COPPA form requesting that schools/districts exercise their rights on behalf of parents
Background information: The Children’s Online Privacy Protection Act, or COPPA, is a federal law that allows parents to control what information is collected online from their children under the age of 13. The Federal Trade Commission’s provides official guidance on how COPPA applies to the educational or “Schools” context, including the following:
“Many school districts contract with third-party website operators to offer online programs solely for the benefit of their students and for the school system – for example, homework help lines, individualized education modules, online research and organizational tools, or web-based testing services. In these cases, the schools may act as the parent’s agent and can consent to the collection of kids’ information on the parent’s behalf. However, the school’s ability to consent for the parent is limited to the educational context – where an operator collects personal information from students for the use and benefit of the school, and for no other commercial purpose…
In order for the operator to get consent from the school, the operator must provide the school with all the notices required under COPPA. In addition, the operator, upon request from the school, must provide the school a description of the types of personal information collected; an opportunity to review the child’s personal information and/or have the information deleted; and the opportunity to prevent further use or online collection of a child’s personal information.” (see more here: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools).
Since COPPA gives schools the authority to demand the types of personal information collected on your child under 13, review your under 13 child’s personal information or have it deleted, and prevent further use or collection of his/her personal information, please use this form to request that your school exercises its rights on your behalf:
[Date]
[To your school’s principal and/or your under-13 child’s teacher]:
Per the Federal Trade Commission’s website, “Congress enacted the Children’s Online Privacy Protection Act (COPPA) in 1998 … The primary goal of COPPA is to place parents in control over what information is collected from their young children online… The Rule applies to operators of commercial websites and online services (including mobile apps) directed to children under 13 that collect, use, or disclose personal information from children, and operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13.”
The FTC’s guidance further states that a school may sign up a child for online websites subject to COPPA but that a “school’s ability to consent for the parent is limited to the educational context – where an operator collects personal information from students for the use and benefit of the school, and for no other commercial purpose.” It further states that in “order for the operator to get consent from the school, the operator must provide the school with all the notices required under COPPA. In addition, the operator, upon request from the school, must provide the school a description of the types of personal information collected; an opportunity to review the child’s personal information and/or have the information deleted; and the opportunity to prevent further use or online collection of a child’s personal information.” (See here: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools.)
It has come to my attention that my under-13 child is participating in one or more online programs at school which is/are collecting [his or her] personal information. While I understand that my under-13 child’s teacher, school and/or district has authority under the Children’s Online Privacy Protection Act to create an online account on [his or her] behalf with an online operator, or instruct my under-13 child to create his or her own account, it is also my understanding that the online operator must provide my school, upon request:
1. A description of the types of personal information collected on my under -13 child;
2. The opportunity to review my under-13 child’s personal information and have the information deleted;
3. The right to opt out of any further use or collection of my under-13 child’s personal information by the online operator.
Since my under-13 child or one of the school’s employees created an online account for my child at school, I request that the school and/or district immediately notify each online operator listed below to [choose one or more: 1. provide my school a description of the types of personal information collected on my under-13 child; 2. allow my school to review and/or delete all the personal information collected on my under-13 child; and/or 3. allow my school to refuse the online operator from further using or collecting my under-13 child’s personal information] in the following online program(s):
_____________________________________________________________________
_____________________________________________________________________
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Thank you for your assistance,
Name, relation to child, child’s name and grade
Your Address, Phone, Email
(Note: Please remember to keep all your records in case you need to file a complaint.)