COPPA Disclosure Request Form

COPPA Disclosure Request Form

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).

To better understand which online operators are collecting your under-13 child’s personally identifying information, and how they use and protect that information, we encourage you to submit the following form to your child’s principal and/or teacher:

[Date]

[To your school’s principal and/or 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 more here: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools.)

As such, I am requesting the following information:

1.  A list of the online programs that my under-13 child is currently participating in at school, or will be participating in over the course of this school year, including online testing. A list of the online operators listed in #1 that have received my under-13 child’s personally identifiable information or will do so over the course of this school year.

2.  Please inform me of the types of personally identifiable data each online operator listed in #2 has received on my under-13 child, or will in the future.

3.  Please provide me with all “notices” (i.e. privacy policy or terms of service) provided to the school by the online operators listed in #2 as required by COPPA. [Note: If you are unable to produce copies because the operator failed to provide it then you and/or the vendor may be in violation of Children’s Online Privacy Protection Act (COPPA).]

Thank you for your assistance,

Name, relation to child, child’s name and grade
Address, Phone, Email

(Note: Please remember to keep all your records in case you need to file a complaint.)