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Less clear, though, is whether COPPA covers information such as IP (internet protocol) address, device identification number, the type of browser being used, or other so-called metadata that can often be used to identify users.

some school lawyers have taken the FTC’s previous guidance to mean that their districts must get consent from every single parent, for every single product that collects information online from young children.

First, according to the FTC, schools can grant consent on behalf of parents only when the operator of the website, online service, or app in question is providing a service that is “solely for the benefit of students and the school system” and is specific to “the educational context.”

How are schools supposed to determine if a website or app is strictly educational?

will any information collected from children under 13 be used or shared for commercial purposes unrelated to education? Are schools allowed to review the information collected on students? Can schools request that student info be deleted? If the answers to that second group of questions are, respectively, yes, no, or no, schools are not allowed to grant consent on behalf of parents, according to the FTC.

Many vendors also allow third-party trackers (usually related to analytics or advertising) to be embedded into their sites and services.

How do schools notify parents and get their consent under COPPA?

Often through an Acceptable Use Policy or similar document that is sent home to parents at the beginning of the school year, said Fitzgerald of Common Sense Media.

Even better, Fitzgerald said, is when schools provide a detailed list of exactly what websites/online services/apps students will be using, and what the information practices of each are.

responsibility for deciding “whether a particular site’s or service’s information practices are appropriate” not be delegated to teachers.

Many districts do in fact have that kind of review-and-approval process.

Old vendor relationships may no longer be as critical, and you might end up dealing with anyone from Amazon to Apple, players who only recently began to play in the enterprise space.