary School
Neil C. Twitchell Elementary School
J.M. Ullom Elementary School
John C. Vanderburg Elementary School
Billy and Rosemary Vassiliadis Elementary School
Vegas Verdes Elementary School
Virgin Valley Elementary School
J. Marlan Walker International Elementary School
Gene Ward Elementary School
Kitty McDonough Ward Elementary School
Shirley and Bill Wallin Elementary School
Rose Warren Elementary School
Howard A. Wasden Elementary School
Fredric W. Watson Elementary School
Cyril Wengert Elementary School
Whitney Elementary School
Louis Wiener Jr. Elementary School
Elizabeth Wilheim Elementary School
Tom Williams Elementary School
Wendell P. Williams Elementary School
Eva Wolfe Elementary School
Elise L. Wolff Elementary School
Gwendolyn Woolley Elementary School
William V. Wright Elementary School
Elaine Wynn Elementary School
Bob Miller Middle School
Dr. William (Bob) H. Bailey Middle School
Ernest Becker Sr. Middle School
Jim Bridger Middle School
Academy of Mathematics, Science and Technology
J. Harold Brinley Middle School
B. Mahlon Brown Junior High School
Lyal Burkholder Middle School
Ralph Cadwallader Middle School
Lawrence & Heidi Canarelli Middle School
Helen C. Cannon Junior High School
James E. Cashman Middle School
Francis H. Cortney Junior High School
Brian & Teri Cram Middle School
Edmundo “Eddie” Escobedo, Sr. Middle School
Wilbur & Theresa Faiss Middle School
9 Victoria Fertitta Middle School
Clifford O. Findlay Middle School
John C. Fremont Middle School
Elton M. Garrett Middle School
Frank F. Garside Junior High School
Robert O. Gibson Middle School
Barbara & Hank Greenspun Junior High School ‘
Kenny C. Guinn Middle School
Kathleen & Tim Harney Middle School
Charles Arthur Hughes Middle School
Hyde Park Middle School
Indian Springs Middle School
Walter Johnson Middle School
Carroll M. Johnston Middle School
Duane D. Keller Middle School
K. O. Kundson Middle School Academy of Creative Arts, Language, and Technology
Clifford J. Lawrence Junior High School
Justice Myron E. Leavitt Middle School
Lied STEM Academy W. Mack Lyon Middle School
Jerome D. Mack Middle School
Jack & Terry Mannion Middle School
Roy Martin Middle School
Bob Miller Middle School
Irwin & Susan Molasky Junior High School
Mario C. & JoAnne Monaco Middle School
Mike O’Callaghan Middle School
William E. Orr Middle School
Dell H. Robison Middle School
Sig Rogich Middle School
Sandy Valley Middle School
Anthony Saville Middle School
Grant Sawyer Middle School
Jack L. Schofield Middle School
Marvin M. Sedway Middle School
Charles Silvestri Junior High School
J.D. Smith Middle School
Theron Swainston Middle School
Tarkanian Middle School
Ed Von Tobel Middle School
Del Webb Middle School
Thurman White Middle School
C.W. Woodbury Middle School
Advanced Technologies Academy
Arbor View High School
Area Technical Trade Center High School
Basic High School
Bonanza High School
Boulder City High School
Canyon Springs High School
Centennial High School
Chaparral High School
Cheyenne High School
Cimarron-Memorial High School
Community College High School
East Community College High School
South Community College High School
West Coronado High School
Del Sol High School
Desert Oasis High School
Desert Pines High School
Durango High School
East Career and Technical Academy
Ed W. Clark High School
Eldorado High School
Eldorado Preparatory Academy
Foothill High School
Green Valley High School
Indian Springs High School
Las Vegas High School
Las Vegas Academy of International Studies, Performing and Visual Arts
Laughlin High School
Legacy High School
Liberty High School
Moapa Valley High School
Mojave High School
Northwest Career and Technical Academy (NWCTA)
Palo Verde High School
Rancho High School
Shadow Ridge High School
Sierra Vista High School
Silverado High School
Southeast Career Technical Academy
Southwest Career Technical Academy
Spring Valley High School
Sunrise Mountain High School
Valley High School
Veterans Tribute Career Technical Academy
Virgin Valley High School
Nevada Learning Academy
West Career And Technical Academy
Western High School
Biltmore Continuation School
Desert Rose High School
Explore Knowledge Academy
Keystone Academy
Odyssey Charter Schools
The Preparatory Institute, School for Academic Excellence (West Prep School)
Helen J. Stewart School
John F. Miller School
Variety School
Miley Achievement Center
[PS numbers repeat from one borough to the next]
PS 1 PS 2 PS 11 PS 15 PS 18 PS 19 PS 20 PS MS 34 PS 63 PS 64 PS 84 PS 102 PS 108 PS 110 PS 111 PS 112 PS 115 PS 116 PS 125 PS 126 PS 128 PS 129 PS 130 PS 132 PS 134 PS 140 PS 142 PS 145 PS 146 PS 150 PS 152 PS 153 PS 154 PS 155 PS 158 PS 161 PS 163 PS 165 PS 166 PS 171 PS 173 PS 175 PS 178 PS 180 PS 182 PS 183 PS MS 184 PS 185 PS 188 PS 189 PS 191 PS 192 PS 197 PS 198 PS 199 PS 200 PS 206 PS 212 PS 234 PS 241 PS 242 PS 315 PS 361 PS 363 PS 364 PS 2 PS 7 PS 8 PS 9 PS 11 PS 15 PS 21 PS 24 PS 28 PS 32 PS 33 PS 37 PS 46 PS 51 PS 53 PS/IS 54 PS 55 PS 56 PS 58 PS 59 PS 63 PS 64 PS 70 PS 73 PS 81 PS 85 PS 90 PS 91 PS 94 PS 109 PS 110 PS 126 PS 128 PS 132 PS 159 PS 163 PS 170 PS 199X PS 204 PS 205 P/IS 218 PS 236 PS 246 PS 306 PS 307 PS 310 PS 315 PS 396 PS 6 PS 16 PS 19 PS 21 PS 36 PS 41 PS 44 PS 47 PS 48 PS 50 PS 57 PS 61 PS 62 PS 67 PS 68 PS 72 PS 75 PS 76 PS 78 PS 83 PS 87 PS 92 PS 93 PS 96 PS 97 PS 100 PS 102 PS 105 PS 106 PS 107 PS 108 PS 111 PS 112 PS 119 PS 130 PS 134 PS 138 PS 140 PS 146 PS 150 PS 152 PS 153 PS 160 PS 178 PS 182 PS 194 PS 195 PS 196 PS 197 PS 198 PS 211 PS 212 PS 214 PS 304 PS 11 PS 12 PS 13 PS 15 PS 18 PS 20 PS 21 PS 22 PS 24 PS 26 PS 29 PS 30 PS 31 PS 32 PS 33 PS 34 PS 35 PS 36 PS 37 PS 38 PS 40 PS 41 PS 46 PS 48 PS 49 PS 50 PS 54 PS 55 PS 79 PS 80 PS 82 PS/IS 87 PS 88 PS 91 PS 94 PS 95 PS 98 PS 99 PS 101 PS 107 PS/IS 113 PS 115 PS 117 PS 118 PS 120 PS 121 PS 128 PS 129 PS 130 PS 131 PS 132 PS 133 PS 134 PS 135 PS 136 PS 138 PS 139 PS 140 PS 144 PS 147 PS 153 PS 154 PS 159 PS 160 PS 161 PS 162 PS 163 PS 165 PS 169 PS 173 PS 174 PS 175 PS 176 PS 178 PS 181 PS 182 PS 184 PS 186 PS 188 PS 191 PS 193 PS 195 PS 196 PS 200 PS 201 PS 203 PS 205 PS 206 PS/IS 208 PS 209 PS 213 PS 214 PS 220 PS 221 PS 242 PS 244 PS 251 PS/IS 266 PS/IS 270 PS 305 PS 360 PS 2 PS 7 PS 11 PS 12 PS 13 PS 14 PS 16 PS 17 PS 19 PS 28 PS 58 PS 68 PS 69 PS 70 PS 71 PS 76 PS/IS 78 PS 81 PS 84 PS 85 PS 86 PS 88 PS 89 PS 91 PS 92 PS 102 PS 106 PS 111 PS 112 PS 113 PS 116 PS 123 PS 128 PS 143 PS 148 PS 149 PS 150 PS 151 PS 152 PS 153 PS 166 PS 171 PS 199 PS 212 PS 222 PS 229 PS 234 PS 239 PS 7 PS 13 PS 41 PS 42 PS 43 PS 45 PS 47 PS 51 PS 56 PS 60 PS 62 PS 63 PS 64 PS 65 PS 65 PS 66 PS 72 PS 89 PS 90 PS 96 PS 97 PS 100 PS 104 PS 105 PS 106 PS 108 PS 108 PS 114 PS 123 PS 124 PS 146 PS 149 PS 150 PS 155 PS 156 PS 158 PS 159 PS 165 PS 174 PS 183 PS 183 PS 184 PS 188 PS 190 PS 197 PS 202 PS 207 PS 213 PS 214 PS 215 PS 223 PS 224 PS 225 PS 232 PS 253 PS 254 PS 260 PS 273 PS 284 PS 290 PS 298 PS 306 PS 323 PS 327 PS 328 PS 332/PS 401 PS 345 PS 346 PS 6 PS 12 PS 705 PS 52 PS 91 PS 92 PS 114 PS 119 PS 135 PS 136 PS 167 PS 178 PS 191 PS 194 PS 195 PS 197 PS 198 PS 203 PS 206 PS 207 PS 208 PS 217 PS 219 PS 221 PS 222 PS 233 PS 236 PS 241 PS 244 PS 245 PS 249 PS 251 PS 254 PS 255 PS 268 PS 269 PS 272 PS 276 PS 277 PS 289 PS 312 PS 316 PS 326 PS 335 PS 361 PS 375 PS 397 PS 398 PS 1 PS 1 PS 3 PS 4 PS 5 PS 6 PS 8 PS 11 PS 13 PS 14 PS 16 PS 18 PS 19 PS 20 PS 21 PS 22 PS 23 PS 26 PS 29 PS 30 PS 31 PS 35 PS 36 PS 38 PS 39 PS 41 PS 42 PS 44 PS 45 PS 46 PS 48 PS 48 PS 50 PS 52 PS 53 PS 54 PS 55 PS 56 PS 57 PS 58 PS 60 PS 69 PS 69 PS 94 PS 97 PS 99 PS 100 PS 101 PS 102 PS 105 PS 112 PS 127 PS 128 PS 153 PS 160 PS 163 PS 164 PS 170 PS 176 PS 177 PS 179 PS 180 PS 185 PS 186 PS 192 PS 199 PS 200 PS 204 PS 205 PS 212 PS 215 PS 216 PS 229 PS 247 PS 253 PS 329 PS 506 PS 861 PS 3 PS 5 PS 8 PS 9 PS 10 PS 11 PS 15 PS 16 PS 17 PS 18 PS 19 PS 20 PS 23 PS 26 PS 28 PS 31 PS 32 PS 34 PS 38 PS 39 PS 40 PS 44 PS 45 PS 46 PS 54 PS 56 PS 58 PS 59 PS 67 PS 73 PS 75 PS 81 PS 84 PS 93 PS 107 PS 110 PS 120 PS 124 PS 130 PS 131 PS 132 PS 133 PS 137 PS 145 PS 151 PS 155 PS 157 PS 160 PS 169 PS 196 PS 243 PS 250 PS 256 PS 257 PS 261 PS 262 PS 270 PS 274 PS 287 PS 295 PS 297 PS 299 PS 301 PS 304 PS 305 PS 307 PS 309 PS 319 PS 321 PS 376 PS 377 PS 380
PS 384 PS 1 PS 2 PS 3 PS 5 PS 6 PS 7 PS 11 PS 15 PS 18 PS 19 PS 20 PS/MS 29 PS 30 PS 30 PS/MS 31 PS 33 PS 38
PS 40 PS 41 PS 42 PS 43 PS 49 PS 51 PS 59 PS 63 PS 65 IS 70 PS 72 PS 77 PS 83 PS 89 PS 102 PS 108 PS 112 PS 116 PS 124 PS/IS 126 PS 130 PS 134 PS 137 PS 142 PS 146 PS 150 PS 155 PS 157 PS 158 PS 161 PS 171
PS 179 PS 182 PS 198 PS 206 PS 212 PS 220 PS 234 PS 277 PS 290 PS 4 PS 5 PS 8 PS 9 PS 20 PS 28 PS 36 PS 46 PS 48 PS 76 PS 84 PS 87 PS 92 PS 98 PS 115 PS 123 PS 125 PS 128 PS 129 PS 132 PS 133 PS 145 PS 152 PS 154 PS 163 PS 166 PS 173 PS 175
PS 185 PS 187 PS 189 PS 191 PS 192 PS 197 PS 200 PS 208 PS242M PS 325 PS 333 PS 314 PS 315 PS 363 PS 364 PS 252 PS 499 PS 6 PS 9 PS 14 PS 16 PS 21 PS 23 PS 24 PS 29 PS 32 PS 35 PS 42 PS 49 PS 50 PS 52 PS 56 PS 59 PS 64 PS 69 PS 71 PS 75 PS 81 PS 86 PS 88 PS 103 PS 105 PS 114 PS 115 PS 121 PS 130 PS 139 PS 146 PS 147 PS 149 PS 149 PS 151 PS 153 PS 154 PS 161 PS 165 PS 172 PS 180 PS 183 PS 193 PS 194 PS 199 PS 209 PS 210 PS 215 PS 226 PS 228 PS 230 PS 230 PS 273 PS 279 PS 282 PS 291 PS 315 PS 321 PS 334 PS 340 PS 360 PS 372 PS 399 PS 4 (Staten Island) PS 9 PS 17 X PS 53 K PS 94 M PS 140 K PS 224 Q PS 231K PS 327 PS 373 R PS 352 X PS 371
Academy for Language and Technology
Academy for Scholarship and Entrepreneurship
Academy of Mount Saint Ursula
Adlai E. Stevenson Educational Campus
Bronx Guild Gateway School for Environmental Research and Technology
Millennium Art Academy
Pablo Neruda Academy for Architecture and World Studies
School for Community Research and Learning
Alfred E. Smith Career and Technical Education High School
Collocated schools:
Bronx Design and Construction Academy
Bronx Haven High School
All Hallows High School
Aquinas High School
Astor Collegiate Academy
Banana Kelly High School
Belmont Preparatory High School
Bronx Academy of Health Careers
Bronx Academy High School
Bronx Academy of Letters
Bronx Aerospace High School
Bronx Center for Science and Mathematics
Bronx Charter School for Excellence
Bronx Coalition Community High School
Bronx Collegiate Academy
Bronx Community High School
Design and Construction Academy
Engineering and Technology Academy
Bronx Envision Academy
Bronx Guild
Bronx Haven High School
Bronx High School for Law and Community Service
Bronx High School for Medical Science
Bronx High School for the Visual Arts
Bronx High School for Writing and Communication Arts
Bronx High School of Business
Bronx High School of Science Bronx International High School
Bronx Lab School
Bronx Latin
Bronx Leadership Academy High School
Bronx Leadership Academy II High School
Bronx Preparatory Charter School
Bronx Regional High School
Bronx School for Law, Government and Justice
Bronx School of Law and Finance
Bronx Studio School for Writers and Artists
Bronx Theatre High School
Bronxdale High School
The Bronxwood Preparatory Academy
Cardinal Hayes High School
Cardinal Spellman High School
The Celia Cruz Bronx High School of Music
Christopher Columbus High School
Collocated specialty schools:
Astor Collegiate Academy
Bronxdale High School
Collegiate Institute for Math and Science
Global Enterprise High School
Pelham Preparatory Academy
The Cinema School
Collegiate Institute for Math and Science
Community School for Social Justice Concourse Village campus See:
Bronx Leadership Academy II
New Explorers High School
Urban Assembly School for Careers in Sports
Crotona Academy High School
DeWitt Clinton High School
Discovery High School
DreamYard Preparatory School
Eagle Academy for Young Men
East Bronx Academy for the Future
Evander Childs Educational Campus See:
Bronx Academy of Health Careers
Bronx Aerospace High School
Bronx High School for Writing and Communication
Arts Bronx Lab School High School for Contemporary Arts
High School of Computers and Technology
Eximius College Preparatory Academy: A College Board School
Explorations Academy
Collocated school: Bronx Envision Academy
Fannie Lou Hamer Freedom High School
The Felisa Rincon de Gautier Institute for Law and Public Policy
The Fieldston School
Fordham High School for the Arts
Fordham Leadership Academy for Business and Technology
Fordham Preparatory School
Foreign Language Academy of Global Studies (FLAGS)
Frederick Douglass Academy III
Secondary School Gateway School for Environmental Research and Technology
Global Enterprise High School
Grace Dodge Career and Technical Education High School
Harry S Truman High School
Health Opportunities High School
Herbert H. Lehman High School Collocated school:
Renaissance High School for Musical Theater & Technology
High School for Contemporary Arts
High School for Language and Innovation
High School for Teaching and the Professions
High School for Violin and Dance
High School of American Studies at Lehman College
High School of Computers and Technology
High School of World Cultures
Holcombe L. Rucker School of Community Research
Horace Mann School
Hostos-Lincoln Academy of Science
In-Tech Academy (Information and Network Technology Academy)
International Community High School
International School for Liberal Arts (Walton Educational Campus)
James Monroe Educational Campus /
Bronx Coalition Community High School
The Cinema School High School of World Cultures
The Metropolitan Soundview High School
Monroe Academy for Business/Law
Monroe Academy for Visual Arts & Design
Pan American International High School at Monroe
Jane Addams High School for Academic Careers
Jill Chaifetz Transfer High School
John F. Kennedy High School Collocated schools:
Bronx Engineering and Technology Academy
Bronx School of Law and Finance
Bronx Theatre High School
Marble Hill High School for International Studies
Jonathan Levin High School for Media and Communications
Kingsbridge International High School
Knowledge and Power Preparatory Academy
International High School (KAPPA)
Leadership Institute
Marble Hill High School for International Studies
The Marie Curie School for Medicine, Nursing, and Health Professions
The Metropolitan High School
The Metropolitan Soundview High School
Millennium Art Academy
Monroe Academy for Business/Law
Monroe Academy for Visual Arts & Design
Monsignor Scanlan High School
Morris Academy for Collaborative Studies
Morris Educational Campus See:
Bronx International High School
High School for Violin and Dance
Morris Academy for Collaborative Studies School for Excellence
Mott Hall Bronx High School
Mott Haven Village Preparatory High School
Mount Saint Michael Academy
New Day Academy
New Explorers High School
New World High School
Pablo Neruda Academy for Architecture and World Studies
Pan American International High School at Monroe
Academy Pelham Preparatory
Academy Performance Conservatory High School
Preston High School
Providing Urban Learners Success in Education (PULSE) High School
Renaissance High School for Musical Theater & Technology
Riverdale Country School
Riverdale Kingsbridge Academy
St. Barnabas High School
St. Catharine Academy
St. Pius V High School
St. Raymond Academy for Girls
St. Raymond High School for Boys
Salanter Akiba of Riverdale (SAR) High School
Samuel Gompers Career and Technical Education High School
School for Community Research and Learning
School for Excellence
South Bronx Educational Campus See:
Mott Haven Village Preparatory High School
University Heights Secondary School
South Bronx Preparatory
Theatre Arts Production Company School
Theodore Roosevelt Educational Campus See:
Belmont Preparatory High School
Bronx High School for Law and Community Service
Fordham High School for the Arts
Fordham Leadership Academy for Business and Technology Knowledge and Power Preparatory Academy International High School (KAPPA)
West Bronx Academy for the Future
University Heights Secondary School
The Urban Assembly School for Applied Math and Science
Careers in Sports High School
Validus Preparatory Academy
Celia Cruz Bronx High School of Music Discovery
High School for Teaching and the Professions
International School for Liberal Arts
Kingsbridge International High School
West Bronx Academy for the Future
William Howard Taft Educational Campus See:
Bronx Collegiate Academy
Bronx High School for Medical Science
Bronx High School of Business
DreamYard Preparatory School
Jonathan Levin High School for Media and Communications
The Urban Assembly Academy for History and Citizenship for Young Men
Wings Academy Women’s Academy of Excellence
Yeshiva of Telshe Alumni School
Abraham Lincoln High School
Academy for College Preparation and Career Exploration
Academy for Conservation and the Environment
Academy for Environmental Leadership
Academy for Young Writers
Academy of Hospitality and Tourism
Academy of Innovative Technology
Academy of Urban Planning
ACORN Community High School
All City Leadership Secondary School
Al-Madinah School
Al-Noor School
Aspirations Diploma Plus High School
Automotive High School
Bedford Academy High School
Bedford Stuyvesant Preparatory High School
Benjamin Banneker Academy
Berkeley Carroll School Beth Jacob High School
Beth Rivkah Big Apple Academy
Bishop Ford Central Catholic High School
Bishop Kearney High School
Bishop Loughlin Memorial High School
B’nos Leah Prospect Park Yeshiva School
B’nos Yisroel High School for Girls Boys and
Girls High School
Brooklyn Academy of Science and the Environment (BASE)
Brooklyn Academy High School
Brooklyn Bridge Academy
Brooklyn College Academy
Brooklyn Collegiate
Brooklyn Community High School of Communication, Arts and Media
Brooklyn Democracy Academy
Brooklyn Generation School
Brooklyn High School for Leadership and Community Service
Brooklyn High School of the Arts
Brooklyn High School for Law and Technology
Brooklyn International High School
Brooklyn Lab School
The Brooklyn Latin School
Brooklyn Preparatory High School
Brooklyn School for Global Studies
The Brooklyn School for Math and Research
Brooklyn School for Music & Theatre
Brooklyn Secondary School for Collaborative Studies
Brooklyn Studio Secondary School
Brooklyn Technical High School
Brooklyn Theatre Arts High School
Brownsville Academy High School
Bushwick Community High School
Bushwick Educational Campus See:
Academy for Environmental Leadership
Academy of Urban Planning
The Brooklyn School for Math and Research
Bushwick School for Social Justice
Bushwick Leaders High School for Academic Excellence
Bushwick School for Social Justice
Canarsie High School
Catherine McAuley High School
City Polytechnic High School of Engineering, Architecture, and Technology
Clara Barton High School
Cobble Hill School of American Studies
Connie Lekas School
Cypress Hills Collegiate Preparatory School
Dr. Susan S. McKinney Secondary School of the Arts
East New York Family Academy
EBC/ENY High School for Public Safety & Law
EBC High School for Public Service–Bushwick
Edward R. Murrow High School
El Puente Academy for Peace and Justice
Enterprise, Business and Technology High School
Expeditionary Learning School for Community Leaders
Erasmus Hall Educational Campus
Academy for College Preparation and Career Exploration
Erasmus High School for Youth and Community Development
Early College High School at Erasmus
FDNY High School for Fire and Life Safety
Fontbonne Hall Academy
Fort Hamilton High School
Foundations Academy
Franklin Delano Roosevelt High School
Franklin K. Lane Educational Campus
Academy of Innovative Technology
Brooklyn Lab School
Cypress Hills Collegiate Preparatory School Multicultural High School
Frederick Douglass Academy IV Secondary School
Frederick Douglass Academy VII High School
Freedom Academy High School
George Wingate Educational Campus See:
High School for Public Service: Heroes of Tomorrow
International Arts Business School
School for Democracy and Leadership
The School for Human Rights
Gerer Mesivta Bais Yisroel School
George Westinghouse Career and Technical Education High School
Gotham Professional Arts Academy
Green School: An Academy for Environmental Careers
Harry Van Arsdale Educational Campus
Brooklyn Preparatory High School
Williamsburg High School for Architecture and Design
Williamsburg Preparatory School
High School for Civil Rights
The High School for Global Citizenship
High School for Public Service: Heroes of Tomorrow
High School for Service & Learning at Erasmus
High School for Youth and Community Development at Erasmus
High School of Sports Management
High School of Telecommunication Arts and Technology
International Arts Business School
International High School at Lafayette
International High School at Prospect Heights
It Takes a Village Academy
James Madison High School
John Dewey High School
John Jay Educational Campus
Millennium Brooklyn High School
Park Slope Collegiate
Secondary School for Journalism Secondary School for Law
Juan Morel Campos Secondary School
Kingsborough Early College Secondary School
Kurt Hahn Expeditionary Learning School
Lafayette High School
Leon M. Goldstein High School for the Sciences
Liberation Diploma Plus Life Academy
High School for Film and Music
Lyons Community School
Magen David Yeshivah High School
Medgar Evers College Preparatory School
Merkaz Bnos High School
Mesivta M’kor Chaim School
Mesivta Nachlas Yakov School
Mesivta of Seagate School
Mesivta Rabbi Chaim Berlin High School
Mesivta/Yeshiva Gedola Manhattan Beach School
Metropolitan Corporate Academy
Metropolitan Diploma Plus High School
Midwood High School
Mikdash Melech Mechina School
Millennium Brooklyn High School
Mirrer Yeshiva High School Multicultural High School
Nazareth Regional High School
New Utrecht High School
New York Harbor School
Olympus Academy Pacific High School
The Packer Collegiate Institute Park Slope Collegiate
Pathways in Technology Early College High School
Paul Robeson High School for Business and Technology
Collocated school: Pathways in Technology Early College High School
Performing Arts and Technology High School
Poly Prep Country Day School
Progress High School for Professional Careers Brooklyn Academy of Science and the Environment
Brooklyn School for Music & Theatre
The High School for Global Citizenship
International High School at Prospect Heights
Rachel Carson High School for Coastal Studies
Roy Campanella Occupational Training Center
St. Ann’s School St. Edmund Preparatory High School
St. Joseph High School
St. Saviour High School
It Takes a Village Academy
Cultural Academy for the Arts and Sciences
The Kurt Hahn Expeditionary Learning School
The School for Classics: An Academy of Thinkers, Writers and Performers
School for Democracy and Leadership
The School for Human Rights School for International Studies
School for Legal Studies
Science Skills Center High School for Science, Technology and the Creative Arts
Science, Technology and Research Early College High School at Erasmus
Secondary School for Journalism
Secondary School for Law
Secondary School for Research
Sheepshead Bay High School
Shulamith High School for Girls
Sinai Academy
Soille Bais Yaakov High School
South Brooklyn Community High School
South Shore Educational Campus See:
Academy for Conservation and the Environment Brooklyn Bridge Academy
Brooklyn Generation School Brooklyn
Theatre Arts High School
Victory Collegiate High School
Sunset Park High School
Teachers Preparatory High School
FDNY High School for Fire and Life Safety
High School for Civil Rights
Performing Arts and Technology High School
World Academy for Total Community Health High School
Tiferes Academy
Tiferes Bais Yaakov High School
Tiferes Miriam High School
Tomer Devora High School for Girls
Torah Academy High School
Transit Tech Career and Technical Education High School
United Lubavitcher Yeshiva
Urban Assembly Institute of Math and Science for Young Women
The Urban Assembly School for Law and Justice
The Urban Assembly School of Music and Art
Victory Collegiate High School
Brooklyn International High School
Science Skills Center High School for Science, Technology and the Creative Arts
Urban Assembly High School of Music and Art
W.E.B. Dubois Academic High School
West Brooklyn Community High School
William E. Grady Career and Technical Education High School
William H. Maxwell Career and Technical Education High School
Williamsburg Charter High School
Williamsburg High School for Architecture and Design
Williamsburg Preparatory School
World Academy for Total Community Health High School
Xaverian High School
Yeshiva Chanoch
Lenaar Yeshiva
Derech HaTorah High School
Yeshiva Gedolah of Midwood
Yeshiva Gezdah Bais Yisrael
Yeshiva Karunas Halev
Yeshiva of Flatbush
Joel Braverman High School
Yeshiva Ohr Moleh Koson
Yeshiva Sharro Yosher
Yeshiva Tiferes Shmiel
Yeshiva Toraf Hesed
Yeshiva Vyelipol School
Yeshivat Ateret Torah Yeshivat
Or Hatorah Yeshivat
Shaare Torah Boys High School
Yeshivat Shaare Torah Girls High School
Yeshiva/Mesivta V’yoel Moshe School
Zvi Dov Roth Academy of Yeshiva Rambam
Philip Randolph Campus High School
Aaron School Abraham Joshua Heschel School
Academy of Environmental Science Secondary High School
Academy for Social Action: A College Board School
Aichhorn School
The American Sign Language and English Secondary School
Avenues: The World School
Bard High School Early College
Ballet Tech, NYC Public School for Dance
Baruch College Campus High School
The Beacon School (Beacon High School)
The Beekman School
Bread & Roses Integrated Arts High School
Brearley School
The Browning School
The Calhoun School
Cascades High School
Cathedral High School
Central Park East High School
Chapin School
Chelsea Career and Technical Education High School)
Choir Academy of Harlem City-As-School
Coalition School for Social Change
Collegiate School
Columbia Grammar & Preparatory School
Columbia Secondary School
Cristo Rey New York High School
Convent of the Sacred Heart
The Dalton School
Daytop Preparatory School
Dominican Academy
The Dwight School
East Side Community High School
Edward A. Reynolds West Side High School
Eleanor Roosevelt High School
Elisabeth Irwin High School
Essex Street Academy
The Facing History School
Fiorello H. LaGuardia High School of Music & Art and Performing Arts
Food and Finance High School
Frederick Douglass Academy See also:
Frederick Douglass Academy II Secondary School
(Manhattan) Frederick Douglass Academy III Secondary School
(Bronx)
Frederick Douglass Academy IV Secondary School (Brooklyn)
Frederick Douglass Academy VI High School (Queens)
Frederick Douglass Academy VII High School (Brooklyn)
Frederick Douglass Academy II Secondary School
Friends Seminary
Fusion Academy & Learning Center
George Washington High School
High School for Health Careers and Sciences
High School for International Business and Finance
High School for Law and Public Service
High School for Media and Communications
Gramercy Arts High School
Greenwich Village High School
Gregorio Luperon High School for Math & Science
Harlem Renaissance High School
Harvey Milk High School
Henry Street School for International Studies
The Heritage School
The Hewitt School High School for Arts, Imagination and Inquiry
High School for Dual Language and Asian Studies
(Seward Park campus)
High School For Environmental Studies
High School for Health Careers and Sciences (George Washington campus)
High School for Health Professions and Human Services
High School for Humanities Educational Campus
Bayard Rustin High School for the Humanities
Humanities Preparatory Academy
The James Baldwin School
High School for International Business and Finance
High School for Law, Advocacy, and Community Justice
High School for Law and Public Service
High School for Leadership and Public Service
High School for Math, Science and Engineering at City College
High School for Media and Communications
High School of Art and Design High School of Arts and Technology
High School of Economics and Finance
High School of Fashion Industries
High School of Graphic Communication Arts
Collocated school: Urban Assembly Gateway School for Technology
High School of Hospitality Management
Humanities Preparatory Academy
Hunter College High School
Independence High School
Institute for Collaborative Education
Jacqueline Kennedy Onassis High School
The James Baldwin School: A School for Expeditionary Learning
John V. Lindsay Wildcat Academy Charter School
Julia Richman Education Complex
Manhattan International High School
Talent Unlimited High School
Vanguard High School
La Salle Academy
Landmark High School
Legacy School for Integrated Studies
Léman Manhattan Preparatory School
Liberty High School
Academy for Newcomers
Life Sciences Secondary School
Louis D. Brandeis High School
Lower East Side Preparatory High School
Lower Manhattan Arts Academy
Loyola School Lycée français de New York (LFNY)
Manhattan Bridges High School
Manhattan Center for Science and Mathematics
Manhattan Comprehensive Night and Day High School
Manhattan High School for Girls
Manhattan/Hunter College High School for Sciences
Manhattan International High School
Manhattan Theatre Lab High School
Manhattan Village Academy
Marta Valle High School (Marta Valle Secondary School)
Martin Luther King High School
High School for Arts, Imagination and Inquiry
High School for Law, Advocacy and Community
Justice High School of Arts and Technology
Hunter College High School (Manhattan/Hunter Science High School)
Manhattan Theatre Lab High School
The Urban Assembly School for Media Studies
Marymount School
Millennium High School
Mother Cabrini High School
Mott Hall High School
Murry Bergtraum High School for Business Careers
New Design High School
New Explorations into Science, Technology and Math High School (NEST+m High School)
NYC iSchool
New York City Lab School for Collaborative Studies
New York City Museum School
Nightingale-Bamford School
Norman Thomas High School
Northeastern Academy
Notre Dame School
Pace High School
Park East High School
Park West High School
The Facing History School
Food and Finance High School
High School of Hospitality Management
Manhattan Bridges High School
The Urban Assembly School of Design and Construction
Professional Children’s School
Professional Performing Arts School
Quest to Learn Ramaz School
Rebecca School Regis High School
Repertory Company
High School for Theatre Arts
Rice High School
Richard R. Green High School of Teaching
The Robert Louis Stevenson School
St. Agnes Boys High School
St. Jean Baptiste High School
St. Michael Academy
St. Vincent Ferrer High School Sacred Heart (See Convent of the Sacred Heart)
Satellite Academy High School
School for the Physical City High School
School of the Future
Seward Park High School
Essex Street Academy
High School for Dual Language and Asian Studies
Lower Manhattan Arts Academy
New Design High School
The Urban Assembly Academy of Government and Law
The Smith School
Solomon Schechter High School of New York
Spence School
Stuyvesant High School
Talent Unlimited High School
Thurgood Marshall Academy for Learning and Social Change
Trevor Day School
Trinity School
United Nations International School
Unity Center for Urban Technologies
University Neighborhood High School
Urban Academy Laboratory High School
The Urban Assembly
Academy of Government and Law
Urban Assembly
Gateway School for Technology
High School of Graphic Communication Arts
The Urban Assembly New York Harbor School
The Urban Assembly School for Media Studies
Urban Assembly School for the Performing Arts
The Urban Assembly School of Business for Young Women
The Urban Assembly School of Design and Construction
Urban Peace Academy
Vanguard High School
Wadleigh Secondary School for the Performing & Visual Arts
Washington Irving High School
Winston Preparatory School
Xavier High School
Yeshiva University High School for Boys
York Preparatory School
Young Women’s Leadership School
Washington Heights Expeditionary Learning School
Academy for Careers in Television and Film
Academy of American Studies
Academy of Finance and Enterprise
Academy of Medical Technology
Al-Iman School
Archbishop Molloy High School
August Martin High School
Aviation High School
Baccalaureate School for Global Education
Bais Yaakov Machon Academy
Bard High School Early College II
Bayside High School
Channel View School for Research
Rockaway Collegiate High School
Rockaway Park High School for Environmental Sustainability
Cambria Heights Academy for New Literacies
Campus Magnet Educational Campus Collocated schools: Andrew Jackson High School /Humanities and the Arts Magnet High School
Mathematics, Science Research and Technology Magnet High School
Institute for Health Professions at Cambria Heights
Benjamin Franklin High School for Finance & Information Technology
Benjamin N. Cardozo High School Cathedral Preparatory Seminary Channel View School for Research
The Child School Legacy High School, Roosevelt Island Christ The King Regional High School East-West School of International Studies Evangel Christian School
Excelsior Preparatory High School (Springfield Gardens Educational Campus) Ezra Academy Far Rockaway Educational Campus
Academy of Medical Technology: A College Board School
Frederick Douglass Academy VI High School
Queens High School for Information, Research, and Technology
Flushing High School
Flushing International High School
Forest Hills High School
Francis Lewis High School
Frank Sinatra School of the Arts High School
Frederick Douglass Academy VI High School
Garden School Gateway to Health Science High School
George Washington Carver High School for the Sciences
Greater New York Academy of Seventh-day Adventists
Grover Cleveland High School
High School for Arts and Business
High School for Community Leadership
High School for Construction Trades, Engineering and Architecture High
School for Law Enforcement and Public Safety
High School of Applied Communication
Hillcrest High School
Hillside Arts & Letters Academy
Holy Cross High School
Humanities & Arts Magnet High School
Information Technology High School
International High School at LaGuardia Community College
Jamaica Gateway to the Sciences
Jamaica High School
High School for Community Leadership
Hillside Arts & Letters Academy
Jamaica Gateway to the Sciences
Queens Collegiate: A College Board School
John Adams High School
John Bowne High School
John F. Kennedy Jr. School
Long Island City High School
The Lowell School
Martin Luther High School
Martin Van Buren High School
The Mary Louis Academy
Maspeth High School
Mathematics, Science Research and Technology Magnet High School
Mesivta Ohr Torah School
Mesivta Yesodei Yeshurun
Metropolitan Expeditionary Learning School (Queens Metropolitan High School campus) Middle College High School at LaGuardia Community College
Monsignor McClancy Memorial High School
Newcomers High School
Newtown High School
North Queens Community High School
Pan American International High School
Pathways College Preparatory School: A College Board School
Preparatory Academy for Writers: A College Board School
Project Blend School, Jamaica Queens Academy High School
Queens Collegiate: A College Board School
Queens Gateway to Health Sciences Secondary School
Queens High School for Information, Research, and Technology
Queens High School for the Sciences at York College
Queens High School of Teaching, Liberal Arts and the Sciences
Queens Metropolitan High School
Metropolitan Expeditionary Learning High School
Queens Preparatory Academy
Queens Vocational and Technical High School
Razi School
The Renaissance Charter School
Richmond Hill High School
Robert F. Kennedy Community High School
Robert F. Wagner, Jr. Secondary School for Arts and Technology
Robert H. Goddard High School of Communication Arts and Technology
Rockaway Collegiate High School
Rockaway Park High School for Environmental Sustainability
St. Agnes High School
St. Demetrios School
St. Francis Preparatory School
St. George Academy
St. John’s Preparatory School
Scholars’ Academy
Shevach High School
Excelsior Preparatory High School
George Washington Carver High School for the Sciences
Preparatory Academy for Writers: A College Board School
Queens Preparatory Academy
Summit School
Thomas A. Edison Vocational and Technical High School
Torah Academy
High School for Girls
Townsend Harris High School
VOYAGES Preparatory
Whitestone Academy
William Cullen Bryant High School
Windsor School
World Journalism Preparatory: A College Board School
Yeshiva Berachel David-Torah School
Yeshiva Binat Chaim – Boys School
Yeshiva of Far Rockaway
Yeshiva Shaar Hatoreh Research
Yeshiva University
High School for Girls
Samuel H. Wang Yeshiva
University High School for Girls
Young Women’s Leadership School
Astoria Young Women’s Leadership School
Queens College of Staten Island
High School for International Studies
Concord High School
Curtis High School
Gaynor McCown Expeditionary Learning School
Mesivta Kesser Yisroel
Michael J. Petrides School
Miraj Islamic School
Monsignor Farrell High School
Moore Catholic High School
New Dorp High School
Notre Dame Academy High School
Port Richmond High School
Ralph R. McKee Career and Technical Education High School
Richard H. Hungerford School
St. Joseph by the Sea High School
St. Joseph Hill Academy
St. Peter’s Boys High School
Staten Island Academy
Staten Island Technical High School
Susan E. Wagner High School
Tottenville High School
Yeshiva of Staten Island
Yeshiva Tifereth Torah
Alexander Graham Bell Elementary School
Alpine Elementary School
Avalon Elementary School
Avondale Elementary School
Beatty Park Elementary School
Berwick Alternative Elementary School
Binns Elementary School
Broadleigh Elementary School
Burroughs Elementary School
Cassady Alternative Elementary School
Cedarwood Alternative Elementary School
Clinton Elementary School
Colerain Elementary School
Como Elementary School
Cranbrook Elementary School
Devonshire Alternative Elementary School
Duxberry Park Alternative Elementary School
Eakin Elementary School
East Columbus Elementary School
East Linden Elementary School
Eastgate Elementary School
Easthaven Elementary School
Fairmoor Elementary School
Fairwood Alternative Elementary School
Forest Park Elementary School
Gables Elementary School
Georgian Heights Alternative Elementary School
Hamilton Alternative Elementary School
Highland Elementary School
Hubbard Mastery Elementary School
Huy Road Elementary School
Indian Springs Elementary School
Indianola Alternative Elementary School
Innis Elementary School
Leawood Elementary School
Liberty Elementary School
Lincoln Park Elementary School
Lindbergh Elementary School
Linden Elementary School
Livingston Avenue Elementary
School Maize Road Elementary School
Moler Elementary School
North Linden Elementary School
Northtowne Elementary School
Oakland Park Alternative Elementary School
Oakmont Elementary School
Ohio Avenue Elementary School
Olde Orchard Alternative Elementary School
Parkmoor Urban Academy Elementary School
Parsons Elementary School
Salem Elementary School
Scottwood Elementary School
Shady Lane Elementary School
Siebert Elementary School
South Mifflin Elementary School
Southwood Elementary School
Special Education Center
Stewart Alternative Elementary School
Sullivant Elementary School
Trevitt Elementary School
Valley Forge Elementary School
Valleyview Elementary School
Watkins Elementary School
Weinland Park Elementary School
West Broad Street Elementary School
West Mound Elementary School
Westgate Alternative Elementary School
Windsor Alternative Elementary School
Winterset Elementary School
Woodcrest Elementary School
Columbus Spanish Immersion
Ecole Kenwood Johnson Park Middle School
Arts Impact Middle School (AIMS)
Baldwin Road Middle School
Buckeye Middle School
Champion Middle School
Columbus City Preparatory School for Boys
Columbus City Preparatory School for Girls
Columbus Gifted Academy
Dominion Middle School
Hilltonia Middle School
Johnson Park Middle School
Medina Middle School
Mifflin Alternative Middle School
Ridgeview Middle School
Sherwood Middle School
Starling Middle School K-8
Wedgewood Middle School
Westmoor Middle School
Woodward Park Middle School
Yorktown Middle School
Africentric K-8
Columbus Spanish Immersion Academy
Ecole Kenwood French Immersion School
Indianola Informal
Starling K-8 School
West High School
Whetstone High School
Beechcroft High School
Briggs High School
Centennial High School
Columbus Africentric High School
Columbus Alternative High School
Columbus North International School
Downtown High School
East High School
Eastmoor Academy
Fort Hayes Metropolitan Education Center
Independence High School
Linden-McKinley High School
Marion-Franklin High School
Mifflin High School
Northland High School
South High School
Walnut Ridge High School
West High School
Whetstone High School
Abernethy
Ainsworth
Alameda
Atkinson
Ball
Boise-Eliot/Humboldt
Bridlemile
Buckman Arts
Capitol Hill
Chapman
Chief Joseph
Duniway
Forest Park
Glencoe
Grout
Hayhurst
Irvington
James John
Kelly
Lewis
Llewellyn
Maplewood
Markham
Martin Luther King Jr. School
Richmond
Rieke
Rigler
Rosa Parks
Sabin
Sitton
Stephenson
Whitman
Woodlawn
Woodmere
Woodstock
ACCESS Academy
Arleta School
Astor
Beach
Beverly Cleary School
Bridger
Cesar Chavez
Creative Science
Creston
Harrison Park
Joseph L. Meek Professional Technical
Lee
Lent
Marysville
Metropolitan Learning Center
Odyssey Program at East Sylvan
Peninsula
Roseway Heights
Scott
Sellwood
Skyline
Sunnyside Environmental School
Trillium Charter School, K–12
Vernon A
Vestal
Winterhaven
Woodlawn A
Beaumont
Da Vinci Arts Middle School
George
Harriet Tubman
Hosford
Jackson
Lane
Mt. Tabor
Ockley Green
Robert Gray
Sellwood
West Sylvan
Benson Polytechnic High School
Cleveland High School
Franklin High School
Grant High School
Jefferson High School
Lincoln High School
Madison High School
Roosevelt High School
Wilson High School
Adaire, Alexander Elementary
Allen, Dr. Ethel Elementary
Allen, Ethan Elementary
Anderson, Add B. Elementary
Arthur, Chester A. Elementary
Bache-Martin Elementary
Barry, John Elementary
Barton Elementary
Bethune, Mary McLeod Elementary
Blaine, James G. Elementary
Blankenburg, R. Elementary
Bregy, Amedee F. Elementary
Bridesburg Elementary
Brown, Henry A. Elementary
Brown, Joseph H. Elementary
Bryant, William C. Elementary
Carnell, Laura H. Elementary
Catharine, Joseph W. Elementary
Cayuga Elementary
Fox Chase Elementary
Childs, George W. Elementary
Comegys, Benjamin B. Elementary
Comly, Watson Elementary
Cooke, Jay Elementary
Cook-Wissahickon Elementary
Cramp, William Elementary
Crossan, Kennedy C. Elementary
Crossroads Academy @ Hunting Park Elementary
Day, Anna B. Elementary
DeBurgos, J. Elementary
Decatur, Stephen Elementary
Dick, William Elementary
Disston, Hamilton Elementary
Dobson, James Elementary
Duckrey, Tanner Elementary
Dunbar, Paul L. Elementary
Edmonds, Franklin S. Elementary
Elkin, Lewis Elementary
Ellwood Elementary
Emlen, Eleanor C. Elementary
Farrell, Louis H. Elementary
Fell, D. Newlin Elementary
Feltonville Intermediate
Finletter, Thomas K. Elementary
Fitler Academic Plus Elementary
Fitzpatrick, A. L. Elementary
Forrest, Edwin Elementary
Frank, Anne Elementary
Franklin, Benjamin Elementary
Garden, Spring Elementary
Gideon, Edward Elementary
Girard, Stephen Elementary
Gompers, Samuel Elementary
Greenberg, Joseph Elementary
Greenfield, Albert M. Elementary
Hackett, Horatio B. Elementary
Hall, Prince Elementary
Hamilton, Andrew Elementary
Harrington, Avery D. Elementary
Hartranft, John F. Elementary
Henry, Charles W. Elementary
Heston, Edward Elementary
Holme, Thomas Elementary
Hopkinson, Francis Elementary
Houston, Henry H. Elementary
Howe, Julia Ward Elementary
Hunter, William H. Elementary
Jackson, Andrew Elementary
Jenks Academy Arts & Sciences Elementary
Jenks, Abram Elementary
John Hancock Demonstration Elementary
Juniata Park Academy
Kearny, Gen. Philip Elementary
Kelley, William D. Elementary
Kelly, John B. Elementary
Kenderton Elementary
Key, S. Francis Elementary
Kirkbride, Eliza B. Elementary
Lamberton, Robert E. Elementary
Lawton, Henry W. Elementary
Lea, Henry C. Elementary
Lewis C. Cassidy Academic Plus Elementary
Lingelbach, Anna L. Elementary
Locke, Alain Elementary
Loesche, William H. Elementary
Logan, James Elementary
Longstreth, William C. Elementary
Lowell, James R. Elementary
Ludlow, James R. Elementary
Marshall, John Elementary
Marshall, Thurgood Elementary
Mayfair Elementary
McCall, Gen. George A. Elementary
McCloskey, John F. Elementary
McClure, Alexander K. Elementary
McDaniel, Delaplaine Elementary
McKinley, William Elementary
McMichael, Morton Elementary
Meade, Gen. George G. Elementary
Memorial, Widener Elementary
Meredith, William M. Elementary
Mifflin, Thomas Elementary
Mitchell Elementary
Moffet, John Elementary
Moore, J. Hampton Elementary
Morris, Robert Elementary
Morrison, Andrew J. Elementary
Morton, Thomas G. Elementary
Munoz-Marin, Hon. Luis Elementary
Nebinger, George W. Elementary
Olney Elementary
Overbrook Elementary
Overbrook Educational School
Patterson, John M. Elementary
Peirce, Thomas M. Elementary
Penn Alexander Elementary
Pennell, Joseph Elementary
Pennypacker, Samuel Elementary
Penrose Elementary
Pollock, Robert B. Elementary
Potter-Thomas Elementary
Powel, Samuel Elementary
Rhawnhurst Elementary
Rhoads, James Elementary
Rhodes Elementary
Richmond Elementary
Roosevelt Elementary
Rowen, William Elementary
Sharswood,George Elementary
Shawmont Elementary
Sheppard, Isaac A. Elementary
Sheridan, Philip H. Elementary
Solis-Cohen, Solomon Elementary
Southwark Elementary
Spring Garden Elementary
Spruance, Gilbert Elementary
Stanton, Edwin M. Elementary
Stearne, Allen M. Elementary
Steel, Edward Elementary
Sullivan, James J. Elementary
Taggart, John H. Elementary
Taylor, Bayard Elementary
Vare-Washington Elementary
Waring, Laura W. Elementary
Washington, Martha Elementary
Webster, John H. Elementary
Welsh, John Elementary
Willard, Frances E. Elementary
Wright, Richard R. Elementary
Ziegler, William H. Elementary
AMY 5 @ James Martin middle
AMY Northwest middle
Baldi middle
Clemente, Roberto middle
Conwell, Russell middle
Crossroads Accelerated Academy middle
Feltonville Arts & Sciences middle
Harding, Warren G. middle
Hill-Freedman World Academy middle
Meehan, Austin middle
Middle Years Alt – MYA
Science Leadership Academy middle
Tilden middle
Wagner, Gen. Louis middle
Washington, Grover Jr. middle
Wilson, Woodrow middle
Academy @ Palumbo High
Arts Academy @ Benjamin Rush High
Bartram, John High
Bodine, William W. High
Building 21 High
Carver Engineering & Science High
Central High
Constitution High
Creative & Performing Arts High
Dobbins, Murrell High
Edison, Thomas A. High
Fels, Samuel High
Frankford High
Franklin Learning Center High
Franklin, Benjamin High
Franklin, Benjamin EOP High
Furness, Horace High
Girard Academic Music Program High
Kensington High
Kensington CAPA
Kensington Health Sciences High
King, Martin Luther High
Lankenau High
Lincoln, Abraham High
Mastbaum, Jules E. High
Masterman, Julia R. High
Motivation High
Northeast High
Overbrook High
Parkway Center City High
Parkway Northwest High
Parkway West High
Penn Treaty High
Philadelphia High School for Girls
Philadelphia Learning Academy – North
Philadelphia Learning Academy – North EOP
Philadelphia Learning Academy – South
Philadelphia Learning Academy – South EOP
Philadelphia Military Academy
Philadelphia Virtual Academy
Randolph Technical High
Robeson, Paul High
Roxborough High
Saul, Walter B. High
Sayre, William L. High
School of the Future
Science Leadership Academy
Science Leadership Academy @ Beeber
South Philadelphia High
Strawberry Mansion High
Swenson Arts/Tech High
The LINC High
U School High
Vaux Big Picture High
Washington, George High
West Philadelphia High
Workshop School High
Camelot Academy
Camelot Academy Hunting Park
Crossroads @ Hunting Park
Crossroads Accelerated Academy
El Centro de Estudiantes
Excel Academy North
Excel Academy South
Franklin High School EOP
Gateway to College
Liguori Academy
Northeast High School EOP
OIC Cadi
Ombudsman Accelerated Northwest
One Bright Ray – Elmwood Campus
One Bright Ray – Fairhill
Pennypack House School
Philadelphia Learning Academy – North EOP
Philadelphia Learning Academy – South EOP
Philadelphia OIC Workforce Academy
South Philadelphia High School EOP
YES Philly
Robert L. Bailey, IV Elementary School
Anthony Carnevale Elementary School
William D’Abate Elementary School
Alan Shawn Feinstein Elementary School
Lillian Feinstein Elementary Schoolt
Mary E. Fogarty Elementary School
Charles N. Fortes Elementary School
Vartan Gregorian Elementary School
Robert F. Kennedy Elementary School
Dr. Martin Luther King, Jr. Elementary School
Harry Kizirian Elementary School
Carl G. Lauro Elementary School
Leviton Dual Language School
Alfred Lima, Sr. Elementary School
Asa Messer Elementary School
Pleasant View Elementary School
Reservoir Avenue Elementary School
Frank D. Spaziano Elementary School & Annex
Veazie Street Elementary School
Webster Avenue Elementary School
George J. West Elementary School
The Sgt. Cornel Young, Jr. & Charlotte Woods Elementary School
Nathan Bishop Middle School
DelSesto Middle School
Nathanael Greene Middle School
Esek Hopkins Middle School
Gilbert Stuart Middle School
West Broadway Middle School
Roger Williams Middle School
360 High School
Dr. Jorge Alvarez High School
Providence Career & Technical Academy
Central High School
Classical High School
E-Cubed Academy
Evolutions High School
Hope High School
Mount Pleasant High School
The William B. Cooley, Sr. High School
The Providence Academy of International Studies
Cedar Hill Elementary
E.T. Wyman Elementary
Greenwood Elementary
Holliman Elementary
Hoxsie Elementary
Lippitt Elementary
Norwood Elementary
Oakland Beach Elementary
Park Elementary
Robertson Elementary
Scott Elementary
Sherman Elementary
Warwick Early Learning Center
Warwick Neck Elementary
Veterans Middle School
Winman Middle School
Pilgrim High School
Toll Gate High School
Warwick Area Career & Technical Center
A.J. Wittenberg Elementary
Alexander Elementary
Armstrong Elementary
Augusta Circle Elementary
Bell’s Crossing Elementary
Berea Elementary
Bethel Elementary
Blythe Academy
Brook Glenn Elementary
Brushy Creek Elementary
Bryson Elementary
Buena Vista Elementary
Chandler Creek Elementary
Cherrydale Elementary
Crestview Elementary
Duncan Chapel Elementary
East North Street Academy
Ellen Woodside Elementary
Fork Shoals
Fountain Inn Elementary
Gateway Elementary
Greenbrier Elementary
Grove Elementary
Heritage Elementary
Hollis Academy
Lake Forest Elementary
Mauldin Elementary
Mitchell Road Elementary
Monarch Elementary
Monaview Elementary
Mountain View Elementary
Oakview Elementary
Paris Elementary
Pelham Road Elementary
Plain Elementary
Robert E. Cashion Elementary
Rudolph Gordon School
Sara Collins Elementary
Simpsonville Elementary
Skyland Elementary
Slater Marietta Elementary
Sterling School Charles Townes Gifted Center
Stone Academy
Sue Cleveland Elementary
Summit Drive Elementary
Taylors Elementary
Thomas E. Kerns Elementary
Tigerville Elementary
Welcome Elementary
Westcliffe Elementary
Woodland Elementary
Beck International Academy
Berea Middle
Blue Ridge Middle
Bryson Middle
Dr. Phinnize J. Fisher Middle
Greenville Middle Academy
Greenville Early College
Greer Middle
Hillcrest Middle
Hughes Academy
Lakeview Middle
League Academy of Communication Arts
Mauldin Middle
Northwest Middle
Northwood Middle
Ralph Chandler Middle
Riverside Middle
Sevier Middle
Tanglewood Middle
Woodmont Middle
Berea High
Blue Ridge High
Carolina High School & Academy
Eastside High
Greenville High
Greer High Hillcrest High
J.L. Mann Academy
Mauldin High
Riverside High
Southside High
Travelers Rest High
Wade Hampton High
Woodmont High
Berkeley High School
Cane Bay High School
Cross High School
Goose Creek High School
Hanahan High School Philip
Simmons High School
Stratford High School
Timberland High School
Berkeley Alternative School
Berkeley Middle College
Daniel Island Elementary and Middle School
Berkeley Middle School
Cane Bay Middle School
Charles B. DuBose Middle School
College Park Middle School
Hanahan Middle School
Macedonia Middle School
Marrington Middle School
St. Stephen Middle School
Sangaree Middle School
Sedgefield Middle School
Philip Simmons Middle School
Westview Middle School
Berkeley Elementary
Berkeley Intermediate
Boulder Bluff Elementary
Cainhoy Elementary
Cane Bay Elementary
College Park Elementary
Cross Elementary
Devon Forest Elementary
Goose Creek Primary
H.E. Bonner Elementary
Hanahan Elementary
Howe Hall AIMS
J.K. Gourdin Elementary
Marrington Elementary
Nexton Elementary
Philip Simmons Elementary
St. Stephen Elementary
Sangaree Elementary
Sangaree Intermediate
Sedgefield Intermediate
Westview Elementary Westview Primary
Whitesville Elementary
Lincoln High School
Roosevelt High School
Washington High School
New Technology High School
Edison Middle School
George McGovern Middle School
Memorial Middle School
Patrick Henry Middle School
Whittier Middle School
Anne Sullivan
Challenge Center
Cleveland
Discovery
Eugene Field A+
FIC at Jane Addams
Garfield
Harvey Dunn
Hawthorne
Hayward
Horace Mann
Jefferson
John F. Kennedy (JFK)
John Harris
Laura B. Anderson
Laura Wilder
Longfellow
Lowell
Mark Twain
Oscar Howe
Renberg
Robert Frost
R.F. Pettigrew
Altruria Elementary School
Arlington Elementary School
Bailey Station Elementary School
Barret’s Elementary School
Bartlett Elementary School
Bon Lin Elementary School
Collierville Elementary School
Crosswind Elementary School
Dexter Elementary School
Dogwood Elementary School
Donelson Elementary School
Ellendale Elementary School
Farmington Elementary School
Germantown Elementary School
E. A. Harrold Elementary School
Highland Oaks Primary School
Highland Oaks Elementary School
Jackson Elementary
E. E. Jeter Elementary School
Lakeland Elementary School
Lucy Elementary School
Macon-Hall Elementary School
Millington Elementary School
Northaven Elementary School
Newberry Elementary School
Oak Elementary School
Rivercrest Elementary School
Southwind Elementary School
Sycamore Elementary School
Tara Oaks Elementary School
Appling Middle School
Arlington Middle School
Bon Lin Middle School
Collierville Middle School
Dexter Middle School
Elmore Park Middle School
Germantown Middle School
Highland Oaks Middle School
Houston Middle School
Millington Middle School
Mt. Pisgah Middle School
Schilling Farms Middle School
Shadowlawn Middle School
Woodstock Middle School
Riverdale School
Lowrance Elementary School
Arlington High School
Bartlett High School
Bolton High School
Collierville High School
Germantown High School
Houston High School
Millington Central High School
Southwind High School
Brogden Primary
Carver Elementary
Carver Heights Elementary
Eastern Wayne Elementary
Fremont Stars Elementary
Grantham Elementary
Meadow Lane Elementary
North Drive Elementary
Northeast Elementary
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Rosewood Elementary
Spring Creek Elementary
Tommy’s Road Elementary
Brogden Middle
Dillard Middle
Eastern Wayne Middle
Grantham Middle
Greenwood Middle
Mount Olive Middle
Norwayne Middle
Rosewood Middle
Spring Creek Middle
Charles B. Aycock High
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Goldsboro High
Rosewood High
Southern Wayne High
Spring Creek High
Wayne Early/Middle College High School
Wayne School of Engineering
Edgewood Community Developmental School
Wayne Middle/High Academy
Thomas Horace Rogers School
Gregory Lincoln Education Center
Briarmeadow Charter School
Garden Oaks K-8 School
The Rusk School
Wharton Dual Language Academy
Wilson Montessori School
Billy K. Reagan K-8 Educational Center
The Rice School
Harper Alternative School
Jane Long Academy
Sharpstown International School
Leader’s Academy High School for Business and Academic Success
Bellaire High School
César E. Chávez High School Heights High School
Sam Houston High School
Mirabeau B. Lamar High School
Westbury High School Westside High School
Stephen F. Austin High School
James Madison High School
Charles H. Milby High School
Northside High School
North Forest High School
Ross Shaw Sterling High School
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School Houston Academy for International Studies
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High School for the Performing and Visual Arts
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Soar Center
William A. Lawson Institute for Peace and Prosperity
Preparatory Academy for Boys
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