USED has replied to a letter sent by Senator Markey concerning the privacy of student information. You can read their response here (pdf). I’m still working my way through it, but it’s obvious that a lot of their response is that they have issued “guidance.” But “guidance” does not have the force of regulation and FERPA does not provide parents and students with any private cause of action. So I’ll keep working my way through their response, but already know that whatever they say lacks teeth.