Under FERPA, what triggers the requirement for written consent to disclose student records?

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Written consent is generally required to disclose a student’s education records to someone outside the institution. But there are several FERPA exceptions that let disclosures happen without written consent. The trigger for needing consent is when none of those exceptions apply. For example, disclosures to school officials with legitimate educational interests inside the district, transfers to another school for enrollment, or sharing directory information after proper notice are permitted without consent. Disclosures in health or safety emergencies, in response to a court order or subpoena, or to researchers under confidentiality protections are other permitted without prior consent. Because FERPA includes these exceptions, the blanket statement that disclosures are never permitted without consent isn’t accurate.