If the school does not list one or more of the three data elements (e.g., telephone number) among its directory information, may it release that information to military recruiters?

If the school does not list one or more of the three data elements (e.g., telephone number) among its directory information, may it release that information to military recruiters?

If a school does not designate one or more of the three items as “directory information” under FERPA, it still must provide all three items to military recruiters upon request.  Also, in that case, the school would have to send a separate notice to parents about the missing “directory information” item(s), noting an opportunity to opt out of disclosure of the information to military recruiters.  An easier method, of course, would be for the school to designate all three items – name, address, and telephone listing – as “directory information.”