At Girls Who Code, we believe it’s important for parents (which we’ll use in this article to include guardians) to understand how their children use Girls Who Code in the classroom. This FAQ will help primary and secondary (K–12) schools that use Girls Who Code communicate effectively with parents about their Club Student Users’ use of Girls Who Code.
Because School Club Administrators can determine which services are available and the policies for each Club Service, each school’s use of Girls Who Code is different. Most schools have policies that govern the use of third-party services like Girls Who Code, and compliance with annual notice requirements such as under the Family Educational Education Rights and Privacy Act (FERPA) or equivalent laws in international jurisdictions. We believe that schools are in the best position to tailor the information they share with parents based on their school’s actual use of Girls Who Code. In order to help inform parents of Girls Who Code’s privacy and security practices, Girls Who Code shares such information and resources, including a copy of the COPPA required Direct Notice, with Teacher Facilitators and School Club Administrators. Teacher Facilitators must work with their ¨to determine if they already have proper permission to allow their students to use Girls Who Code in the classroom.
What permissions are needed in order for Teacher Facilitators to allow Club Students to use Girls Who Code?
Girls Who Code voluntarily follows portions of the U.S. Federal Trade Commission’s (FTC) Children’s Online Privacy Protection Act and its implementing regulations under the Children’s Online Privacy Protection Rule (collectively “COPPA”) for parental consent, including, where applicable, the use of which is commonly referred to “school consent” if a school or Teacher Facilitator elects to utilize Girls Who Code in the classroom. Girls Who Code will provide all required notices and disclosures for schools to provide to parents when utilizing school consent. Girls Who Code voluntarily follows COPPA: as a non-profit, Girls Who Code is not actually subject to COPPA. COPPA expressly states that the law applies to commercial websites and online services, and not to nonprofit entities that otherwise would be exempt from coverage under Section 5 of the FTC Act. Although nonprofit entities generally are not subject to COPPA, the FTC encourages such entities to post privacy policies online and to provide COPPA’s protections to their child visitors. For more information, please see the FTC’s FAQ (Section B).
COPPA protects the online privacy of children under the age of 13 and requires Girls Who Code to obtain parental consent or notice (as appropriate) prior (with limited exceptions) to the collection, use, and disclosure of that child's Personal Information. Due to the requirements of COPPA and similar to other cloud-based educational tools, Girls Who Code requires that schools provide parental consent if they allow Club Students under the age of 13 to access or use Girls Who Code in connection with classroom or school use. Teachers may provide parental consent through "school consent" under COPPA, where teachers have certified that they are acting as the agent of the parent and consenting on the parent’s behalf for the student to use Girls Who Code for Educational Purposes*. For clarity, it is Girls Who Code’s obligation to comply with COPPA as a whole, and we rely on schools to provide consent under COPPA by acting as the agent of the parent, but only after providing the school with the required notices set forth below. For more information on "school consent" under COPPA, please see the FTC's FAQ Section N as well as the FTC’s Policy Statement on Education Technology and COPPA.
Girls Who Code obtains parental consent directly from a child’s parent if the parent (instead of the teacher) sets up their child’s account for use in a non-school context. For more details on how we obtain parental consent directly from parents and what types of verifiable parental consent are used, please see our FAQ.
* Girls Who Code must ensure that services made available to students when schools are providing parental consent using “school consent”, are used for Educational Purposes, and are used in compliance with applicable laws and regulations (including FERPA, the Children’s Internet Protection Act, and COPPA). Note that some of the restrictions on the use of Club Student User’s Personal Information for strictly Educational Purposes may not apply once Girls Who Code additionally obtains verifiable consent directly from parents through methods like “email plus” or other approved methods.
Resources for schools to share with parents:
Below are resources that can be shared with parents which explain Girls Who Code’s Club Services and our commitments to privacy and security. This information will help parents and schools to make informed choices about the technology their Club Student Users use in the classroom.
- Download our COPPA “Direct Notice” which Girls Who Code provides to parents to review at the time Girls Who Code directly obtains parental consent (e.g., when a parent sets up their child’s account directly instead of the Teacher Facilitator). Please provide this Direct Notice to parents.
- Please see this page where we provide further transparency and an easy way for users to see the Personal Information we collect from each user type, including the sources from which the information was collected, the business purpose for which the information was collected, and the third parties with whom we disclose Personal Information for a business purpose.
- Answers to many top questions about privacy and security appear on the Girls Who Code Clubs Privacy Center.
For more information about COPPA and generally protecting children's online privacy, please visit OnGuard Online.