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Does FERPA regulate student publications and exclude them from being digitized?

Submission Date
Question

We received two grant applications for projects involving the digitization of high school student newspapers/magazines. The schools have given permission for these materials to be made available on a historic resource-focused, free database.

When our board was reviewing these grant applications, it was brought up that sharing student publications may not be possible under FERPA regulations. The board was concerned that these student publications might be considered educational records, which under FERPA would be subject to restricted access. If FERPA applies to these materials, they could not be uploaded and made accessible via an online database, and consequently would not be eligible for grant funding.

Does FERPA regulate student publications? Are there any other legal reasons student could not be made available freely in an online repository?

Thank you!