November 19, 2019

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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. 


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