1. Overview
The Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and its regulations at 34 CFR Part 99 protect the privacy of student education records. FERPA applies to Institutions, not directly to software providers, and there is no FERPA certification. Grad-Tracker is designed so that Institutions can use it consistently with their FERPA obligations.
2. Grad-Tracker as a school official
Under 34 CFR § 99.31(a)(1)(i)(B), an Institution may disclose education records to an outside service provider as a "school official" if the provider performs an institutional service the Institution would otherwise use employees for, is under the Institution's direct control with respect to the use and maintenance of education records, and is subject to the rules on use and redisclosure of personally identifiable information in § 99.33(a). Here is how Grad-Tracker supports each condition:
- Institutional service: Grad-Tracker performs functions career services, institutional research and alumni relations staff would otherwise do, such as collecting graduate outcomes, running outcome surveys and reporting.
- Direct control: the Institution decides what data is collected, which staff can access it by role and department, and what retention settings apply. It can export or delete its data, and we use its records only to provide the service under its direction and our customer agreement.
- Use and redisclosure: we do not sell education records or use them for advertising or to train artificial intelligence models, and we do not redisclose them except to service providers needed to operate Grad-Tracker under confidentiality obligations, as the Institution directs, or as required by law.
Institutions should describe the criteria for who qualifies as a school official in their annual FERPA notification.
3. Safeguards
- Hosting on Microsoft Azure in the United States, with encryption in transit and at rest.
- Each Institution's data kept separate from every other Institution's.
- Role-based access with department-level scoping, so staff see only the records they are responsible for.
- An audit log of changes, and a review step before survey responses update a record.
- Data retention settings and export tools controlled by the Institution.
4. Alumni records
Under 34 CFR § 99.3, records created or received after an individual is no longer a student in attendance, and not directly related to their attendance as a student, are not education records. Some post-graduation information in Grad-Tracker, such as later employment outcomes, may fall into that category, while records carried over from a student's time in attendance generally do not. Whatever the classification, Grad-Tracker protects all Institution Data with the same safeguards.