The Children's Online Privacy Protection Act (15 U.S.C. 6501 to 6506, regulations at 16 CFR Part 312) applies to online services that knowingly collect personal information from children under 13. The default rule is that the operator gives notice and gets verifiable consent from a parent before collecting anything. Schools are the practical wrinkle, because no teacher is going to chase 28 permission forms for every tool.
What the FTC says about schools
The Federal Trade Commission's COPPA guidance says a school can stand in for the parent and consent, but only in the educational context: where the operator collects information from students for the use and benefit of the school and for no other commercial purpose. The FTC finalized amendments to the rule in 2025, with a compliance date of April 22, 2026, adding items such as a written information security program and a written data retention policy. The FTC did not finalize its proposed education-specific provisions, so school consent still rests on its existing guidance.
What this means for you: a school can consent for educational use. A school cannot consent to advertising, to selling data, or to use of student information for the vendor's own commercial purposes. That limit is the real test of any tool.
How ClassSense handles under-13 students
- School-consent model. A student can only join through a class code a teacher issues. ClassSense relies on the school or teacher to consent in place of parents, for educational use.
- Limited collection. Account details such as name and email, plus learning activity: answers, mastery scores, game activity and the settings a student chooses. We run no advertising trackers.
- No advertising, no sale. Student data is used only to operate the adaptive learning service.
- Parent review and deletion. A parent linked through a teacher-issued invite code can see their own child's information. Export or deletion can be requested through the teacher, from the account, or by email to us, and email requests are completed within 30 days.
- Nicknames. Class games use a student-chosen nickname, and the nickname text goes through an automated moderation check before it is shown.
A sensible setup order
Check your district
Ask whether it has authorized teachers to consent for educational tools, and whether it wants a notice to parents.
Create the class
Students join with the class code. Do not post the code publicly.
Keep uploads instructional
Upload lessons and readings, not rosters or graded student work.
Know the exits
Tell families who to contact to see or delete a child's data.
What we have not done
- We do not run our own verifiable parental consent process. If a school will not stand in for parents, ClassSense cannot be used with that school's under-13 students.
- No outside body has certified our COPPA practices.
- The 2025 amendments call for a written information security program and a written retention policy. Our retention terms are in the privacy policy and the security description is in the security overview, but we have not published separate documents under those titles. A district that wants them should ask.
For what happens to student information and AI, read student data and AI. For the FERPA side, see FERPA and ClassSense.
Plain-language summary, not legal advice. Last reviewed October 2026. Laws and regulations change, so have your district's counsel confirm anything you rely on.
Common questions
Does ClassSense collect parental consent for students under 13?
No. We rely on the school or teacher to consent in place of parents for educational use, which is the approach the FTC's COPPA guidance describes. If your school will not do that, do not enroll under-13 students.
What can a school not consent to?
Under the FTC's guidance, schools can consent only for educational purposes, not for advertising or other commercial use of student information. ClassSense runs no advertising and does not sell student data.
Can a parent ask to see or delete their child's information?
Yes. A linked parent can see their child's information in the portal, and deletion or an export can be requested through the teacher or by email to us. Email requests are completed within 30 days.
Are students asked for their real names in games?
Games use a student-chosen nickname, and the nickname text goes through an automated moderation check before it is displayed.