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Ask the FERPA Professors

September 15, 2025
  • Dual Enrollment
  • FERPA
  • Registration & Records
  • Family Educational Rights and Privacy Act
  • FERPA
  • FERPA Professor
  • privacy

Dear FERPA Professors,

We have a growing population of students who are attending our community college full-time while completing their senior year of high school. All the students are full-time here and are under 18. They are known as "concurrent students" because they are enrolled in both this institution and the local high school.

Under FERPA, these students are covered because they are enrolled in a postsecondary institution; however, in this case, they are enrolled in both high school and our community college.  

Should we require these students to complete the authorization? Or are their parents automatically allowed access to their education records at our community college? Again, these students have not yet graduated from high school; they will graduate based on the completion of the year at our community college.

Your advice will be appreciated. 

Regards,

Connie Currant


Dear Connie Currant,

FERPA rights transfer to the student when the student attends a postsecondary institution at any age.  Thus, giving access to the parents would require a written consent from the student or meeting the requirement of § 99.31(a)(8), the dependent student exception. 

If the students are dual enrolled, your community college could share the records with the students' attending high schools without a signed consent. See § 99.34(b) of the FERPA regulations.  

I hope this is helpful in answering your questions. You can find the above cited regulations on pages 161 and 165 of the .

The FERPA Professor

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