Student data privacy
How TPA Ventures handles education records.
Plain language for directors, technology officers and parents: what we receive from a district, what we do with it, what we will never do, and which laws and agreements hold us to it.
The school official model
The district keeps control. We do the work.
FERPA lets a school share education records without parent consent with a contractor that acts as a school official, 34 CFR § 99.31(a)(1)(i)(B). Four conditions make that true for TPA Ventures, and each one is written into our agreements.
- 01
Direct control
The district decides which students, which fields and which staff. It can revoke any connector or account at any time, and it directs how records are used and maintained.
- 02
Used only for the service
Records are used to extract baselines, draft PLAAFPs, goals and prior written notices for educator review, and track IDEA timelines. Nothing else.
- 03
No redisclosure
We do not share personally identifiable information from education records with anyone except subprocessors bound by the same terms, or as the district directs under 34 CFR § 99.33.
- 04
Parents' rights stay with the district
Requests to inspect, review or amend records go to the district. If a request reaches us directly, we refer it to the district and help the district respond.
What we collect and why
Six kinds of data, each with a purpose and an end date.
Exhibit B of our NDPA lists the same categories. We do not collect biometric data, geolocation, health records outside the evaluation, discipline records or social media information.
| Data element | Source | Purpose | Retention |
|---|---|---|---|
| Roster data | District SIS via OneRoster, Ed-Fi, Clever or ClassLink | Match students to case managers, buildings and timelines | Refreshed each sync; removed one sync after the student exits; deleted with the contract |
| Evaluation reports | Uploaded by staff or exported from the IEP system | Extract baselines and scores for PLAAFP drafting, each linked to its source row | Contract term; returned and deleted within 60 days of termination |
| IEP content | Prior IEPs from the IEP system; drafts written in TPA Ventures | Provide drafting context, produce drafts for educator review, keep the audit trail | Contract term; returned and deleted within 60 days of termination |
| Progress data | Entered by staff or synced from the IEP system | Aim lines, progress reports and goal revisions | Contract term; returned and deleted within 60 days of termination |
| Staff account data | District identity provider (SSO) | Operate accounts, enforce roles, log activity, send service notices | While the account is active; audit log entries kept for the contract term |
| Website form data | Forms on tpaventures.si | Respond to trial, demo and contact requests | Until you unsubscribe or ask us to delete it |
What we never do
Eight lines we do not cross.
- Sell student data, or share it for anyone else's commercial purpose
- Use student data for advertising, targeted or otherwise
- Train, fine-tune or evaluate AI models on student data, ours or our providers'
- Redisclose education records except as the district directs or as 34 CFR § 99.33 permits
- Retain student data beyond the contract term and the deletion window the district sets
- Use student data for product analytics beyond aggregate counts that identify no student
- Give students accounts, or collect information directly from a student
- Place advertising or third-party analytics trackers inside the application
Student Privacy Pledge commitments
The Pledge is retired. Our commitments are not.
The Future of Privacy Forum closed the Student Privacy Pledge program in April 2025. TPA Ventures carries its core commitments into every customer agreement.
- No sale of student information
- No behavioral or targeted advertising
- No profiles of students for any non-educational purpose
- Transparent, published practices for collection, use and retention
- Security appropriate to the sensitivity of special education records
- Successors bound to the same commitments if TPA Ventures is ever acquired
State privacy laws we sign
Your state's agreement, on your state's form.
Where a state alliance has its own form or exhibit, we sign that. Legal typically returns a signed agreement within 10 business days.
New York
Education Law § 2-d and 8 NYCRR Part 121
We sign the district's data privacy agreement, attach the Parents' Bill of Rights for Data Privacy and Security with the required supplemental information exhibit, and meet the 7-day breach notice to the educational agency.
Illinois
Student Online Personal Protection Act, 105 ILCS 85
We sign the SOPPA agreement your district posts publicly, with the data elements, purpose, breach terms and subcontractor list the law requires schools to publish.
California
SOPIPA (Bus. & Prof. Code § 22584) and AB 1584 (Educ. Code § 49073.1)
We sign the California Student Data Privacy Agreement and include the AB 1584 contract terms: district ownership, parent access through the district, deletion on termination and no advertising.
Texas
Education Code Chapter 32, Subchapter D
We sign the Texas Student Data Privacy Agreement with its state exhibit and align our safeguards with the cybersecurity framework districts adopt under SB 820.
Every other state
SDPC National Data Privacy Agreement with state exhibits
NDPA v1 or v2 as adopted by your state alliance, with Exhibit G state terms. Districts can adopt an existing signed agreement through the General Offer of Terms.
Parents and guardians
Your child's records belong to your school district.
TPA Ventures is a tool your district's special education staff use to prepare drafts for the IEP team, which includes you. It does not make eligibility, placement or service decisions, and it does not replace the team described in 34 CFR § 300.321. Every draft is reviewed by a certified educator before it reaches a meeting.
To inspect or review records
Ask your district's special education office. FERPA gives you that right, and the district holds the records.
To request a correction
Ask the district to amend the record. If the district needs an export, a change log or a deletion from TPA Ventures, we provide it.
If you contact us directly
We will refer your request to your district within 2 business days and support the district in answering it. We cannot release records to a parent ourselves.
What we will never do with your child's data
Sell it, use it for advertising, use it to train AI models, or keep it after the district's contract ends.
A note for parents who landed here: the fastest route to your child's IEP, evaluations and progress reports is your district's special education office or your child's case manager. For questions about how TPA Ventures handles data, write to privacy@tpaventures.si.
Subprocessors
The companies that help us run the service.
We use the smallest set of providers needed, bind each to terms at least as protective as the NDPA, and limit student data to U.S. locations. The list changes only with 30 days' notice to district administrators, and districts may object in writing.
Student data privacy questions
Is TPA Ventures a school official under FERPA?
Yes. TPA Ventures performs a service the district would otherwise do with its own staff, operates under the district's direct control for use and maintenance of records, and uses records only for the purpose the district authorizes. That is the school official exception at 34 CFR § 99.31(a)(1)(i)(B). The district stays the owner and the point of contact for parents.
Does COPPA apply, and how do you meet it?
Students never create accounts or interact with TPA Ventures, so we collect nothing from a child directly. To the extent records about children under 13 reach us, they are collected by and for the school for an educational purpose under the FTC's school authorization guidance for 16 CFR Part 312, and we use them for no commercial purpose.
Can parents see what TPA Ventures produced about their child?
Yes, through the district. Drafts, extracted baselines and the audit trail are part of the education record the district controls. Parents and eligible students exercise their FERPA inspection and amendment rights with the district, and we give the district the exports it needs to respond.
What is in the audit log, and who can read it?
Every view, draft, edit, export and sync is recorded with the user, timestamp, student identifier and field changed. District administrators can read and export it. TPA Ventures staff cannot see student records without a district-approved, logged support session.
How will we know if a subprocessor changes?
District administrators receive at least 30 days' notice before a new subprocessor that handles student data is added. You may object in writing; if we cannot address the objection, you may terminate the affected service with a prorated refund.
Read the policy, then send us your agreement.
The full privacy policy covers everything on this page in contract language. Our legal team signs state agreements within 10 business days.