The consent exception is most often used by schools when they contract with educational technology (EdTech) providers that offer online educational services, such as online learning and online assessments.

Under the school official exception, Pll may be granted to a provider, so long as the provider:

• Performs an institutional service or function for which the school or district would otherwise use its own employees.
• Has been determined to meet the criteria set forth in the school's or district's annual notification of FERPA rights for being a school official with a legitimate educational interest in the education records.
• Is under the direct control of the school or district with regard to the use and maintenance of education records.
• Uses education records only for authorized purposes and may not re-disclose PII from education records to other parties.