FERPA Q&A: Do records need to be created for former students?

Question: Do you need to recreate or attempt to recreate records for former students?

Answer: If student educational data has been maintained and destroyed according to the University's retention schedule, the University is not obligated to recreate destroyed records. If, however, the record still exists (even if it has been maintained well beyond the required time stipulated in the retention schedule), and a student or former student requests access to it, the record cannot be destroyed.