Answer: It is not a Family Educational Rights and Privacy Act (FERPA) violation to share information on these students’ McKinney-Vento eligibility with their mentors.  FERPA specifically allows the sharing of education records without parent consent to other school officials, including teachers, within the district or school whom the district or school has determined to have legitimate educational interests. The district or school must use reasonable methods to ensure that school officials obtain access only to those education records in which they have legitimate educational interests. 34 CFR §99.31(a)(1). The mentors certainly would have a legitimate educational interest to know the student is McKinney-Vento eligible and to know about other needs.

As for parent permission or notification, we see no reason that would be required. This is part of the school day and takes place at school. The students choose to participate. We don’t see where parental permission would come into play.  If a mentor wants to spend time with the student outside of school, take the student on a college visit, etc., then you likely are moving into parental consent territory (but still would need to ensure full participation in this school activity, per the McKinney-Vento Act). That said, you might want to check with your State Coordinator just in case there is a relevant state requirement.

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