USED Student Privacy Actions Timeline

Tags: FERPA · Investigation opened · California SEA · State education agency (SEA)

SPPO launched an investigation into the California Department of Education (CDE) for “allegedly abdicat[ing] the responsibilities FERPA imposes due to a new California state law [AB 1955] that prohibits school personnel from disclosing a child’s ‘gender identity’ to that child’s parent.” The Department said that “Given the number of LEAs that appear to be involved, SPPO is concerned that CDE played a role, either directly or indirectly, in the widespread adoption” of LEA practices ‘to socially transition children at school while hiding minors’ ‘gender identity’ from parents.”

Tags: FERPA · PPRA · Guidance, Notice, or Dear Colleague Letter · All LEAs and SEAs

USED announced that SPPO sent a Dear Colleague Letter (DCL) notifying school leaders “of their compliance obligations under the Family Educational Rights and Privacy Act (FERPA) and the Protection of Pupil Rights Amendment (PPRA)” and outlining SPPO’s “priority concerns.” The Department said that “Compliance with [FERPA and PPRA] means that schools must allow parents to review all education records of their student, including any document related to a student’s ‘gender identity.’”

Tags: FERPA · PPRA · Guidance, Notice, or Dear Colleague Letter · All LEAs and SEAs

SPPO sent letters to state and local education agencies of their responsibilities under FERPA and PPRA. Compared to previous years, there was an increased emphasis on PPRA requirements.

Tags: FERPA · Finding issued · Letter or demand · Middleton Cross Plains, WI · Local education agency (LEA)

SPPO sent a letter of finding to the Middleton Cross Plains Area School District (Wisconsin) in response to a FERPA investigation that began 12 years ago. The letter addresses a 2013 complaint regarding a parent being denied access to a student's education records in the form of emails and personal notes. SPPO found insufficient evidence of a FERPA violation regarding the emails, noting the evolving legal landscape and that the parent ultimately received the emails via state law. Regarding personal notes, SPPO concurred with the District that these fell under the "sole possession" exception to FERPA, thus were not subject to disclosure. Consequently, the complaint was closed due to an “absence of a finding of noncompliance in regard to either allegation.” SPPO apologized for significant delays in its investigation.

Tags: FERPA · Title IX · Investigation opened · KCKPS, KS · Olathe, KS · Shawnee Mission, KS · Topeka, KS · Local education agency (LEA)

OCR and SPPO announced that it launched FERPA and Title IX investigations into four Kansas districts: Kansas City, Kansas Public School District (KCKPS); Olathe Public Schools (OPS); Shawnee Mission School District (SMSD); and Topeka Public Schools (TPS). The Department received a complaint alleging that the districts’ policies “prevent school officials from disclosing a student’s ‘transgender status’ to their parents without the student’s consent.”

Tags: PPRA · Investigation opened · Fairfax County, VA · Local education agency (LEA) · Marked historical

SPPO initiated a PPRA enforcement action against Fairfax County Public Schools (Virginia) following reports that “a Centreville High School social worker reportedly scheduled an abortion appointment for a 17-year-old student, paid the required clinic fees, and swore the girl to secrecy without informing the student’s parents” while “A second student was allegedly pressured by the social worker to have an abortion, with the social worker reportedly telling her she ‘had no other choice’ and directing her to the same clinic for an abortion procedure, which the student did not ultimately undergo.” The Department required “Fairfax to investigate this matter and provide a written response by October 17” addressing listed issues.

Tags: FERPA · Investigation opened · Tufts University · National Student Clearinghouse · Higher ed · Vendor or service provider · Marked historical

SPPO announced FERPA investigations into Tufts University (Massachusetts) and the National Student Clearinghouse following “multiple reports alleging that the process of compiling NSLVE data involves illegally sharing college students’ data with third parties to influence elections.” The Department references a DCL issued the same day, in which “SPPO makes clear in this guidance that any institution that utilizes NSLVE data – set to be released this year – could be at risk of being found in violation of FERPA.”

Tags: FERPA · Finding issued · Resolution or referral · KCKPS, KS · Olathe, KS · Shawnee Mission, KS · Topeka, KS · Local education agency (LEA)

USED announced that that it found Kansas districts in violation of FERPA following its August 2025 investigation: “Based on a lack of substantive documentation submitted by the Districts, SPPO found that [TPS, SMSD, OPS, and KCKPS] had policies that were likely to prevent schools from notifying parents of their child’s so-called ‘gender transition,’ even if the parent requested their child’s records, thereby violating parents’ rights under FERPA to access school records pertaining to their children.” USED noted that it “issued proposed Resolution Agreements to the Districts” specifying actions to remedy FERPA violations.

Tags: Title IX · FERPA · Resolution or referral · Letter or demand · KCKPS, KS · Olathe, KS · Shawnee Mission, KS · Topeka, KS · Local education agency (LEA)

OCR announced that it sent “Letters of Impending Enforcement Action to [OPS], [SMSD], and [TPS to] notify the Districts that they have 10 calendar days to come into compliance or face enforcement action, potentially including referral to [DOJ] and the termination of federal funding.” The Department also sent a “Letter of Impasse to [KCKPS] notif[ying] the District that the Department is preparing for impending enforcement, which, following the Department’s regulatory procedures, could result in the termination of the Districts’ federal education funding.” The Department claimed that “Despite receiving OCR’s proposed Resolution Agreements, which, if implemented, would remedy the Districts’ violations of Title IX, the Districts continue to take no action to protect women and girls and have failed to uphold parents’ rights to inspect their children’s educational records.”

Tags: Title IX · Investigation opened · Ann Arbor, MI · Local education agency (LEA)

OCR announced a Title IX investigation into Ann Arbor Public Schools (Michigan) for allegedly having “policies allowing males to compete on women’s sports teams” and allowing a male to use “female-only locker rooms to undress.” Note that the Department did not include FERPA-related allegations in this press release, but we include it in our timeline because of SPPO’s FERPA enforcement announcement against the district nine days later (July 27). Prior to July 27, this is the only potentially relevant information on the Department’s website related to Ann Arbor.

Tags: FERPA · Finding issued · Resolution or referral · Anne Arundel, MD · Ann Arbor, MI · DOJ Involvement · Local education agency (LEA)

SPPO announced partnering with DOJ “to take enforcement action against Anne Arundel County [Maryland] after determining the District improperly classifies information about a student’s so-called ‘gender identity’ as ‘confidential medical information’ that cannot be shared with parents.” The Department alleged an instance “When the parents approached school administrators about the matter, the principal declined to provide details about the student’s ‘gender transition,’ and the assistant principal refused to turn over the child’s relevant records.”

SPPO also announced a finding that an Ann Arbor Public Schools (Michigan) “policy requiring school employees to hide a child’s ‘transgender status’ from his or her parents likely violates FERPA.” The Department gave the district “until August 10th to demonstrate why ED and DOJ should not move forward with enforcement,” requiring Ann Arbor to “justify its policy that directs school officials to maintain records related to a student’s so-called ‘gender identity’ in a separate filing system or be subjected to imminent enforcement action.”

Tags: PPRA · Investigation opened · Minnesota SEA · State education agency (SEA)

USED announced a PPRA investigation into the Minnesota Department of Education (MDE) following a complaint in which “parents expressed their concern that their statutory and constitutional rights were violated as they were not notified or given the opportunity to opt their children out of an activity that used ‘transgender dolls’ in the classroom.” The Department referenced news reporting that “‘MyGenderDolls’ will be available to Minnesota educators for use in classrooms with students as young as four years old this fall,” and said that “The dolls – developed via a taxpayer-funded University of Minnesota program – feature removable, interchangeable internal and external genitalia, gender-neutral names, and clothing (including undergarments) for both sexes.”

Tags: FERPA · Letter or demand · California SEA · Washington SEA · State education agency (SEA)

SPPO “demanded updated information from [CDE and OSPI] regarding policies governing schools’ disclosure of records to parents in light of recent rulings in the U.S. Supreme Court and the U.S. Circuit Court of Appeals for the Ninth Circuit, both of which bolster the legal rights of parents.” The Department “request[ed] that the CDE and OSPI immediately detail their plans to revise their policies and practices in light of” Mirabelli v. Olson and the City of Huntington Beach v. Newsom

Tags: FERPA · PPRA · Guidance, Notice, or Dear Colleague Letter · All LEAs and SEAs

SPPO announced that it sent a DCL and annual notifications “amid rampant reports of schools withholding critical information from parents, such as maintaining records related to a child’s ‘gender’ separately in order to keep them hidden from parents.” The press release announced “that SPPO will consider… surveys [revealing sensitive categories of information under PPRA to be] ‘required’ when administered by an educator, counselor, or other school official and that an opt-out policy is not sufficient to secure parental consent.”

Tags: FERPA · PPRA · Guidance, Notice, or Dear Colleague Letter · All LEAs and SEAs

SPPO sent letters to state and local education agencies of their responsibilities under FERPA and PPRA. Compared to the annual notices issued last year, the Department made several changes to reflect that parental opt-out policies are no longer sufficient for any surveys issued at school addressing the eight protected categories of information under PPRA.