FERPA was written before cloud computing existed. Here's how institutions can meet their legal obligations while modernizing their technology infrastructure.
Cloud Architecture and FERPA
Cloud-first architecture is compatible with FERPA, but it requires deliberate design choices. Data residency matters. Access controls need to be granular enough to implement FERPA's disclosure restrictions. Audit logging needs to be comprehensive enough to respond to student access requests.
Vendor Management
Due diligence on vendor FERPA compliance is one of the most important and underperformed compliance activities at educational institutions. Every vendor touching education records must qualify as a "school official" under FERPA's legitimate educational interest exception.