FERPA Do’s & Don’ts for The Early Signal Project
Protecting student privacy while delivering early intervention insights
The Early Signal Project is built on a powerful idea: use data to help students before they fall behind emotionally or academically. But with great data comes great responsibility. That’s where FERPA, the Family Educational Rights and Privacy Act, comes in.
DO: Respect Student Privacy Rights
1. Treat Educational Records as Protected Assets
FERPA defines educational records as any data directly related to a student and maintained by a school. This includes grades, attendance, behavior logs, and even survey responses. Handle these with care.
2. Use De-Identified Data Whenever Possible
Strip names, student IDs, and other personally identifiable information (PII) before analysis. Use randomized keys (e.g., StudentKey) and avoid storing full ZIP codes, birthdates, or combinations that could re-identify students.
3. Get Written Consent for Non-Routine Data Use
Obtain parental or student consent. Keep it simple, transparent, and opt-in.
4. Limit Access to Authorized Personnel
Only designated project leads, IT staff, and school officials should access sensitive data. Use role-based permissions and multi-factor authentication to protect our systems.
5. Secure Data at Rest and In Transit
Encrypt databases (AES-256) and use secure protocols (TLS 1.2+) for data transfers. FERPA doesn’t mandate specific technologies, but it expects “reasonable methods” to safeguard student information.
6. Create a Data Retention & Destruction Policy
Keep raw data only as long as needed. FERPA encourages timely deletion of sensitive records. For example:
- Raw files: delete after 6 months
- Anonymized data: retain up to 2 years for longitudinal analysis
DON’T: Share or Publish Identifiable Student Data
1. Don’t Share PII Without Consent
Even well-intentioned sharing (e.g., with volunteers or external researchers) is a violation unless consent is obtained or data is fully anonymized.
2. Don’t Assume Aggregated Data Is Always Safe
Use suppression rules (e.g., hide data for groups <5 students).
3. Don’t Store Sensitive Data in Unsecured Systems
Avoid using personal Google Drives, unencrypted spreadsheets, or public cloud folders. Always use secure, school-approved platforms.
4. Don’t Ignore Breach Protocols
If data is exposed or mishandled, FERPA requires prompt notification. Have an incident response plan ready: who to contact, how to contain, and how to report.
5. Don’t Use Data for Non-Educational Purposes
FERPA restricts data use to legitimate educational interests. That means no marketing, fundraising, or unrelated analysis—even if anonymized.
Final Thought: Privacy Is Trust
FERPA isn’t just a legal framework, it’s a trust contract between schools, families, and organizations like ours. By following these Do’s & Don’ts, The Early Signal Project can deliver life changing insights while honoring the dignity and privacy of every student.
Early Signal Project 