Defense · FERPA
FERPA for defense AI workflows
FERPA in defense AI workflows: what compliance requires, who asks for evidence, and the records to keep.
01 / The rule
What FERPA requires
Educational agencies and institutions that receive U.S. Department of Education funds, and outside parties that receive education records from them.
- 01Get written consent before disclosing personally identifiable information from education records, unless a listed exception applies.
- 02Treat an AI vendor as a 'school official' only if it performs an institutional function, under direct school control over use and maintenance of records.
- 03Limit vendors' use and redisclosure of records to the authorized purpose (34 CFR 99.33).
- 04Use reasonable methods so school officials, including vendors, access only records with a legitimate educational interest.
- 05Publish an annual notice of rights stating the criteria for who counts as a school official and legitimate educational interest.
02 / In this sector
In a defense AI workflow
AI tutors, grading tools and analytics platforms that receive student records usually rely on the school-official exception, so the school must keep direct control over how the vendor uses the data. A vendor reusing records for its own purposes, such as training general models, falls outside the authorized purpose unless consent or another exception covers it.
Program office leads and ATO-package owners.
NIST AI RMF · DoW RAI · OMB M-25-21.
03 / Records
Records to keep
- 01Vendor contracts with school-official, use-limit and deletion terms
- 02Annual FERPA notice defining school officials
- 03Record of disclosures kept under 34 CFR 99.32
- 04Access-control settings and data deletion confirmations from vendors
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
SOURCES
Go back to the source
Legal Information Institute (Cornell)
Legal Information Institute (Cornell)
U.S. Department of Education, Privacy Technical Assistance Center
RELATED
Related: FERPA: the full guide · FERPA for medicine · FERPA for law · FERPA for education