Ask Mr. Ethics: Can I Share a Student's Personal Data With Other Employees at Our Institution?


The following was reviewed for accuracy and updated on 7/29/2021.



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


Dear SIC:

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: 

  • Ensuring that student and parent private information provided to the financial aid office by financial aid applicants is protected in accordance with all state and federal statutes and regulations, including FERPA and the Higher Education Act, Section 483(a)(3)(E) (20 U.S.C. 1090).
  • Protecting the information on the FAFSA from inappropriate use by ensuring that this information is only used for the application, award, and administration of aid awarded under Title IV of the Higher Education Act, state aid, or aid awarded by eligible institutions.

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.

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Updated: 7/29/2021


Publication Date: 5/20/2015

Renee W | 9/16/2021 9:46:02 AM

I tend to disagree because knowledge of what other aid the student athlete may be receiving is not needed to determine an amount to award in a "competitive athletic scholarship." I feel knowledge of the other aid would only be used to potentially reduce the amount of athletic aid the student might be offered. I feel that by sharing this information that may be used to actually decrease the student's athletic scholarship offer, we would open ourselves to justified complaints from both athletes and their parent(s) for sharing of their other award information.

Michelle M | 5/20/2015 1:1:31 PM

That begs the question of whether or not this "competitive athletic scholarship" is Title IV aid or institutional funds restricted to a specific group of students and not generally available to all students, wouldn't it?

Tangene U | 5/20/2015 12:40:21 PM

Isn't the coach using the FAFSA information to award a scholarship? If so, wouldn't the use of the FAFSA be for ensuring that this information is only used for the application, award, and administration of aid awarded under Title IV of the Higher Education Act, state aid, or aid awarded by eligible institutions?

I agree having a signed released would cover any unforseen ethical questions however, it is not necessary in this instance.

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