'Disclosing' educational records
http://www.aacrao.org/ferpa_guide/enhanced/disclosure.html --

I think this page gets at the heart of what we were discussing. It's important to understand (see below) that some kinds of personally identifiable info may be designated as directory info (with a few exceptions, like SS#.)

An institution may disclose directory information if it has given students in attendance public notice of:
• what the institution has designated as directory information.
• a student’s right to refuse designation of any or all of their information as directory information.
• the time within which a student must notify the school, in writing, that he or she does not want any or all of the information designated as directory information.

Cal Poly -- Office of Academic Records
http://www.ess.calpoly.edu/_records/stu_info/ferpa.htm -- Good example of web documentation to communicate FERPA issues to students.
Posted at 13:41 #

DIRECTORY and PERSONALLY IDENTIFIABLE information may overlap

Two examples of where current GC practice has these two categories overlapping: The student's name is explicitly listed as personally identifiable info in the AACRAO guide, an e-mail address would also be personally identifiable info, but we also consider it to be directory info.
Posted at 23:06 #

definitions from AACRAO 'FERPA online guide'
http://www.aacrao.org/ferpa_guide/enhanced/terms_content.html --

Personally Identifiable Information:

Includes, but is not limited to:
• The student’s name
• Name of the student’s parent or other family members.
• Address of the student or student’s family.
• A personal identifier, such as a social security number or student number.
• A list of personal characteristics or other information that would make student’s identity easily traceable.

Directory Info is defined to include things like photos. It may explicitly not include: - Student identification numbers, — Social security numbers, — Ethnicity/race/nationality, — Gender
Posted at 22:45 #

AACRAO FERPA online guide
http://www.aacrao.org/compliance/ferpa/index.htm --

Go to the page above, and then click on the link titled "FERPA online guide".

From the Overview (I'm adding the occasional bold emphasis which is not in the original):

The essence of the Act is .... Institutions may not disclose information about students nor permit inspection of their records without written permission, unless such action is covered by certain exceptions permitted in the Act.

From the Student Rights section.... Students have the Right

to have some control over the disclosure of information from education records. This includes the right to ... forbid disclosure of directory information.

Definition of DIRECTORY INFORMATION
http://www.aacrao.org/federal_relations/nrm_ferpa.htm --

From the Amer. Assoc. of Collegiate Registrars and Admissions... We have this summary of an updated definition of 'directory information' included in a 1998 amendment to FERPA:

Directory information. (a)(1) The term means information contained in an education record of a student which would not generally be considered harmful or an invasion of privacy if disclosed. It includes, but is not limited to the student=s name, address, telephone listing, date and place of birth, major field of study, grade level, enrollment status (undergraduate, graduate), full-time/part-time, participation in officially recognized activities and sports, photograph, dates of attendance, degrees, honors and awards received, and the most recent previous educational agency or institution attended.

University of Kentucky
http://www.uky.edu/Registrar/ferpa.html --

They include photos, place/date of birth, dates of attendance, enrollment status and others as 'directory information'

The University of Kentucky assumes that a student's failure specifically to request blocking access to any element of "directory information" constitutes approval for disclosure.