AASA Submits Comments to FTC on COPPA
Today AASA submitted comments to the FTC on proposed changes to the Children's Online Privacy Protection Act (COPPA). If not amended the FTC proposal could pose major administrative obstacles for school districts.The proposed rule would guarantee a number of rights to parents in connection with the data
collected from their children who are under the age of 13 in schools. These include the
right to receive direct notice prior to the collection of such data, the right
to review the personal information collected from their child, the right to
revoke their consent and refuse the further use or collection of personal
information from their child, and the right to delete their child’s personal
information. AASA believes that the rights enumerated above should remain in the hands of schools and not placed into the hands of parents in order to assure the administrative, educational, privacy, and equity benefits of the use of Ed Tech.
If schools must actively obtain
parental consent, this is likely to cause a number of harmful and unintended
consequences. First, the requirement will create a substantial administrative
burden on schools. Districts rarely receive 100% return on requests for parent
consent which may impede the function and operation of critical technology
services. Online and Ed Tech services, including learning management systems
that deliver curriculum by collecting student input and providing an
individualized level of instruction depending on student individual response,
are ubiquitous in schools and may provide vital school functions. Additionally,
some school districts serve tens of thousands of students and operate multiple
educational software programs and applications that may serve the same purpose
as textbooks or other core curricular materials. Therefore, in addition to the
administrative burden, this requirement could shut down or inhibit many vital
school functions, like managing curriculum materials, taking attendance, or
transferring transcripts. For these reasons we urge the FTC to formally align COPPA with FERPA
and allow schools to provide consent to Ed-Tech providers.