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"In a 2002 case, the United States Supreme Court suggested that Congress envisioned FERPA applying only to files kept in a central file by a records custodian designated by the school, not to every record that might be generated across the school district by which a student can be identified. In Owasso Independent School Dist. No. I-011 v. Falvo, the Supreme Court found that students' assignments are not educational records under FERPA. 534U.S. 426. In so doing, the Court clarified that not every record in a school concerning a student is an education record. The Court looked to a provision in FERPA, 20 U.S.C. § 1232g(b)(4)(A), which requires that a record of access be kept when a request for student records is made. That record must be kept "with the education records" of the student. The Court found that this suggested that Congress intended that education records would be kept in one place. Moreover, FERPA requires that a "school official" and "his assistants" are responsible for the custody of the records. The Court indicated that this implies that "education records are institutional records kept by a single central custodian, such as a registrar, not individual assignments handled by many student graders in their separate classrooms."  534U.S. at 434-435."

As an integral part of students' daily lives, mobile technology has changed how they communicate, gather information, allocate time and attention, and potentially how they learn. The mobile platform's unique capabilities - including connectivity, cameras, sensors, and GPS - have great potential to enrich the academic experience.3 Learners are no longer limited to the classroom's geographical boundaries, for example; they can now record raw observations and analyze data on location. Furthermore, mobile technology platforms let individuals discuss issues with their colleagues or classmates in the field. The ever-growing mobile landscape thus represents new opportunities for learners both inside and outside the classroom.4 We conducted two surveys - one in 2012 and one in 2014 - to investigate student use of mobile technology.