The Importance of Records Access Security
Twilight looked around the headmare's office. Now that Cozy Glow was under arrest, she could get back to work. Twilight had a lot of work today. She had to get the class schedule back to normal and start creating a lesson plan for Cozy Glow's reformation. As she looked at the splinters of a chair on the floor, however, something more immediate had to be done first. She had to clean up her office. Twilight walked over to her desk and tipped the wastebasket upright. She caught a glimpse of beige and a corner of a photo from deep inside the basket.
"What's this?" She didn't remember throwing anything like that away recently. Twilight reached a hoof in and pulled out a folder. Some of the files were starting to fall out the folder. The folder itself had a picture of Yona on the front. Twilight frowned. "Now why is this in the trash?" She walked over the desk. Best to make sure the other studnets' folders were still in their proper place after Cozy's attempted takeover. Twilight pulled the right hoof drawer expectantly. Inside, Twilight should find the files for the students she was keeping a special eye on; the international students in particular. Those folders held the personal recommendations, prior school transcripts, admit letters, current course records, notes from professors. Everything that had to do with a student's application and attendance at the School of Friendship were stored in these folders, and the particular folders she was looking for should be right here in this drawer.
They weren't there. Five folders besides Yona's were missing. All the international students' files, gone. Deeply troubling. Twilight walked back over to the wastebasket and pulled out the paper contents. There was Sandbar's folder. The others were still missing. She wondered where they could be.
Twilight trotted through the halls of the school. Even if they were missing, Twilight needed to tell the students. Their sensitive information was in her care, and they should be informed of what happened. She went to the student dorms. "Gallus, Silverstream?" she called into on wing. "Are any of you six there?" Six heads poked out of their rooms.
"Yes Twilight?" Gallus spoke up. "What do you need?"
"I need to talk to the six of you. I'm afraid something came up with your files." They followed Twilight out of the room. She already had a hunch as to who took the files, since it was these six that had been taken. But talking to the six of them confirmed it. It was Cozy Glow.
She still had to find the rest of the files. Luckily, Cozy hadn't bothered to hide them. She searched Cozy's dorm and recovered them in short time. At least that load was off her back. There was still one more matter to attend to.
Twilight's brow furrowed as she crossed the courtyard toward the main entrance. She had trusted Cozy Glow with being her assistant, given her access to the students' files, and Cozy had used them to manipulate and bully her fellow students. This changed everything. She need to reach Luna before they got too far with Cozy. Twilight broke into a run as she left the school grounds. She could still catch them.
A quarter hour of sprinting and she caught up to Luna and the guards escorting Cozy Glow. "Wait!" she shouted. Luna and the guards came to a stop, turning to meet her. "There's been a change of plans," Twilgiht said as she reached them.
"Hm? Is something wrong, Twilight?"
Twilight turned to Princess Luna. "Are you at all familiar with the Federal Equestrian Records Privacy Act?"
The Federal Equestrian Records Privacy Act or FERPA was a law that governed how and who could access government stored personal records in Equestria and why that information could be accessed.
"Yes, I an." Luna replied. "It's what prevents me from just going into anyone's dream willy-nilly. I need to have a reason related to my royal duties to enter a pony's dream."
Twilight raised an eyebrow. This curious revelation sidetracked her. "Huh? Your dream walking falls under FERPA protections?"
Luna sighed. "Yes..." she considered whether to continue for a moment. Probably better to explain it. "Well, it didn't until recently. Nineteen moons ago the press may have gotten access to some dream recordings that may have played a role in forcing the Mayor of FIllydelphia to resign."
Twilight muttered the words over to herself. "Nineteen moons, mayor of Fillydel- WAIT! Horseradishgate was you?" Twilight's eyes were wide.
Luna chuckled. "What, did you think the entire Squallkill River being filled with horseradish was real?"
"I just chalked it up to Discord," Twilight shrugged.
"Fair," Luna smiled.
Their tangent was interrupted by a high pitched cough. "Can you get back to whatever you were talking about before I decide to try and escape?"
"Oh, right." Twilight said, her face falling to a frown. The reminder Cozy Glow was there and still had to be dealt with quickly deflated the wonder of discovering a new aspect of Equestrian legal policy.
Twilight scowled at Cozy Glow and turned back to Luna. "Unfortunately, I recently discovered the nature and extent of Cozy Glow's crimes against Equestria has run even deeper than I first thought." Twilight glanced at Cozy Glow. The pegasus filly was pouting with her hooves crossed, still being restrained by the two guards flanking her. "Despite the attempt to destroy all magic in Equestria and take over the school, Cozy Glow is still just a filly. My years with Discord and Starlight have taught me how even some of the most evil creatures were still capable of redemption if offered, and I had thought that path was still there for Cozy. She did do well in her classes. With more schooling, some dream therapy from you perhaps to get at the source of her desire to take over Equestria, I thought there could be real potential in her."
Luna nodded. So that was why Twilight had put Cozy Glow under her charge after the arrest.
"But now I see I was mistaken. Because I found these!" Twilight whirled on Cozy Glow and produced several folders from her saddlebag, brandishing them like a winning hoof of cards. Six colored folders; blue, beige, periwinkle, orange, pink, and tea green. The folders were stuffed with files, and had note markers sticking out of each of them in various colors. "I found these in the trash in my office and in your room! You looked at fellow student records during your scheme, didn't you?"
Cozy Glow stared at the folders. They had been in her room. She wasn't going to deny it now. "Of course I looked at them. You keep very good records."
"See?" Twilight pointed an accuasing hoof at Cozy Glow. "She violated FERPA regulations! Under the FERPA section governing educational institutions, student records, especially educational records like transcripts and grade reprots, must have an educational purpose to be accessed by any employee. It is intended to prevent unauthorized disclosure of a student's application, admission, or current school records to a parent or other group, or for a situation like this, where a student employee," the words felt wrong and icky on Twilight's tongue describing Cozy Glow, "looks at a fellow student's records for nefarious purposes!"
Luna nodded along.
Cozy Glow cut in. "But I was just glacning at them. Neighsay was the one who threw them in the trash!"
Twilight froze. Her mind whirred trying to process Neighsay's actions. "Well, in Neighsay's position as," Twilight steeled herself. She was already upset as it was. She nearly growled the title of "Acting Headstallion of the School of Friendship," before resuming. "he did have a sound educational reason for accessing the records. He did under the purview of his position have a right to review students' application status and reassess their eligibility for acceptance to the School of Friendship, even if he was wrong in his justification for rescinding their admission." Recalling and reciting the passages from the FERPA descriptions calmed Twilight as she was deciding what to do with Cozy.
Twilight continued, quieting to a mutter. "Though he really should have shredded them if he was getting rid of the records. And I am a bit miffed about Neighsay just discarding them like that. He should have put them in rescind admit, or at most into the room for the inactive student files. Even under EEA policy we're supposed to keep student admissions records for at least a year, and the files should be kept with an indicator in case they try to apply again. Sounds like I will need to have a talk with Neighsay after this."
Again, Twilight realized she was getting distracted. "No more distractions. Even if you were just retrieving them, you should have put them back in the proper place immediately. Instead, you took the files and rifled through them! And I'm guessing you were looking at records you weren't supposed to all this time while you were my assistant."
"You can't prove that," Cozy Glow sneered. "I may have had them in my room, but I was making sure Neighsay didn't get rid of them."
Twilight glared at Cozy. She was putting up a good defnse. But she'd gotten cocky. "Ohh," Twilight laughed triumphantly, "yes I can. I talked to the others. Gallus told me how you taunted him with Grandpa Gruff's recommendation letter. You had no right to do what you did to Gallus. The other five told me similar stories."
"What, and you're just going to believe them?"
Twilight pointed back toward the school. "After you tried to drain Equestria's magic and they saved everycreature? Yes, yes I am."
"So what do you intend to do with Cozy Glow?" Luna broke in. "If you're not going to continue trying to teach Cozy."
"There is only one place for creatures like her who would do such a heinous act as violate the confidentiality of a pony's academic records." Twilight took a deep breath.
Luna braced herself for the words.
"Tartarus."
Luna sighed in relief. "Oh good, I thought you might say the moon."
"What? No, of course not. The moon is too good for Cozy."
"I see. Well, you are Cozy's charge and get to decide her sentence. Come along Cozy Glow. It's a long trip to Tartarus."
Twilight walked with them a bit longer, discussing with Luna the precautions of locking Cozy Glow in Tartarus. After everything was sorted out, she turned back to the school and began walking back.
"Maybe I should create a magic spell that I can use on the records storage areas," she mumbled to herself, mulling the thought over. "I'll have to talk to Starlight about it. Maybe a spell that can control who gets access to which rooms and which drawers, something like that. If I can tune it to a certain frequency maybe? It would be best to have it around just the doors to stay safe, a spell to allow only certain ponies to be able to open the doors."
Twilight's mind caught up with her. She just reinvented the key.
She broke into laughter and trotted happily toward the school. There was still much to do. But at least Twilight knew the safety of her students' records would be assured.
Author's Note
This is not an entirely serious interpretation of FERPA protections.
