Legal
FERPA addendum
The school-official addendum for US institutions. In legal review — here is what it will cover and what is already true.
This document is not final
It is being reviewed by a lawyer and is not published as an agreement. If you need it now, write to us and we will send the current draft, marked as a draft.
Ask us for itWhat the addendum will cover
The school-official exception under FERPA, 34 CFR §99.31(a)(1): that the institution designates Spontar as a school official with a legitimate educational interest, that we use education records only for the purposes the institution authorises, and that we do not redisclose them.
Where a state has its own student-privacy statute — and more than a hundred do — a state addendum sits alongside it.
What is already true
- No student email addresses and no directory information beyond a display name a teacher typed.
- No advertising, no advertising technology, and no sale of anything about a student. This is the substance of most state statutes and it is a design decision rather than a commitment.
- No behavioural profile, and no AI model receives lesson records. The one exception to "no student data": a class-list import may send column headings and up to five sample rows, shown to a person for review.
- Deletion on request, and automatic deletion on the institution's schedule.
Note that data is currently stored in the EU. For a US school that is usually acceptable and occasionally is not — if your district requires in-country storage, we cannot serve you yet, and we would rather say that now than at contract stage.
Why it is not published
FERPA and the state statutes are US law and we are a German company. This needs a US lawyer, and we have not engaged one.