School-official designation
Per 34 CFR 99.31(a)(1)(i)(B), Koydo qualifies as a school official with a 'legitimate educational interest' when a school formally contracts with Koydo and the DPA documents the data processing purpose. The school remains the FERPA-responsible party; Koydo processes data on the school's behalf.
Direct control test
Koydo operates under the school's direct control: data is used only for the documented educational purpose, is not shared with non-school parties without authorization, and is subject to the same restrictions as other school employees handling educational records.
Parental access rights
Parents of minor students retain the right to inspect and review their child's educational records. The Koydo parent portal (/parent + /parent/data-export) gives parents direct access without requiring a FERPA records request to the school.
What constitutes an educational record on Koydo
Roster data, attendance, gradebook entries, lesson notes, homework submissions, IEP documents. Lesson recordings are educational records when retained beyond the 90-day default.
Directory information policy
Koydo does not disclose directory information (student name, photo, etc.) to third parties without explicit parental consent. The school's directory information policy is honored if more restrictive.
Annual notification
The school is responsible for the annual FERPA notification to parents; Koydo provides a template paragraph that schools can include describing Koydo's role.
Records of disclosure
Koydo maintains a record of all disclosures of educational records (which is essentially zero in normal operation — Koydo doesn't disclose, only processes). Records available to parents on request.