What “FERPA-safe AI” has to mean before anyone says it
By The Corra team · · 2 min read · Privacy
FERPA — the Family Educational Rights and Privacy Act — governs education records held by schools that receive federal funding, and it does not issue certifications, which means no vendor can be "FERPA certified" no matter how the badge is drawn. What a tool can do is fit the specific exception that lets a school share records with an outside service at all, and that exception has conditions worth knowing.
The school-official exception, in plain terms
FERPA generally requires consent before a school discloses personally identifiable information from education records. The school-official exception allows disclosure without consent to an outside party performing a service the school would otherwise do itself — provided that party is under the school’s direct control regarding the use of the records, uses them only for the authorised purpose, and does not redisclose them.
- The service must be one the school would otherwise perform in-house.
- The provider acts under the school’s direction, not on its own purposes.
- The records may not be redisclosed or reused for anything else.
- The school decides who has a legitimate educational interest — not the vendor.
Where a general-purpose chatbot falls down
Pasting a student’s essay and name into a consumer chatbot is a disclosure to a third party, and the conditions above have to be met for it to be permissible. Consumer AI products are generally not set up as a school’s service provider, may use conversation content to improve their models depending on the plan, and are not under any school’s direction. That does not make them evil; it makes them the wrong container for an education record.
The questions worth asking any AI tool
Five questions separate a serious answer from a marketing one, and a vendor that cannot answer them quickly probably has not thought about it.
- Does identifiable student information reach the model provider at all, and if so, which fields?
- If you de-identify, does that happen on your server or in my browser — and can it be skipped?
- Is our data used to train models, and is that guaranteed by contract rather than by a blog post?
- Where is the data stored, and who else can read it?
- Can I delete everything myself, and what survives that deletion?
How Corra answers them
Identifiers do not reach the model provider: names, family contacts and roster identifiers are replaced with placeholder tokens on our Cloudflare Workers edge before the request leaves, and restored in your browser afterwards. Because the substitution is server-side it cannot be skipped by the client. Our AI requests run on the OpenAI API, which states that API data is not used to train its models. Storage is a single United States region, and account deletion is self-service and immediate. The privacy policy lists every processor by name, including the ones that are switched off.
The part that is still your responsibility
No tool can grant you permission to use it. Districts differ enormously in what they have approved, and some require a signed data-privacy agreement before any student information goes into a third-party product. Corra records your acknowledgement of that during onboarding because it is a real obligation, not a checkbox — and it sits with you and your district, not with us.
Common questions
- Can a vendor be FERPA certified?
- No. FERPA has no certification scheme. A vendor can describe how it fits the school-official exception, and you can check that description, but a certification badge is decorative.
- Is de-identified data still covered by FERPA?
- Properly de-identified data — with direct and indirect identifiers removed such that a student is not reasonably identifiable — falls outside the disclosure restrictions. The care is in doing it thoroughly and in a place the user cannot accidentally bypass.
- Does my district still need to approve Corra?
- Quite possibly, and only your district can tell you. Corra is bought by individual teachers, which does not remove your district’s rules about third-party tools.