Dear Mr. Ethics,
Our college's football coach called to ask me for some information from a particular student's FAFSA. The coach wants to use the information to help determine what might be a competitive athletic scholarship offer for the student. The student provided us with a signed release form; does that mean it's OK for us to share their personal data with others in our institution?
Sharing is Caring
You're right to be cautious. According to NASFAA's Statement of Ethical Principles, financial aid professionals must protect the privacy of financial aid applicants, which includes:
Since the coach would be using the FAFSA data for the purpose of awarding institutional aid, this request appears to comply with the HEA data sharing provisions. However, even when FAFSA data being shared with a campus office is for the application, awarding, and administration of federal, state, or institutional aid, FERPA requirements still must be met. In this limited scenario, students’ education records could be disclosed to a coach if the school defined those officials as school officials with a legitimate educational interest in those records under 34 CFR 99.7 of the FERPA regulations. Financial aid administrators should also take care to release the minimum amount of information that is necessary for the other campus office to base its decisions.
You should contact your school's legal counsel if you need assistance in making either of the above determinations. You can also contact ED’s Privacy Technical Assistance Center (PTAC) with additional questions.
Publication Date: 5/20/2015