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History of FERPA��

The Family Educational Rights and Privacy Act (FERPA), also known as the Buckley Amendment, was enacted by Congress in 1974 as part of the Education Amendments of 1974 and signed into law by President Gerald Ford. Sponsored by Senator James L. Buckley of New York, the law responded to growing concerns in the early 1970s about the privacy of student records and the lack of clear rights for parents and students to inspect or control the release of those records.��

FERPA established two core principles: (1) the right of parents (and eligible students) to access and seek amendment of education records, and (2) the requirement that schools obtain documented consent before disclosing personally identifiable information from those records, subject to limited exceptions. Once a student turns 18 or enrolls in a postsecondary institution, the rights transfer from the parent to the student.��

The law applies to educational agencies and institutions that receive funds under any program administered by the U.S. Department of Education. Over the decades it has been refined through regulations and amendments, but its fundamental purpose—protecting the privacy of student education records while balancing legitimate educational and administrative needs—has remained consistent.��

Protecting Student Information (FERPA) When Documenting Purchases��

FERPA protects the privacy of student education records and the information within such records. FERPA defines “student education records” broadly as "records that are directly related to a student and that are maintained by an educational institution,” and for example include records such as student-related academic records, health records, and records with student financial information. When purchase documentation—receipts, Concur justifications, official function forms, invoices, participant payment logs, and similar records—includes student names, student IDs, or other identifiers, those records can become education records subject to FERPA. Broader access within financial systems means we need extra care to limit unnecessary personally identifiable information (PII) and restrict further disclosure.��

Here is practical guidance for minimizing and protecting student PII information while still meeting fiscal accountability and audit requirements.��

Minimize student PII by default��

Include only the information required for business justification and audit. Prefer aggregate descriptions whenever possible—for example, “12 undergraduate research assistants – Chemistry lab supplies” or “15 students – departmental recognition event.” Existing official-function practice already supports this approach: names and affiliations for groups under roughly 10 people; group counts for larger groups. Extend the same principle to other documentation.��

Do not include diagnoses, treatment details, procedure codes, medication information, or other clinical content in Concur expense reports, Marketplace vouchers, invoice comments, or attached files. Use only the minimum necessary information (amount, date or period of service, proof of payment, and high-level business purpose). Store more detailed records, if required for departmental files, outside the Concur and Marketplace systems and share them only with individuals who have a legitimate educational interest or documented fiscal/audit need. System access alone does not equal legitimate educational interest for student health information.��

When individual names are necessary��

Limit the information to the student’s name (and affiliation if needed for justification). Avoid student ID numbers, email addresses, phone numbers, academic status details, or other identifiers unless specifically required by policy or sponsor terms. Treat the resulting documentation as containing FERPA-protected information. Store and share it only with individuals who have a legitimate educational interest or legitimate fiscal/audit need to do their work for the university. Redact student names and identifiers before circulating documents beyond the immediate approval chain or attaching them to broadly accessible shared drives.��

Watch for higher-risk situations��

These include official functions and events with student attendees, research subject or participant payments, student travel or team-related expenses, supplies or services purchased for named student projects or theses, and any invoice or packing slip that lists student names.��

Access and retention��

Do not post or leave unsecured lists containing student names. Securely dispose of paper or electronic files containing student PII once retention requirements are met. If a document must be shared externally (sponsor, auditor outside the normal chain, etc.), consult the Office of the Registrar first when student identifiers are present.��

Students who have elected full privacy status require additional caution. When in doubt, treat the information as protected and limit both the amount of detail recorded and the circle of people who see it.��

Questions? Reach out to the Campus Controller’s Office fiscal compliance team.��

For more information on FERPA, see the Office of the Registrar site.��