FERPA Compliance

1. Our FERPA Commitment

The Family Educational Rights and Privacy Act (FERPA) protects the privacy of student education records. WishWell Counseling & Empowerment Center ("WishWell") designs the Belonging Score so partner schools can gather student connection insights while staying fully compliant with FERPA.

This page explains how we meet that commitment in practice. It is provided for transparency and does not replace a school's own FERPA policies or a signed services agreement.

2. School Official Status

WishWell acts as a "school official" with a legitimate educational interest when processing student survey responses for the Belonging Score. We perform services that the school would otherwise perform itself, under the school's direct control, and we use student data only for the purposes the school directs.

We do not use the data for commercial purposes, advertising, or any purpose outside the scope of the school's program.

3. What Data Is Collected

Students respond to a short, research-grounded connection survey. Responses may include a school-supplied identifier so that authorized staff can follow up with students who need support. The survey does not ask for Social Security numbers, medical diagnoses, or disciplinary history.

All student-level data is treated as an education record under FERPA.

4. How Data Is Used

Individual responses are used to produce Belonging Scores visible only to authorized school staff. Aggregate, de-identified reports help school leadership see trends by grade, campus, or time period. Small groups are suppressed to protect student anonymity.

The Belonging Score is a support signal. It is never used as a disciplinary tool, a diagnostic label, or a public ranking.

5. Who Can Access the Data

Access is limited to school staff the district authorizes and to the WishWell personnel who deliver and support the program. Administrative dashboards require approved, authenticated accounts with role-based permissions.

We do not disclose identifiable student data to third parties except as directed in writing by the school or as required by law.

6. Data Security

Student data is stored in access-controlled cloud infrastructure, encrypted in transit and at rest. We use row-level access rules, strong authentication, audit logging, and least-privilege access to protect education records.

7. Retention and Return

Student data is retained for the duration of the school's program plus any additional period the school requires for continuity. When the program ends or the school requests it, data is returned to the school or securely deleted according to the services agreement.

8. Rights of Parents and Eligible Students

FERPA gives parents and eligible students the right to inspect, request correction of, and ask about disclosures of education records. These rights are exercised through the school or district. WishWell supports schools in responding to these requests promptly and accurately.

Families are informed about the Belonging Score program by the school and through our Family Guide, which explains in plain language what is measured, how data is protected, and who can see the results.

9. Questions

Schools, families, and students with FERPA questions can contact the school's data privacy officer or reach WishWell directly at vereniceh@wishwellcc.com.