Yes, a school district is allowed, and very likely should be required under the Public Information Act, to release information about student transfers as long as it does not release information with individually identifiable information about students.
Educational records generally are exempt from disclosure under the Texas Public Information Act [Texas Gov’t Code § 552.026]. The Texas act defers to the federal Family Educational Rights and Privacy Act [20 U.S.C. § Sec . 1232] when it comes to handling of student records. Thus, federal law and policy govern release of records from educational institutions.
Federal regulations make it clear that information may be released without violating FERPA if all personally identifiable information has been removed from the record to protect student privacy [34 CFR 99.61]. Release of aggregate data, such as the number of student transfers in a school district, would be permissible without violating FERPA as long as any specific references to student names were removed.
Under policy of the Texas Education Agency, records and data of student transfers must be reported to this state agency, which keeps a database of student information. The agency is a “government body” under the Texas PIA, so its records are open to the public as long as they do not conflict with FERPA or fall under any exemptions.
While courts and the attorney general have not clarified what qualifies as an “educational record,” administrative information about school district policy and aggregate data that does not identify students should be open under the general policy of openness at the heart of the Public Information Act.
Requesters should consider all avenues to get the information they need. In this instance, one should not only ask the school district for answers, but also should request aggregate data from the Texas Education Agency, which has public information request guidelines in place (http://ritter.tea.state.tx.us/gir/PublicInfoMain.html) and may be able to answer queries such as this more quickly.