Student Privacy Rights: Children’s Online Privacy Protection Act (COPPA) Checklist


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Student Privacy Rights: Children’s Online Privacy Protection Act (COPPA) Checklist

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Student Privacy Rights: Children’s Online Privacy Protection Act (COPPA) Checklist

  1. 1. © 2014. Gagnier Margossian LLP. All rights reserved. Student Privacy Rights: Children’s Online Privacy Protection Act (COPPA) Checklist The Children’s Online Privacy Protection Act (COPPA) is the regulatory regime that any online operator must abide by if they are going to interact with children ages 12 and under. As schools begin to integrate consumer technologies into the classroom, it is important to keep this regulation in mind beyond obligations under FERPA. COPPA  Checklist  for  Schools 1. Know what qualifies as personal information under the statute. • Check out the FederalTrade Commission (FTC) FAQs at COPPA-Frequently-Asked-Questions for COPPA’s definition of Personal Information. 2. Implement a standardized district-wide process for reviewing an online or education technology service provider’s practices for information collection, use and disclosure to ensure they are COPPA compliant. • It should never fall on the individual teacher to assess sites’ and services’ practices.The district or school should have a set approval process that must be followed each time a new service is being considered. 3. Know where students are accessing information. • When planning lessons, make sure the sites students will use are vetted in advance with the proper safety settings selected, e.g. turning on Google SafeSearch. 4. Make sure the sites students visit have prominently displayed, clearly stated privacy policies that meet COPPA’s requirements. • Create lesson plans with links to specific websites that satisfy this requirement to direct students’ web use. 5. Provide parents with a notice of the websites and online services whose collection the school has consented to on their behalf. • At the beginning of every year, notify parents that their child’s work, likeness, name, etc. will be shared during the year. Have a permission release form provided and signed as part of the student registration packet. Permission to simply use the Internet is not enough. • As specific projects come up, notify parents in traditional ways such as a note home or email. Schools can also post this information on a parent page of the school website, or on a class website or blog.
  2. 2. T: 415.766.4591 F: 909.972.1639 E: @gamallp Inland Empire Internet Intellectual Property Privacy Social Media Technology The Good Stuff Sacramento San Francisco What  is  COPPA? The Children’s Online Privacy Protection Act, known as COPPA, requires websites and any company that provides a platform of any kind online or via mobile technology, to get parental consent before collecting or sharing information for children under the age of 13. As more unique and engaging education products emerge on the market, it is important to make sure that any websites or applications used in the classroom or recommended to parents are COPPA compliant. The FederalTrade Commission, who enforces this law, has a variety of resources for educators and parents alike on best practices and tools. #nerdlawyers COPPA  Checklist  for  Schools 6. Inform parents of the procedure for opting out of sharing their child’s personal information. • Find out how the school’s contracted service providers’ allow parents to opt out or access their child’s information and share the procedures. 7. Know when schools can or cannot consent on behalf of the parents. • Verifiable parental consent is mandatory unless the service provider guarantees that student’s personal information is only used for the benefit of the school and no other commercial purpose. Review the terms of service to determine whether student information is being shared. 8. Ensure the method used to obtain verifiable parental consent is FTC approved, or you can apply to the FTC for pre-approval of a new consent mechanism. • Check out the FTC FAQs at Questions for approved consent mechanisms. 9. Implement yearly trainings for school administration and faculty covering the school or district’s COPPA responsibilities and compliance practices. • Make sure all school staff know COPPA’s requirements and what role each of them play in ensuring total compliance. 10. Educate students about online safety and privacy issues. • Require teachers to incorporate online safety and privacy into their lesson plans.