What this policy does
Redacts personally identifiable information from student educational records as defined by the Family Educational Rights and Privacy Act (FERPA) — the federal law governing disclosure of student records by schools that receive federal funding.
This policy targets the PII fields that identify a specific student:
- Student names — redacted to
[STUDENT](confidence-gated to avoid misfires on school names, building names, and common nouns) - Birthdates — fully redacted when the date appears in a birth-related context
- SSNs — fully redacted (rare in modern student records but still appears in older systems and financial-aid forms)
- Phone, email, address — redacted (student or parent contact information)
- Student IDs — redacted with a custom identifier pattern (default matches
SID 887623,Student-ID: 887623, etc.) - Lunch/meal program IDs — redacted (these are educational-record-linked identifiers under FERPA)
It preserves the educational substance: grades, course names, term/semester references, narrative observations, attendance summaries. Those are the records’ actual content; you usually want them for the analytical or operational purpose the redacted records are being used for.
When to use this
- Sharing data with external evaluators or researchers (school districts running effectiveness studies with university partners)
- Inter-district transfers of de-identified cohort data for benchmarking
- Reporting to state education agencies where the requested record doesn’t need to be student-linkable
- EdTech vendor data sharing under written consent or under FERPA’s school-official exception
- Internal analytics across schools where the analytics team shouldn’t have access to identified records
When to customize
- Directory information. FERPA permits schools to disclose certain “directory information” (typically name, address, phone, dates of attendance, photographs, awards, participation in officially recognized activities) without consent — provided parents/students have been notified annually and given the opportunity to opt out. If you’ve collected directory-information opt-outs and want a less-aggressive variant for the opt-in records, remove the
personsNameandaddressentries (or build a parallelferpa-directory-allowed.jsonpolicy). - Student ID format. The default regex matches
SID 887623,Student ID: 887623with 6+ digits. Replace with your district’s actual format (state IDs, federal IDs, or proprietary SIS identifiers). - Confidence threshold.
> 60for names is moderate. School records have many proper nouns (school names, building names, district names, sports teams) that Philter can occasionally misclassify as personal names. Raise to> 75if you see false positives. - Parent/guardian names. Not separately tagged — they get caught by
personsNamelike any other name. If your use case treats parent contact info differently (e.g., emergency outreach preserved, marketing redacted), build a custom variant. - Special-education and IEP records. These often contain additional sensitive content (disability diagnoses, medical history, behavioral observations) that go beyond standard FERPA PII. Pair this policy with a healthcare/PHI policy when redacting IEP narratives.
Compliance notes
- FERPA applies to schools that receive funding under any program administered by the U.S. Department of Education — K-12 public schools, charter schools, post-secondary institutions, and certain private schools.
- “Educational records” are interpreted broadly: grades, transcripts, disciplinary records, counseling notes, special-education records, financial-aid records, attendance, and most narrative records maintained by school officials.
- Schools must obtain written consent from parents (or the student, once age 18 or attending post-secondary) before disclosing PII from educational records — subject to specific exceptions (school officials with legitimate educational interest, other schools the student is transferring to, audit/evaluation, etc.).
- This policy redacts PII fields, but does not by itself constitute de-identification under FERPA’s standards (34 CFR 99.31(b)). True de-identification under FERPA requires a “reasonable determination” that a student’s identity is not personally identifiable, considering all available information. Statistical evaluation is recommended for records shared as de-identified.
- State laws (e.g., the California Student Online Personal Information Protection Act — SOPIPA) may impose additional or stricter requirements. This policy is FERPA-baseline.