**FERPA’s Recordkeeping Requirement (34 CFR § 99.32)**

We informally

contacted eight school officials

– three officials at elementary /secondary school districts and one official at an elementary school and four officials at postsecondary institutions. M ost of the schools we contacted use a paper

- based s ys tem for recordkeeping, while some of the postsecondary institutions use both paper

- based and electronic. From our informal review, it is clear that the recordkeeping is done at the individual school (as opposed to the school district at the elementary /secondary

level) and the individual postsecondary

institution. We estimate that an average of .0833 hours (5 minutes) per disclosure is required for the recordkeeping requirement. The average number of di sclosures of individual student records per ye ar is based on responses from the eight school officials. (Based on the t ype and size of the school, the number of releases vary.)

It is not clear that schools recognize that FERPA requires that they record disclosures made of personall y identifiable information from students’ education records to State authorities
, such as when a school discloses personall y identifiable information on all students in attendance to a State education department on the element ar y/ secondary level or to the State postsecondary

educational authority

on the college level. Without more information on the practices of schools in this regard, it is difficult to accuratel y estimate the specific burden hours for this recordkeeping requ irement

. However, w e assume that many of these schools, especiall y at the postsecondary level and more urban school districts , utilize computerized methods to record disclosures , which would make it less burdensome to record disclosures for large numbers of students. Where there are large numbers of disclosures and no computerized method is used to indicate that a disclosure occurred, FPCO has advised schools that they

may utilize a single notice about the mass disclosure. When a parent or student reques ts access to his or her record of disclosure, the school may provide the notice with the information concerning the disclosure to the parent or student a t the time of the request , thereby

minimizing the burden on the school. However, because these recorda tions are not exempt from FERPA’s recordkeeping requirement, we have included an estimate for the burden of recording disclosures of all students in attendance to State authorities. We estimate that schools must share this information with State officials twice a y ear and estimate that it would take schools 1 hour to either make the recording via their computer sy stem or develop a notation and make it available to parents or students asking to inspect this record. As explained elsewhere, it is our adminis trative experience that few parents and students request to see this record.

F or the general recordkeeping requirement of § 99.32(a) for recordation of individual disclosures
, f

ollowing is a breakdown of individual schools (public elementary , seconda ry , or combined) and postsecondary institutions:

No. of Schools: 97,382 Average No. of Disclosures: x 192 # of Responses 18,697,3442 Hours /Response : x .0833

Burden Hours 1,557,489

No. of Postsec. Inst.: 6,463 Average No. of Disclosures: x 192 # of Responses 1,240,896

Hours /Response : x .0833

Burden Hours 103,367

Elementary

/Secondary

S chool Burden Hours: 1,557,489 Postsec. In st. Burden Hours: + 103,367 Total Burden Hours for recordation of individual disclosures : 1,660,85 6

For the recordkeeping requirement for disclosures of all students in attendance to State educational authorities, following is a b reakdown of individual schools (public elementary
, secondary , or combined) and postsecondary institutions:

No. of Schools: 97,382 Average No. of Disclosures: x 2 # of Responses 194,764

Hours/Response: x 1

Burden Hours 194,764

No. of Postsec. Inst.: 6,463 Average No. of Disclosures: x 2 # of Responses 12,926

Hours/Response: x 1

Burden Hours 12,926

Elementary

/Secondary

School Burden Hours: 194.764 Postsec. I nst. Burden Hours: + 12,926 Total Burden Hours for recordation3 of disclosures of all students : 207,690

**Total Burden Hours for recordation**

**of ind ividual disclosures:**  **1,660,856**

**Total Burden Hours for recordation**

**of disclosures of all students: 207,690** 

**Total Burden Hours for Recordation 1,868,546** 
The number of school districts and the number of postsecondary institutions subje ct to FERPA is based on the number of public school districts and the number of Title I V postsecondary

institutions, as reported in the National Center for Education Statistics’ (NCES’) Digest of Education Statistics. See http://nces.ed.gov/programs/digest/d07/tables/dt07_005.asp . The number of affected schools reported to OMB in previous y ears was higher, but we believe this number that is based on NCES’ count is more accurate.