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Illinois student privacy (SOPPA) and ClassSense

Illinois has one of the more detailed student privacy statutes for online tools. This page walks through what it asks of an operator and where ClassSense does and does not have an answer.

The Student Online Personal Protection Act, 105 ILCS 85 (usually shortened to SOPPA), covers operators of websites, online services and apps used for K-12 school purposes. The statute was amended in recent years to add duties for operators and for schools. The rules for each side are in different sections, so it helps to read them separately.

What the statute asks of an operator

Prohibitions (section 10). An operator may not knowingly engage in targeted advertising on its service, may not use covered information to amass a profile of a student for purposes other than K-12 school purposes, may not sell or rent covered information, and may not disclose it except in the listed situations.

Duties (section 15). Among them:

Section 26 sets matching duties for schools. The written-agreement requirement there does not apply to nonpublic schools, though a private school can still ask for one.

How ClassSense lines up

What we have not done

What an Illinois school should ask for

1

The written agreement

Ask for the items SOPPA requires to be addressed, in writing, before students are enrolled.

2

A breach deadline

Put the 30-day outer limit, or something shorter, in the contract.

3

Deletion confirmation

Ask for written confirmation when a deletion request is complete.

4

Subprocessor updates

Agree how you will be told when the data practices page changes.

For how we handle a request, see data processing agreements.

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. Statute cited: 105 ILCS 85, sections 10, 15 and 26.

Common questions

Is ClassSense SOPPA compliant?

We do not make that claim. We can describe how our practices compare to each SOPPA duty, and where we have gaps, but compliance is a legal conclusion for your district's counsel, and no outside party has assessed us.

Does SOPPA require a written agreement?

For public schools, yes. SOPPA requires operators and schools to have a written agreement containing the items the statute lists. The requirement does not apply to nonpublic schools.

How soon must an operator tell the school about a breach?

SOPPA's operator duties include notifying the school no later than 30 calendar days after determining a breach occurred. ClassSense's public wording has no day count, so an Illinois agreement should state the deadline.

Can a private school in Illinois use ClassSense?

Yes, subject to its own policies. The written-agreement requirement does not apply to nonpublic schools, but you can still ask for one.

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