What is FERPA? What it means for school staff using AI with gradebooks and class lists

FERPA is the US federal law on the privacy of student education records. This guide explains what it is and what rights it gives, what it counts as identifying, what to leave out of a gradebook or class list before using an AI tool, and why a small class needs extra care.

You have a quiz export, a gradebook or an attendance list. You suspect that an AI assistant could show you in a minute what would take an evening: which topics the class missed, who has slipped since October, how the scores of two sections compare.

That is a reasonable thing to want. It also involves records about children or young adults, held by a school, which US law treats with care. This guide explains how the federal student privacy law, known as FERPA, describes identifying information, what an analysis of a class file really needs, and how to prepare the file. It is written for US teachers, and other countries have their own rules.

Key terms

FERPA: the Family Educational Rights and Privacy Act of 1974, the US federal law on the privacy of student education records.
Eligible student: a student who is 18 years old or older, or who attends a school beyond the secondary level. FERPA rights that belong to parents pass to an eligible student.
Education records: records that relate directly to a student and are kept by a school or by someone acting for it.
Personally identifiable information: FERPA's term for information that identifies a student directly or in combination with other facts.
Directory information: information that a school has designated as something it may release without consent, such as a name or a grade level. Families may opt out.
Stand-in: a made-up label used in place of a real name, such as STUDENT_07.

What is FERPA, and what rights does it give?

FERPA is a federal law that ties duties about student records to federal education funding. It applies to a school, district or university that receives money under the federal programs it covers. The law says that no federal funds are to be made available to such a school if it has a policy of denying parents access to their children's education records, or of releasing them without consent outside the listed exceptions.

The law gives parents, and eligible students themselves, three main rights.

To inspect and review the education records the school keeps about the student. The school must grant a request within a reasonable time, and in no case more than forty-five days after the request.
To ask for a hearing to challenge the content of the records, so that inaccurate or misleading information can be corrected or deleted.
To consent before the records are released, with the exceptions listed in the law. See the next sections.

The school must also inform parents, or eligible students, of these rights. Your school's own policy on student records and AI tools comes first.

What does FERPA count as identifying?

The federal regulations list what personally identifiable information includes. Among the items are the student's name and the names of the student's parents or other family members. Others are the address of the student or family, a personal identifier such as a student number, and indirect identifiers such as the date of birth, the place of birth and the mother's maiden name.

The list ends with two broader items. One covers other information that, alone or in combination, is linked or linkable to a specific student. It counts if it would allow a reasonable person in the school community, who does not have personal knowledge of the circumstances, to identify the student with reasonable certainty. The other covers information requested by someone the school reasonably believes knows the student's identity.

The broader items matter for spreadsheets. A file with no names can still identify a student to classmates, parents or colleagues. A column that says "Accommodation: extended time" in a class of fourteen may point to one student, and everyone in the room may know which one.

Who may receive student information?

In outline, the law says that a school may not have a policy or practice of releasing education records, or personally identifiable information from them, without written consent from the parents, with listed exceptions. When a student turns 18 or attends a postsecondary institution, the rights and the consent pass from the parents to the student. One exception covers other school officials, including teachers, whom the school has determined to have a legitimate educational interest. Another covers directory information, which a school must announce and which families may refuse.

The law was written before AI assistants. It does not say whether a given AI service counts as one of the exceptions, and a teacher cannot decide that for the school. In practice, schools and districts decide which tools staff may use for student information, and many publish a list or a policy. Look for yours first, and ask the person responsible for student privacy if you cannot find it.

What does an analysis of a class file need?

Write the question first. "Which standards did most students miss on the unit test?" needs the question-level scores and nothing about who the students are.

Question	Often needed	Usually not needed
Which topics did the class miss?	Question or standard, points earned, points possible	Names, student numbers, birth dates, comments
How did scores change over the term?	A stand-in for each student, assignment, date or month, score	Names, parent contacts, addresses
Do two sections differ?	Section, assignment, score	Names, ID numbers, accommodation notes
Who may need extra help?	A stand-in, scores over time, attendance totals	Names, behavior notes, health or family information

Which columns should come out of a gradebook or class list?

Names and contact details: student, parent and guardian names, email addresses, phone numbers, home addresses.
Numbers that identify: student ID, state ID, lunch or account numbers, login names.
Birth dates and places of birth. An age band or a grade level is usually enough.
Comments and notes. Teacher comments name students, families and events.
Support and services information: special education, accommodation, language-learner, free or reduced-price lunch or counseling flags. If the question truly needs one of them, treat it as the most sensitive column in the file and ask your privacy contact first.
Hidden parts of an Excel file: hidden sheets, comments and the document properties that carry your name. See hidden data in Excel files.

Why does a small class need extra care?

Because the group that can recognize a student is the class itself. In a section of fourteen, one low score, one absence total or one flag may be enough for everyone to know who it is. When you ask a question about a few students, the answer can identify them even if the file holds only stand-ins.

Ways to reduce the problem:

Ask for group-level answers, such as an average for the section or a count of students above a line, and not a list of individual results.
Use bands in place of exact values, such as a score range or a month in place of a day.
Combine small groups before you analyze them.
Leave out the one student who is unlike the others if the question does not need that student.

See why removing names is not enough for a way to count how many students share each combination of values.

How can you keep track of who is who?

Give each student a stand-in, the same one every time the student appears in the file, such as STUDENT_07. The assistant can then compare one student's scores across assignments without knowing who the student is. When it answers "STUDENT_07 improved most", you look up the name on your own computer. See replacing real names with consistent stand-ins and putting the original values back after an AI answers.

Keep the list of stand-ins out of the file you share and out of any folder the class can see. Anyone who holds it can undo the protection.

How can DataAttendant help?

DataAttendant is a tool that runs in your web browser, on your own computer. You open a CSV or Excel file exported from your gradebook, and it looks for names, email addresses, phone numbers, birth dates, postal addresses and other personal details by the values in a column and by its heading. It proposes what to do with each, such as replacing names with stand-ins, and shows a preview and a list of what remains before you download the protected copy. You decide every treatment, and you can save your choices as a reusable plan for the next export. It cannot find everything, and it does not decide whether a service is approved by your school. Your file is processed in your browser and is not sent to DataAttendant. How DataAttendant works shows the steps.

Sources

34 CFR § 99.3 (definitions of personally identifiable information, education records, directory information and eligible student), read on law.cornell.edu on 28 October 2026.
20 U.S.C. § 1232g (FERPA), read on law.cornell.edu on 28 October 2026. Subsections (a)(1)(A), (a)(2), (a)(3) and (e) cover the rights to inspect, to a hearing and to be informed, and the educational institutions the law reaches. Subsection (a)(5) covers directory information. Subsections (b)(1) and (b)(2) cover the release of education records and the exceptions, including school officials with legitimate educational interests. Subsection (d) covers the rights of students aged 18 or in postsecondary education.
Your own school's or district's policy on AI tools and student information is not covered here.