How does FERPA apply to College Board for the SAT Suite?

Like other education service providers to schools, College Board is an outsourced "school official" for provision of certain educational services. Under FERPA, schools may disclose student personally identifiable information (PII) to outsourced "school officials" without parental consent, subject to certain requirements, most importantly that the "school official" only use the student PII to perform services to the school and for no other purposes not allowed by FERPA. Those services are defined in the contract between the school and College Board.

Additionally, a separate provision of FERPA allows schools to disclose "directory information" to third parties without parental consent. Directory information includes, among other things, name, telephone number, address, email address, date and place of birth, grade level, honors, awards received, and participation in activities and sports.