Executive Order on Election Integrity Has Minimal Impact on Illegal Student Data Use for Voter Registration and GOTV

The post is dated March 25, 2025. President Donald J. Trump signed an executive order that day, “Preserving and Protecting the Integrity of American Elections.” It asks whether that order stops universities or the ALL IN Campus Democracy Challenge from using student data, possibly in violation of FERPA, for voter registration and get-out-the-vote campaigns. Its answer is no: the effect on those practices is minimal.

The related case page is Campus voter data and the ALL IN challenge.

What the order does

It describes ALL IN as a program at more than 950 colleges, aimed at registration, education, and turnout. Critics suspect schools or ALL IN use names, addresses, or enrollment status to target students, which FERPA (20 U.S.C. § 1232g) generally forbids without consent, aside from narrow exceptions such as directory information when the student has not opted out.

The order, effective that day, prioritizes:

• Documentary proof of citizenship for voter registration (Section 2, citing 52 U.S.C. § 20508).
• An Election Day ballot-receipt deadline (Section 7, citing 2 U.S.C. § 7 and 3 U.S.C. § 1).
• Federal enforcement against non-citizen voting and election crimes (Sections 2 and 5, citing 18 U.S.C. § 611).
• Paper-based voting-system upgrades (Section 4, citing 52 U.S.C. § 21003).

Why the effect on campus data is small

1. The order does not mention student data or FERPA. Enforcement of FERPA sits with the Department of Education. the order does not hand that job to the Justice Department, Homeland Security, or the Election Assistance Commission.
2. Citizenship checks hit registration, not campus files. Section 2 requires proof of citizenship for registration. that can surface bad registrations later, but it does not regulate how a university or ALL IN gets student information. It cites Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1 (2013), for federal registration standards, and says that case is not a privacy ruling.
3. Election-crime enforcement is aimed at voters and officials. Section 5 tells the Justice Department to pursue crimes such as 18 U.S.C. §§ 611 and 1015 and to share information with states. a FERPA violation is civil unless it is tied to a crime the order actually covers.
4. Funding leverage does not reach campus data practices. Section 4 lets the Election Assistance Commission withhold funds from non-compliant states under 52 U.S.C. § 21145. that is election administration, not university operations, and that ALL IN is not an EAC grantee.
5. States still run election logistics. The post cites Article I, Section 4, and says FERPA violations stay with the Department of Education under 34 C.F.R. § 99.67.

Stricter roll checks might prompt a later FERPA inquiry, but the order itself adds no new penalty. Existing FERPA sanctions, including loss of federal funds under 20 U.S.C. § 1232g(a)(3), are unchanged. ALL IN can still do get-out-the-vote work with consented or public data.

It cites Shelby County v. Holder, 570 U.S. 529 (2013), for the limits of federal election power, and Gonzaga University v. Doe, 536 U.S. 273 (2002), for FERPA as its own enforcement regime.

This note reflects the order’s text as of 2:52 p.m. Pacific on March 25, 2025. A FERPA violation depends on the evidence in a given case.

Its citation list is FERPA, 20 U.S.C. § 1232g; the registration-form statute, 52 U.S.C. § 20508; non-citizen voting, 18 U.S.C. § 611; Arizona v. Inter Tribal Council; and Gonzaga.

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