Update Sept. 12, 2024:  Our letter was covered by  Daily News , Chalkbeat , State Scoop  and K12 Dive so far.  We just learned that in California a class action lawsuit was filed against Talkspace, the parent company of Teenspace, for sharing with TikTok the personal information of clients and visitors to its website, including the information of minors. We also learned that when a NYC student visits the Teenspace website on their phone, their personally identifiable information is shared with 15 ad trackers and 34 cookies, as well as Facebook, Amazon, Meta, Google, and Microsoft among other companies, which we saw from using the Blacklight  privacy audit tool,.

note:  corrected email address for Ann Williams-Isom is [email protected]

Sept. 10, 2024

See below and here: a letter sent today to NYC Mayor Adams,  Chancellor Banks, the NYC Health Commissioner, and the Deputy Mayor for Health and Human Services.  The letter was written and signed by the Parent Coalition for Student Privacy, NYCLU and AI for Families, and expresses our collective privacy concerns with the Teenspace telehealth mental health service.  The city is paying $26 million for this service, which has been widely promoted by the Mayor and NYC DOE to be used by NYC students.  

Teenspace is owned by a company called Talkspace and collects a huge amount of very sensitive personal information from teens before they even can create accounts  or access the privacy policy – and much of this information would be barred from collection by the federal student privacy law PPRA without parental consent or opt out if the district had contracted for these services rather than the city’s Department of Health.  The list of these questions is included in the appendix to our letter.

To make things worse, Talkspace says personal student data can be used for marketing purposes, which would be prohibited by the NY Student privacy law 2D, again if the DOE had signed the contract.

In 2022, several US Senators wrote to Talkspace, pointing out how the company also appeared to be taking advantage of a “regulatory gray area” in HIPAA, to exploit their patients’ data for profit.

Especially with all the breaches and misuse of student data by DOE contractors, the privacy of NYC students should be better protected than this. Finally, there have been widespread consumer complaints about Talkspace’s inadequate counseling services and overcharging of clients.  All of this and more is touched on in our letter below.   

 Teenspace Letter 2024.9.10

Here is the presentation we gave on May 6 to parents from states throughout the nation, with tips on how to ensure their children’s data is not sold by the College Board or ACT.  Our spreadsheet with links to state laws where this is illegal for school vendors is here.  A video of the event is available on YouTube; Part I with the presentation, and Part II, with a Q and A.

Here is a template letter that you can use to write to your State Attorney General urging them to stop these vendors from selling student data in violation of your state law, as the NY AG did, is below.

If you are an Illinois resident, here is a form to write to the Illinois AG asking him to enforce Illinois’ state student privacy law, sponsored by Illinois Families for Public Schools.

Please email us if you have any questions at: [email protected]

Also contact us if you are a parent at one of the states that do not have a law prohibiting the sale of student data by the College Board/ACT, or have a state law that allows this with student consent, but without specifying the age of that student.  We can help you file a FERPA complaint to the US Department of Education.

Thanks!  Leonie and Cassie

See below comments that PCSP and attorney Zephyr Teachout submitted to the Federal Trade Commission, urging them to strengthen their proposed student privacy and security regulations for the federal law entitled COPPA, for Children’s Online Privacy Protection Act.  COPPA is one of a few key federal laws that protect student privacy. There has not been a change to the rule implementing COPPA for more than a decade, and the new one will have major implications for data collection for children under age 13 in schools and elsewhere.  Some discussion about the weaknesses in these proposed regs are here; the public comments from over 700 individuals and groups that were due March 11 are posted here.