If an LEA has not provided notice relating to directory information, may it release a students name, address, and telephone number when requested by a military recruiter?

An LEA may provide a single notice regarding both directory information and information disclosed to military recruiters.  If an LEA does not disclose “directory information” under FERPA, then it must still provide military recruiters access to secondary students’ names, addresses, and telephone listings.  In addition, the LEA must notify parents that they may opt out of this disclosure.  In other words, an LEA that does not disclose “directory information” must nonetheless provide a notice that it discloses information to military recruiters.  The notice must be reasonably calculated to inform parents.