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Dear FERPA Professors,
I wanted to request your feedback or any suggestions on the timing of our annual notification to students. We have several part-of-term and enrolled students who could best be described as registering on an almost rolling basis.
At the university, we have established a notice that is sent to every student as they register, which includes several consumer notices. The first one on the list is FERPA. It provides a brief introduction and a link to our university's FERPA page, which contains all the necessary information for students. Given that students register at various times, I wanted to confirm with you that this would satisfy our required annual notification.
Regards,
Reg Rolling
Dear Reg Rolling,
The University's means of notifying students of their FERPA rights appears to meet the notification requirements of FERPA. This is because you notify all incoming students of these rights at the time they register at the University.
Because FERPA requires that this notice be done at least annually, you would also want to do the general notification you mention at the beginning of each long semester to those students who are now in attendance at the University. You can review the annual notice requirements at § 99.7 of the FERPA regulations.
The FERPA Professor
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