FERPA Compliance for EdTech: Disco Case Study

About Disco

Disco is an AI-powered social learning platform. The company builds tools that help organizations create structured, social, and personalized learning experiences. As Disco moved into the higher education sector, it needed to meet FERPA, the U.S. federal privacy law governing the handling of student education records, as a condition of working with institutional clients.

Context and Challenge

FERPA (Family Educational Rights and Privacy Act) is the primary privacy regulation for education records in the United States. It governs how vendors that process student data must handle, store, share, and dispose of those records. FERPA requires clear documentation of policies, procedures, and institutional responsibilities. TechMagic's work with Disco began with SOC 2, establishing a technical security baseline. As Disco's business grew and the company moved into the higher education sector, FERPA became the next compliance requirement to address. The FERPA Gap Assessment identified that governance, policy documentation, and operational readiness had not yet been formalized to meet the expectations of institutional clients. TechMagic was engaged to address those gaps through a structured advisory program.

TechMagic and Disco’s Ongoing Partnership

SOC 2

Security baseline & certification

FERPA compliance

Governance, policy, documentation & operational readiness

Ongoing support

Ad hoc advisory, regulatory guidance as needs grow

FERPA Compliance Engagement Process

Our engagement was structured across three phases over approximately three months, following the findings of the FERPA Gap Assessment. Technical security controls were outside the scope of this engagement, as Disco's existing SOC 2 posture covered that baseline. The focus was governance, policy, and operational readiness.

001

Foundational documentation

TechMagic restructured and updated Disco's External Service Privacy Policy, separating website and marketing content from the service and product policy. A FERPA subsection was added to the service privacy policy, and a standalone FERPA Notice/Addendum was developed for institutional customers. A Short Internal FERPA Privacy Policy was drafted for Disco employees, covering roles, escalation procedures, and plain-language obligations for staff with access to education records. TechMagic also created the FERPA Request Handling Toolkit: response templates for acknowledgment, processing, and closure of requests; a Request/Disclosure Register; and recordkeeping guidance.

002

Operational formalization

Privacy and FERPA onboarding and offboarding guidance was defined and aligned with Disco's existing access control procedures. A periodic FERPA and privacy refresher training module was developed and delivered to staff with education-record access, along with a training record. The vendor and sub-processor privacy assessment process was strengthened with a structured questionnaire and checklist, defined evidence expectations, and a regular review cadence for FERPA-relevant risk evaluation.

003

Risk management

TechMagic produced a DPIA-style risk assessment template and completed an assessment for Disco's AI-driven features as they relate to education-record processing. The Incident Response Playbook was updated with a FERPA-specific scenario, covering education-record impact triage, institution notification steps, and documentation requirements. A secure data retention and disposal procedure was developed for education records, including deletion and disposal verification guidance. TechMagic also defined a periodic FERPA-focused privacy audit checklist, specifying what to review, evidence to retain, and how to track remediation.

Engagement Deliverables

Restructured External Service Privacy Policy with a FERPA subsection and standalone FERPA Notice/Addendum for institutional customers

Periodic FERPA and privacy training module and training record

Short Internal FERPA Privacy Policy for employees

Periodic FERPA privacy audit checklist and cadence

FERPA Request Handling Toolkit: response templates, Request/Disclosure Register, and recordkeeping guidance

DPIA-style risk assessment template and completed AI-feature assessment

FERPA onboarding and offboarding guidance, aligned with existing access control procedures

Updated Incident Response Playbook with a FERPA-specific scenario

Enhanced vendor and sub-processor privacy assessment process

Secure data retention and disposal procedure for education records

What Disco Says About Working With Us

"TechMagic team put together a really thoughtful and thorough project plan, which was executed not even on time, but actually a bit early, which is always appreciated. They spent the time to really go through a topic area that requires a level of deep expertise, and ensured that there was really solid knowledge transfer to our team at the end of the project."

Chris Stefanyk - Head of Revenue & Operations at Disco

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What Results Were Achieved

001

Fully documented FERPA compliance framework, ready for institutional due diligence

002

Delivered ahead of the planned three-month timeline

003

Coverage across policy, operations, risk management, and audit readiness

004

Knowledge transfer completed, Disco's internal team equipped to maintain and operate the framework independently

Why Choose TechMagic for FERPA Compliance

Structured delivery with predictable timelines

TechMagic follows a phased engagement model built around gap assessment findings. Disco's full FERPA compliance framework, covering policy, operations, and risk management, was completed ahead of the planned three-month timeline.

Certified expertise in security and data privacy

TechMagic is an ISO 27001-certified company. Every FERPA engagement is led by a dedicated team of security and data privacy consultants with practical experience across security controls, governance design, and policy documentation.

Knowledge transfer included

Every engagement ends with the client's internal team fully equipped to maintain and operate the framework independently. Ongoing support is available after delivery for questions as compliance requirements evolve.

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