Must the Child Welfare Agency (CWA) or tribal organization record any redisclosure of personally identifiable information (PII) from education records made by the welfare agency or tribal organization to an individual or entity?

No.  FERPA does not require the CWA or tribal organization to record any redisclosure of PII from education records that it may make to an individual or entity, such as a contractor providing services to address a student’s education needs.  However, if the CWA or tribal organization does redisclose PII from an education record on a student in foster care placement to anyone other than an agency- or organization-employed caseworker or other representative who has the right to access a student’s case plan, the Department recommends, as a good data management practice, that the CWA or tribal organization record the redisclosure and inform the school of the redisclosure for record keeping purposes.