Must an educational agency or institution have a written agreement to disclose PII from education records without consent for the purposes of conducting a study or an audit or evaluation of an education program?

Must an educational agency or institution have a written agreement to disclose PII from education records without consent for the purposes of conducting a study or an audit or evaluation of an education program?

Yes. Both the studies exception and the audit or evaluation exception specifically require that the parties execute a written agreement when disclosing PII from education records without consent. The mandatory elements of that agreement vary slightly between the two exceptions.  See FPCO’s  Guidance for Reasonable Methods and Written Agreements for more information regarding the mandatory elements for written agreements.