Disclosures 14: Do you have to keep records of disclosures? Two instances

Last month, we took a look at FERPA's recordkeeping requirements when we make a disclosure of education records. Those requirements are found at 34 CFR §99.32. It is clear from §99.32 that you do not have to make a record of every education record disclosure we make. This recordkeeping requirement depends on (1) why the education records are to be disclosed (the legitimate interest) and (2) to whom the disclosure is made.