Children's Online Privacy Protection Act (COPPA) Compliance Policy for Students and Parents
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Introduction
This COPPA Compliance Policy outlines the practices and measures undertaken by Smart Innovations, Inc. ("Company") and its Licensees or Institutions to ensure compliance with the Children's Online Privacy Protection Act (COPPA) regarding the collection, use, and protection of personal information of children under the age of 13 who access and use the Epic EMIS educational software application ("Application"). Smart Innovations is committed to safeguarding the privacy and security of children's personal information and maintaining a safe online environment.
Definitions
- Licensees or Institutions: Each of the Educational Institutions, e.g., Institutions, Colleges, Universities, Literacy Centers, Training Centers, and others (hereinafter referred to as the "Institution" or "Institutions" or "Licensee" or "Licensees") are the Data Controllers for the purposes of GDPR. You may contact the Institution at the address and contact information provided to you on the Institution's home page.
- COPPA: The Children's Online Privacy Protection Act is a U.S. federal law designed to protect the online privacy of children under 13 years of age.
- Personal Information: Information that can identify or be linked to an individual, including but not limited to name, address, email, and any other data that might allow someone to identify or contact a child.
- Application: The Epic EMIS educational software application by Smart Innovations designed, developed, and released for educational purposes.
- User: An individual who accesses and uses the Application.
Collection of Personal Information
Smart Innovations acknowledges the importance of protecting children's privacy and commits to collecting only the minimal personal information necessary for the operation of the Application. When a child under 13 years of age is registered at a school by a parent, legal guardian, school principal, or headmaster, he or she may use the Application, the following information may be collected:
- Usernames: For the purpose of creating and maintaining individual accounts within the Application.
- Parental Consent: In cases where the collection of personal information is necessary, verifiable parental consent will be obtained before collecting any personal information from a child.
- Usage Data: Non-personal information related to the child's interaction with the Application, such as progress, performance, and learning activities, may be collected to improve the educational experience.
- Other Personal Information such as:
- Names, addresses, telephone numbers, e-mail addresses and other contact details;
- car details, such as those who use the Institution's car parking facilities;
- bank details and other financial information, e.g., about parents who pay fees to the Institution;
- past, present, and prospective students' academic, disciplinary, admissions, and attendance records, including information about any special needs, and examination scripts and marks;
- personnel files, including in connection with academics, employment, or safeguarding;
- where appropriate, information about individuals' health and welfare, and contact details for their next of kin;
- references given or received by the Institution about students, and relevant information provided by previous educational establishments and/or other professionals or organizations working with students;
- correspondence with and concerning staff, students, and parents past and present; and
- images of students (and occasionally other individuals) engaging in the Institution's activities, and images captured by the Institution's CCTV system (in accordance with the Institution's policy on taking, storing, and using images of children).
Obtaining Verifiable Parental Consent
Prior to collecting any personal information from children under 13 years of age, the Institution will take steps to obtain verifiable parental consent. This may include:
- Direct Notification to Parents: Notifying parents about the information being collected and its purpose, while also providing the option to refuse consent.
- Obtaining Parental Consent Offline: Providing parents with the option to provide consent through traditional methods such as fax, mail, or phone.
- Online Payment: If the Application involves monetary transactions, the parent's payment information will be considered as verifiable parental consent.
- Email Confirmation: Obtaining a parent's online consent via email, coupled with additional steps to confirm the authenticity of the consent.
Use and Disclosure of Personal Information
Smart Innovations is committed to using children's personal information solely for the purpose for which it was collected. The information collected will be used for:
- Personalization: Customizing the educational experience for each child based on their progress and performance within the Application.
- Improvement: Analyzing usage patterns and learning outcomes to enhance the Application's educational content and features.
- Communication: Communicating with parents or legal guardians regarding their child's progress, performance, and any relevant updates.
Smart Innovations will not disclose, sell, or share children's personal information with third parties without prior verifiable parental consent, except in the following cases:
- Service Providers: Disclosure to service providers who assist in the operation and maintenance of the Application. These service providers are contractually obligated to keep the information confidential.
- Legal Requirements: Compliance with applicable laws, regulations, and legal processes.
Data Security and Retention
Smart Innovations employs industry-standard security measures to protect children's personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure socket layer (SSL) technology, and access controls. Personal information will be retained only as long as necessary to fulfill the purposes for which it was collected or as required by law.
Parental Access and Control
Parents or legal guardians have the right to review, delete, or modify their child's personal information collected by the Application. They can exercise these rights by contacting the Company's designated privacy officer through the contact information provided in this policy.
Children's Online Safety
Smart Innovations encourages parents and guardians to monitor their children's online activities and educate them about safe and responsible online behavior. The Application will not contain any links to external websites that are not educational or do not comply with COPPA guidelines.
Conflict with Local Laws and Regulations
In the event that any provision, term, or condition within this Policy, including any related documents, guidelines, or agreements, contradicts or conflicts with applicable local laws or regulations, such provision, term, or condition shall be deemed null and void to the extent of such contradiction or conflict. The remaining provisions, terms, and conditions of this Policy shall remain in full force and effect. This clause is intended to ensure that this Policy remains compliant with the prevailing legal requirements of the jurisdiction in which it operates. In cases where any part of this Policy is found to be in contravention of local laws or regulations, such conflicting portion shall not be enforceable, and all other aspects of this Policy shall continue to apply as intended.
Updates to the COPPA Compliance Policy
Smart Innovations may update this COPPA Compliance Policy to reflect changes in legal requirements, industry practices, or the operation of the Application. In case of material changes, the Company will provide notice through appropriate channels and obtain any required verifiable parental consent.
Questions and Complaints
If you have a question about this Policy or the Institution's handling of your information, you can send contact the Institution's COPPA Compliance Lead mentioned on its home page. If you believe that the Institution has not complied with this Policy or acted otherwise than in accordance with COPPA, you should utilize the Institution's Complaints procedure and should also notify the Institution's COPPA Lead and its principal or headmaster. You can also make a referral to or lodge a complaint with the regulator, although the regulator recommends that steps are taken to resolve the matter with the Institution before involving the regulator.
If you have any other questions, you may contact us at:
Smart Innovations Inc.
Privacy Officer
1032 E Brandon Boulevard #1550
Brandon, Florida 33511-5509
United States
Tel: +1 (813) 322-2780
coppa@EpicEMIS.org
Smart Innovations is dedicated to upholding the principles of COPPA and ensuring that children's personal information is handled with the utmost care and responsibility. By adhering to the guidelines outlined in this COPPA Compliance Policy, the Company aims to create a safe and enriching educational environment for children using the Application.
Last Updated: 20 August 2023