Are there any limitations to sharing information based on personal knowledge or observations?

FERPA applies to the disclosure of personally identifiable information (PII) from education records that are maintained by the school.  Therefore, FERPA does not prohibit a school official from releasing information about a student that was obtained through the school official’s personal knowledge or observation unless that knowledge is obtained through his or her official role in making a determination maintained in an education records about the student. For example, under FERPA a principal or other school official who took official action to suspend a student may not disclose that information, absent consent or an exception under § 99.31 that permits the disclosure.

K-12 School Officials
Postsecondary School Officials