# School-official exception review

An invented district considers a vendor for administrative drafting with student-record excerpts. Its proposed terms leave several required conditions unestablished.

Synthetic district, vendor and terms. No real FERPA exception, contract or institutional approval is determined.

Source: https://aona.ai/resources/guides/ferpa-ai-school-official-exception/
Sources checked: 2026-09-21

## Four checks before relying on the exception

### Function

A defined institutional task

### Control

Use and maintenance under school control

### Restrictions

Permitted use and onward disclosure

### Access

Legitimate interest and notice criteria

| Condition | Fictional evidence | Outcome or next step |
| --- | --- | --- |
| Institutional service or function | The school describes a limited administrative drafting task normally handled by employees. | Record that exact task; do not extend the scope to unrelated vendor uses. |
| Direct control | The proposal gives the vendor broad reuse discretion and no demonstrated school control over record maintenance. | Condition is not established in this case; resolve the arrangement before disclosure. |
| Use and redisclosure | Onward access by a connected service is not explained. | Identify recipient and purpose restrictions under the applicable rules. |
| Annual notice criteria | The district’s actual notice criteria have not been compared in the example. | Check school-official and legitimate-interest criteria with the institutional owner. |
| Access limitation | Only the assigned team needs the specific administrative record. | Define users, records and feature permissions; a whole-school licence is insufficient evidence. |
| Illustrative decision | Required direct-control and onward-use facts remain unresolved. | Do not send student records on this route based on the school-official exception yet. |

## Review checklist

- [ ] Name the institutional task
  Explain which service the school would otherwise use employees to perform.
- [ ] Review enforceable control
  Document actual terms and procedures for use, maintenance and onward disclosure.
- [ ] Match interest and access
  Apply the annual-notice criteria and limit the feature to the users and records needed.

## Included example files

- ferpa-ai-school-official-review.md
- ferpa-ai-school-official-review.csv

## Source references

- US Department of Education: FERPA regulations: https://studentprivacy.ed.gov/ferpa (2026-09-21)

Use the worksheet within the relevant legal, contractual and technical scope. It is not a certification or a record of an installed-product test.