Yes. FERPA requires recordkeeping on requests for access to and disclosures of education records. See § 99.32. Thus, if a school discloses education records to the Child Welfare Agency (CWA) or tribal organization under this exception, the school must be compliant with the recordation requirements under FERPA and also must include: (1) the parties who have requested or received PII from the education records, and (2) the legitimate interests the parties had in requesting or obtaining the information. If an educational agency or institution discloses PII from education records with the understanding that further disclosures will be made, the educational agency’s or institution’s record of disclosure must include the names and legitimate interests of the additional parties.
K-12 School Officials
Exceptions - Uninterrupted Scholars Act