FERPA and student records
This article summarizes FERPA-oriented controls in SpeechGradebook for institution reviewers. It is not legal advice — work with your institutional counsel and FERPA officer for binding determinations.
Education records
Student speech evaluations, scores, feedback, and associated media may constitute education records under FERPA when maintained by the institution or on its behalf. When ValidBound processes those records for an institution, ValidBound acts as a School Official with a legitimate educational interest under 34 CFR Part 99, solely to provide the contracted services.
No public AI training by sub-processors
Student voice recordings, video streams, transcripts, and rubric results are not sent to third-party APIs that use user content for public model training. Sub-processors that process such content must use zero-data-retention or private-tenant arrangements.
Access controls
- Instructors access only their own courses and students.
- Admins access data within their department or institution per policy.
- Supabase row-level security enforces these boundaries at the database layer.
Audit logging
Access to student evaluation data is recorded in application audit logs (who/what/when/action/context when available). Not every UI interaction is guaranteed to generate a log entry. Admins can review compliance-oriented logs under Settings → Admin → Compliance where enabled.
Consent
Evaluation materials are stored for instructional use by the instructor and authorized unit administrators. Affirmative student consent (18+) is required before ValidBound includes materials in LLM training or R&D exports. See Consent and data storage.
Additional resources
- Privacy policy
- Terms of Service
- Higher Education Pilot Addendum
- Internal engineering assessment:
docs/FERPA_COMPLIANCE_GUIDE.mdin the repository (for implementers)