Answer: If the student is 18, the student can consent for the friend to access school records and participate in the student’s education. 34 CFR 99.3.
For students under age 18, if an adult is acting as a parent in the absence of a parent or guardian, then that adult meets FERPA’s definition of parent and has the rights of a parent. No designation or other action is needed. 34 CFR 99.3; 99.4.
An unaccompanied youth under age 18 also can access his or her own records and consent for their disclosure, as long as a parent does not object. 34 CFR 99.5(b).