Know how to handle requests, refusals for internal disclosures of records

Internal disclosures of education records tend to be potentially more contentious than external disclosures to third parties outside one's own institution. Whether to disclose internally is governed by the “school official/legitimate educational interest” regulation found at 34 CFR §99.31 (a) (1). This regulation requires two conditions before you can disclose an education record. First, the disclosure must be to a school official who has been identified in the institution's annual Family Educational Rights and Privacy Act notification. Second, the school official must demonstrate a legitimate educational interest in your disclosing the record. In other words, the official must give a reason as to why she needs to see a record.