Under FERPA, may an educational agency or institution disclose education records to any of its employees without consent?

Under FERPA, may an educational agency or institution disclose education records to any of its employees without consent?

No.  FERPA permits an educational agency or institution to disclose, without consent, personally identifiable information from students’ education records only to school officials within the educational agency or institution that the educational agency or institution has determined to have legitimate educational interests in the information. 34 CFR § 99.31(a)(1).  Generally, a school official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibility.