The disclosure of student records to the inBloom data services is allowed by two different provisions in FERPA. The first provision allows schools to disclose student records to school officials with a legitimate educational interest in the records, including private contractors hired by a school district, when the student records are needed to provide the contracted
services. This applies to inBloom, which is contracted by school districts to provide technology services for school administrators and teachers. USED spelled out rules authorizing disclosure of student records to school district contractors in 2008 (see section 99.31(a)(1)(B)); however, this type of disclosure was consistently allowed long before it was codified in 2008 (for example, see this 2004 USED advisory opinion).