No. Regardless of whether the community-based organization received the PII under the school official, studies, or audit/evaluation exception, the answer is the same – the community-based organization may not redisclose it unless such redisclosure is on behalf of the disclosing entity and is consistent with FERPA. (34 CFR § 99.33). If further redisclosure is contemplated, we recommend that provisions addressing authorized redisclosures be included in any agreement with the community-based organization.
K-12 School Officials
Community Based Organizations