Every summer, schools and universities retire devices by the thousand — 1:1 program Chromebooks and laptops, lab machines, faculty refreshes. Each one carries student records in some form: cached logins, documents, rosters, accommodations data. FERPA's protection of those records doesn't end when the device does.
The scale is the trap. A district can't hand-wipe four thousand Chromebooks, and an end-of-lease return with no data step ships the records to whoever refurbishes the fleet.
What works: bulk, certified sanitization with per-device serialized documentation, lease-return coordination so devices never leave with data aboard, and remarketing programs that turn the retired fleet into budget for the next one — a real consideration when every dollar competes with classroom needs.
Bulk FERPA-conscious destruction with documented custody, built for education timelines and budgets.