Requests from Third Parties. The general rule is that Confidential Student Information cannot be released to third parties without written consent from a parent or legal guardian. There are, however, exceptions. Confidential student information may be disclosed without consent in response to a request from: • Officials at private schools and in other school systems where a student intends or seeks to enroll; • Agencies or organizations requesting information in connection with a student’s application for, or receipt of, financial aid (but only as may be necessary to determine the student’s eligibility for financial aid, the amount of the financial aid, the conditions that will be imposed in connection with the financial aid, or to enforce the conditions of the financial aid); and • County elections officials, only for the purpose of identifying students who are eligible to vote and conducting programs offering students the opportunity to register to vote. Among third parties with whom the District will share Confidential Student Information without consent are vendors who are either performing services normally performed by District employees or are conducting studies to improve instruction. In these cases the District will enter into a Data Use Agreement with such vendors. Examples of such Data Use Agreements are provided in Attachments A-3 and A-4. The District may provide aggregate and statistical data to third parties where such data is not personally identifiable to any individual student. Under FERPA, the definition of personally identifiable information includes “any set of facts that makes a student’s identity easily discernable.” Therefore, the demographic break down of the student population from which the data is extracted and the size of the pool of students used for such data analysis must be taken into consideration and care must be taken so that it is not easy to discern any individual student’s identity. Further, no information that could be used to identify a student, such as student identification number, address, telephone number or social security number may be included. For all other requests from third parties, consent must be obtained before Confidential Student Information may be disclosed. All questions about disclosing Confidential Student Information to a third party, or about the manner in which consent must be obtained, should be referred to the Office of General Counsel as quickly as possible after receipt of any request.
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