See below letter, sent to the FTC by Fairplay, the Parent Coalition for Student Privacy, and other groups, urging them to prohibit the use of personal student data for marketing purposes through targeted ads, described here as “Surveillance Advertising.”

Recent exposes of Naviance, for example, in The Markup here and here, for example, revealed how students are assigned to take surveys and provide their personal data to this company to apply to colleges, data which is then monetized  by Naviance and used by colleges to discriminate against particular racial groups.

This violates the student privacy laws of many states, including New York’s, which bar the use of student data for commercial purposes, and arguably FERPA as well, which holds that if student data is going to be shared with third parties without parent consent it must be to further the student’s education or the district’s operations.

Naviance also uses personal student data obtained through surveys of questionable validity and legality, filtered through black-box algorithms, to steer students into certain colleges or careers.