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:
- use reasonable security procedures and practices that meet or exceed industry standards;
- delete a student's covered information when the school asks;
- publish its terms and a privacy policy;
- enter a written agreement with the school containing the items the statute lists;
- notify the school of a breach no later than 30 calendar days after determining one occurred; and
- keep a list of the third parties that receive covered information and update it each year.
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
- Targeted advertising, profiles, sale. We run no advertising and no advertising trackers, do not sell student data, and build the mastery profile solely to decide what a student practices next.
- Security. We describe the controls we can verify in the security overview. We cannot say they meet or exceed industry standards in the statute's sense, because no outside party has assessed them. That judgment belongs to your district.
- Deletion. Deletion on request within 30 days. If your agreement sets a shorter period, raise it before signing.
- Published terms and privacy policy. See the terms and privacy policy.
- Third parties. The data practices page lists who handles data for us. That is the single list we maintain. We have not set up a separate annual update schedule for it.
- Breach notice. Email to affected account holders without undue delay after confirmation. That is a different kind of commitment from a fixed 30-day outer limit to the school. We have not committed to a 30-day outer limit in writing, so a school should put one in the agreement.
What we have not done
- We have not signed an Illinois-specific agreement with any school or district.
- We are not part of any state or consortium registry or listing.
- No outside party has assessed us against SOPPA.
- Our public documents say uploaded curriculum and student answers may be processed by an AI service. See student data and AI.
What an Illinois school should ask for
The written agreement
Ask for the items SOPPA requires to be addressed, in writing, before students are enrolled.
A breach deadline
Put the 30-day outer limit, or something shorter, in the contract.
Deletion confirmation
Ask for written confirmation when a deletion request is complete.
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.