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Creativity
Collaboration
Critical Thinking
Communication

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Infographic

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Socratic Seminar--Critical thinking, collaboration, communication all clearly evident. Student engagement and knowledge.

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The 4Cs: Making 21st Century Education Happen

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Applications of the 4Cs, how the 4Cs work together

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As a middle or high school career readiness teacher, you likely need to teach 21st century skills as part of your curriculum.

While all twelve of those skills are necessary to teach, the "four C's" are often considered to be the most important.
The four C's of 21st Century skills are:

1. Critical thinking

2. Creativity

3. Collaboration

4. Communication

These four skills are essential for modern students to succeed in school and the workplace.

They often make the biggest impact in terms of setting your students apart when applying for and starting their careers.
In this article, you'll discover what each skill entails and why they are so important to teach.
You'll also be able to download a free guide on how you can teach the 4 C's of 21st Century skills in middle or high school courses.

1. Critical Thinking
Critical thinking is the practice of solving problems, among other qualities.
In addition to working through problems, solving puzzles, and similar activities, critical thinking also includes an element of skepticism.

This is important in the 21st Century because it's harder than ever to verify accurate information (mostly thanks to the Internet).

Critical thinking empowers students to discover the truth in assertions, especially when it comes to separating fact from opinion.

Free Critical Thinking Lesson Download Related Resource:

With critical thinking, students don't just learn a set of facts or figures. Instead, they learn how to discover the facts and figures for themselves.

They ask questions. They become engaged in the world around them. They help others think critically, too.

That might be the most important part of critical thinking. Once one student has it mastered, it quickly spreads to their peers.

Whether they learn how to think critically from spending time online or simply asking "Why?" in everyday life, this skill prepares students for a life of independence and purposeful thought.

Still, critical thinking is just one of the four C's in 21st Century skills.

It works just fine when students use it alone. But when students combine it with the next skill, the sky is the limit to what they can achieve.

2. Creativity
Creativity is the practice of thinking outside the box.
While creativity is often treated like a you-have-it-or-you-don't quality, students can learn how to be creative by solving problems, creating systems, or just trying something they haven't tried before.

That doesn't mean every student will become an artist or a writer.

Instead, it means they'll be able to look at a problem from multiple perspectives - including those that others may not see.

Creativity allows students to embrace their inner strengths from big-picture planning to meticulous organization.

As a student learns about their creativity, they also learn how to express it in healthy and productive ways.

More importantly, they also become motivated to share that creativity with others.

Just like with critical thinking, that makes creativity contagious.

One student creates an interesting or innovative solution to a problem. Then, when they share it, the next student can become inspired to try something similar.

That's not to say every single creative endeavor will be a ringing success. Students will fail at some point, and some of their ideas simply won't work.

But that's okay. The point of creativity is to encourage students to think differently than convention demands.

They don't have to do things the way they've always been done.

Instead, they can figure out a better way.

Students don't have to embrace their creativity alone, either.

In fact, creativity works best when combined with the next 21st Century skill.

3. Collaboration
Collaboration is the practice of working together to achieve a common goal.
Collaboration is important because whether students realize it or not, they'll probably work with other people for the rest of their lives.

Virtually every job requires someone to work with another person at some point, even if it's for something as simple as what to get for lunch.

Practicing collaboration and teamwork helps students understand how to address a problem, pitch solutions, and decide the best course of action.

It's also helpful for them to learn that other people don't always have the same ideas that they do.

In fact, as students practice collaboration more and more, they'll learn that they have almost none of the same ideas that others do.

This can affect students in one of two ways. First, it could discourage them since nobody seems to agree with them that often. Second, it could embolden them because they realize they're bringing something unique to every conversation.

As a teacher, it's crucial that you encourage students to look at themselves through that second lens.

That way, students learn that they should speak up when they have an idea.

They may not be on the money 100% of the time - and some of their peers may have strong, opinionated reactions - but it'll teach them to speak up when they're working with others.
Communication is the practice of conveying ideas quickly and clearly.
4. Communication

Communication is often taken for granted in today's society. After all, if you say something, that means you conveyed an idea, right?

Not exactly.

In the age of text-based communications - SMS, emails, social media, etc. - it's never been more important for students to learn how to convey their thoughts in a way that others can understand them.

That's because text-based communications lack tone, which is critical to understanding the context of someone's words.

Still, even in situations where vocal tone is available, students need to learn how to communicate effectively.

That includes minimizing tangents, speaking directly to an idea, and checking other participants to make sure they're engaged.

Reading an audience - even if it's just two other people in a group discussion - lets students determine whether they should keep expanding on an idea or wrap up their point.

Their audience could even be their family at Thanksgiving dinner.

The point is that as students practice communication, they become better at efficiently conveying an idea without losing their point "in the weeds," so to speak.

With communication locked down, students can streamline their ideas and make a positive impression on those around them.

Still, it's important to note that communication isn't enough on its own to help students with 21st Century skills.

To really succeed, students need to use all four of these skills together.
The four C's of 21st Century skills let students create a whole that's greater than the sum of its parts.
How Do the Four C's Work Together?

That may sound overly-generalized, and you may be right. But the skills themselves are so general that it's difficult to pin down what, why, or how students should learn the four C's.

It's most accurate to say that students need the four C's for any and every reason.

Critical thinking teaches students to question claims and seek truth.

Creativity teaches students to think in a way that's unique to them.

Collaboration teaches students that groups can create something bigger and better than you can on your own.

Communication teaches students how to efficiently convey ideas.

Combined, the four C's empower students to become one-person think tanks.

Then, when those students get together, they can achieve almost anything!

How Do You Teach the Four C's of 21st Century Skills?

Now you know what the four C's of 21st Century skills are and why employers want new hires to have them.
Click below to get your free guide on teaching critical thinking, creativity, collaboration, and communication!
So now you're probably wondering how to teach 21st Century skills in your daily middle and high school classes.

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What Are the 4 C's of 21st Century Skills?

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Need to teach 21st Century skills in your classroom? Learn why 'the four C's' are the most important ones to focus on and how you can teach them.

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Internet safety for children, specifically in regard to what they can access, the information they could potentially provide, filtering content, and other potential dangers online.

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The Children's Internet Protection Act (CIPA) was enacted by Congress in 2000 to address concerns about children's access to obscene or harmful content over the Internet. CIPA imposes certain requirements on schools or libraries that receive discounts for Internet access or internal connections through the E-rate program - a program that makes certain communications services and products more affordable for eligible schools and libraries. In early 2001, the FCC issued rules implementing CIPA and provided updates to those rules in 2011.

What CIPA requires

Schools and libraries subject to CIPA may not receive the discounts offered by the E-rate program unless they certify that they have an Internet safety policy that includes technology protection measures. The protection measures must block or filter Internet access to pictures that are: (a) obscene; (b) child pornography; or (c) harmful to minors (for computers that are accessed by minors). Before adopting this Internet safety policy, schools and libraries must provide reasonable notice and hold at least one public hearing or meeting to address the proposal.

Schools subject to CIPA have two additional certification requirements: 1) their Internet safety policies must include monitoring the online activities of minors; and 2) as required by the Protecting Children in the 21st Century Act, they must provide for educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms, and cyberbullying awareness and response.

Schools and libraries subject to CIPA are required to adopt and implement an Internet safety policy addressing:

Access by minors to inappropriate matter on the Internet;

The safety and security of minors when using electronic mail, chat rooms and other forms of direct electronic communications;

Unauthorized access, including so-called "hacking," and other unlawful activities by minors online;

Unauthorized disclosure, use, and dissemination of personal information regarding minors; and

Measures restricting minors' access to materials harmful to them.

Schools and libraries must certify they are in compliance with CIPA before they can receive E-rate funding.

CIPA does not apply to schools and libraries receiving discounts only for telecommunications service only;

An authorized person may disable the blocking or filtering measure during use by an adult to enable access for bona fide research or other lawful purposes.

CIPA does not require the tracking of Internet use by minors or adults.

You can find out more about CIPA or apply for E-rate funding by contacting the Universal Service Administrative Company's (USAC) Schools and Libraries Division (SLD). SLD also operates a client service bureau to answer questions at 1-888-203-8100 or via email through the SLD website.

Printable Version

Children's Internet Protection Act (CIPA) (pdf)

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Children's Internet Protection Act (CIPA)

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The Children's Internet Protection Act (CIPA) was enacted by Congress in 2000 to address concerns about children's access to obscene or harmful content over the Internet.

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Applies to minors under 13 and the data that websites and apps can collect.

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A GUIDE FOR BUSINESS AND PARENTS AND SMALL ENTITY COMPLIANCE GUIDE

The following FAQs are intended to supplement the compliance materials available on the FTC website. In addition, you may send questions or comments to the FTC staff's COPPA mailbox, CoppaHotLine@ftc.gov. This document represents the views of FTC staff and is not binding on the Commission. To view the Rule and compliance materials, go to the FTC's Children's Privacy page for businesses. This document serves as a small entity compliance guide pursuant to the Small Business Regulatory Enforcement Fairness Act.

Some FAQs refer to a document called a Statement of Basis and Purpose. A Statement of Basis and Purpose is a document an agency issues when it promulgates or amends a rule that explains the rule's provisions and addresses comments received in the rulemaking process. A Statement of Basis and Purpose was issued when the COPPA Rule was promulgated in 1999, and another Statement of Basis and Purpose was issued when the Rule was revised in 2013.
A. GENERAL QUESTIONS ABOUT THE COPPA RULE B. COPPA ENFORCEMENT C. PRIVACY POLICIES AND DIRECT NOTICES TO PARENTS D. WEBSITES AND ONLINE SERVICES DIRECTED TO CHILDREN, INCLUDING MIXED AUDIENCE SITES AND SERVICES E. THIRD PARTIES, SUCH AS AD NETWORKS AND PLUG-INS, COLLECTING PERSONAL INFORMATION ON SITES DIRECTED TO CHILDREN F. PHOTOS, VIDEOS, AND AUDIO RECORDINGS G. GEOLOCATION DATA H. GENERAL AUDIENCE AND TEEN SITES OR SERVICES I. VERIFIABLE PARENTAL CONSENT J. EXCEPTIONS TO PRIOR PARENTAL CONSENT K. PARENTAL ACCESS TO CHILDREN'S PERSONAL INFORMATION L. DISCLOSURE OF INFORMATION TO THIRD PARTIES M. REQUIREMENT TO LIMIT INFORMATION COLLECTION N. COPPA AND SCHOOLS O. COPPA SAFE HARBOR PROGRAMS
A. GENERAL QUESTIONS ABOUT THE COPPA RULE

1. What is the Children's Online Privacy Protection Rule?

Congress enacted the Children's Online Privacy Protection Act (COPPA) in 1998. COPPA required the Federal Trade Commission to issue and enforce regulations concerning children's online privacy. The Commission's original COPPA Rule became effective on April 21, 2000. The Commission published an amended Rule on January 17, 2013. The amended Rule took effect on July 1, 2013.

The primary goal of COPPA is to place parents in control over what information is collected from their young children online. The Rule was designed to protect children under age 13, while accounting for the dynamic nature of the Internet. The Rule applies to operators of commercial websites and online services (including mobile apps and IoT devices, such as smart toys) directed to children under 13 that collect, use, or disclose personal information from children, or on whose behalf such information is collected or maintained (such as when personal information is collected by an ad network to serve targeted advertising). The Rule also applies to operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13, and to websites or online services that have actual knowledge that they are collecting personal information directly from users of another website or online service directed to children. Operators covered by the Rule must:

1. Post a clear and comprehensive online privacy policy describing their information practices for personal information collected online from children;

2. Provide direct notice to parents and obtain verifiable parental consent, with limited exceptions, before collecting personal information online from children;

3. Give parents the choice of consenting to the operator's collection and internal use of a child's information, but prohibiting the operator from disclosing that information to third parties (unless disclosure is integral to the site or service, in which case, this must be made clear to parents);

4. Provide parents access to their child's personal information to review and/or have the information deleted;

5. Give parents the opportunity to prevent further use or online collection of a child's personal information;

6. Maintain the confidentiality, security, and integrity of information they collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security;

7. Retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use; and

8. Not condition a child's participation in an online activity on the child providing more information than is reasonably necessary to participate in that activity.

2. Who is covered by COPPA?

The Rule applies to operators of commercial websites and online services (including mobile apps and IoT devices) directed to children under 13 that collect, use, or disclose personal information from children. It also applies to operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13. The Rule also applies to websites or online services that have actual knowledge that they are collecting personal information directly from users of another website or online service directed to children.

3. What is Personal Information?

The Rule defines personal information to include:

First and last name;

A home or other physical address including street name and name of a city or town;

Online contact information;

A screen or user name that functions as online contact information;

A telephone number;

A Social Security number;

A persistent identifier that can be used to recognize a user over time and across different websites or online services;

A photograph, video, or audio file, where such file contains a child's image or voice;

Geolocation information sufficient to identify street name and name of a city or town; or

Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

4. Where can I find information about COPPA?

The FTC has a comprehensive website that provides information to the public on a variety of agency activities. The Children's Privacy section includes a variety of materials regarding COPPA, including all proposed and final Rules, public comments received by the Commission in the course of its rulemakings, guides for businesses, parents, and teachers, information about the Commission-approved COPPA safe harbor programs, and FTC cases brought to enforce COPPA. Many of the educational materials on the FTC website also are available in hard copy free of charge at www.bulkorder.ftc.gov.

5. What should I do if I have questions about the COPPA Rule?

The first thing you should do is read the FTC's Children's Privacy guidance materials. If, after reviewing the FTC's online materials, you continue to have specific COPPA questions, please send an email to our COPPA hotline at CoppaHotLine@ftc.gov.

6. What should I do if I have a complaint about someone violating the COPPA Rule?

If you want to help law enforcement potentially spot a pattern of violations requiring law enforcement action, you may report that to the FTC online. You also may call our toll free telephone number at (877) FTC-HELP to report to a live operator. Please note that the FTC does not resolve individual consumer disputes. If you have a complaint about someone violating the COPPA Rule and need individual help, you should contact your State Attorney General.

7. I know that COPPA doesn't just apply to websites, but also to "online services." What types of online services does COPPA apply to?

COPPA applies to personal information collected online by operators of both websites and online services. The term "online service" broadly covers any service available over the Internet, or that connects to the Internet or a wide-area network. Examples of online services include services that allow users to play network-connected games, engage in social networking activities, purchase goods or services online, receive online advertisements, or interact with other online content or services. Mobile applications that connect to the Internet, Internet-enabled gaming platforms, connected toys, smart speakers, voice assistants, voice-over-Internet protocol services, and Internet-enabled location-based services also are online services covered by COPPA.

8. Does COPPA apply to information about children collected online from parents or other adults?

No. COPPA only applies to personal information collected online from children, including personal information about themselves, their parents, friends, or other persons. However, the Commission's 1999 Statement of Basis and Purpose notes that the Commission expects that operators will keep confidential any information obtained from parents in the course of obtaining parental consent or providing for parental access pursuant to COPPA. See 64 Fed. Reg. 59888, 59902 n.213.

9. Why does COPPA apply only to children under 13? What about protecting the online privacy of teens?

In enacting the Children's Online Privacy Protection Act, Congress determined to apply the statute's protections only to children under 13, recognizing that younger children are particularly vulnerable to overreaching by marketers and may not understand the safety and privacy issues created by the online collection of personal information.

Although COPPA does not apply to teenagers, the FTC is concerned about teen privacy and does believe that strong, more flexible, protections may be appropriate for this age group. See FTC Report: Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers (Mar. 2012), at 29, 60. The FTC also has issued a number of guidance documents for teens and their parents. These educational materials are available at www.OnguardOnline.gov.

10. I know the COPPA Rule is triggered by the collection of personal information from children, but the information I collect at my site or service is voluntary, not mandatory. Does COPPA still apply?

Yes. The Rule governs the online collection of personal information from children by a covered operator, even if children volunteer the information or are not required by the operator to input the information to participate on the website or service. The Rule also covers operators that allow children publicly to post personal information. Finally, the Rule defines "collection" to include the passive tracking of children's personal information through a persistent identifier, and not just active collection. See 16 C.F.R. § 312.2 (definition of "collection").

11. Will the COPPA Rule keep my child from accessing inappropriate materials, such as pornography?

No. COPPA is meant to give parents control over the online collection, use, or disclosure of personal information from children. It was not designed to protect children from viewing particular types of content wherever they might go online. If you are concerned about your children seeing inappropriate materials online, you may want to consider a filtering program or an Internet Service Provider that offers tools to help screen out or restrict access to such material. Information about such tools is available at ConnectSafely.org and Stay Safe Online's advice about parental controls, and from operating system developers.

12. Will the COPPA Rule prevent children from lying about their age to register for general audience sites or online services whose terms of service prohibit their participation?

No. COPPA covers operators of general audience websites or online services only where such operators have actual knowledge that a child under age 13 is the person providing personal information. The Rule does not require operators to ask the age of visitors. However, an operator of a general audience site or service that chooses to screen its users for age in a neutral fashion may rely on the age information its users enter, even if that age information is not accurate. In some circumstances, this may mean that children are able to register on a site or service in violation of the operator's Terms of Service. If, however, the operator later determines that a particular user is a child under age 13, COPPA's notice and parental consent requirements will be triggered.

Importantly, however, a website or online service may be deemed directed to children even if its Terms of Service prohibits children from using the site or service. In determining whether a particular site or service is directed to children, the FTC will consider the factors set forth in the Rule. See 16 C.F.R. 312.2 (definition of "Web site or online service directed to children"); see also FAQs Section D.

B. COPPA ENFORCEMENT

1. How does the FTC enforce the Rule?

Information about the FTC's COPPA enforcement actions can be found by clicking on the Cases link on the FTC's Children's Privacy page. Parents, consumer groups, industry members, and others that believe an operator is violating COPPA may report that to the FTC online or call our toll free telephone number at (877) FTC-HELP.

2. What are the penalties for violating the Rule?

A court can hold operators who violate the Rule liable for civil penalties of up to $51,744 per violation. The amount of civil penalties the FTC seeks or a court assesses may turn on a number of factors, including the egregiousness of the violations, whether the operator has previously violated the Rule, the number of children involved, the amount and type of personal information collected, how the information was used, whether it was shared with third parties, and the size of the company. The determination of the appropriate civil penalty will vary on a case-by-case basis. In some cases, the FTC has elected to seek no civil penalty, while in other cases, the penalties have been millions of dollars. Information about the FTC's COPPA enforcement actions, including the amounts of civil penalties obtained, can be found by clicking on the Cases link on the FTC's Children's Privacy page.

3. Can the states or other federal government agencies enforce COPPA?

Yes. COPPA gives states and certain federal agencies authority to enforce compliance with respect to entities over which they have jurisdiction. For example, New York has brought several COPPA enforcement actions. See https://ag.ny.gov/press-release/2019/ag-james-google-and-youtube-pay-record-figure-illegally-tracking-and-collecting (Sept. 2019); https://ag.ny.gov/press-release/2018/ag-underwood-announces-record-coppa-settlement-oath-formerly-aol-violating (Dec. 2018); https://ag.ny.gov/press-release/2016/ag-schneiderman-announces-results-operation-child-tracker-ending-illegal-online (Sept. 2016). In addition, some federal agencies, such as the Office of the Comptroller of the Currency and the Department of Transportation, are responsible for handling COPPA compliance for the specific industries they regulate.

4. What should I do if my website or app doesn't comply with the Rule?

First, until you get your website or online service into compliance, you must stop collecting, disclosing, or using personal information from children under age 13.

Second, carefully review your information practices and your online privacy policy. In conducting your review, look closely at what information you collect, how you collect it, how you use it, whether the information is necessary for the activities on your site or online service, whether you have adequate mechanisms for providing parents with notice and obtaining verifiable consent, whether you have adequate methods for parents to review and delete their children's information, and whether you employ adequate data security, retention, and deletion practices.

Educational materials aimed at operators of websites and online services are available in the Children's Privacy section of the FTC's Business Center, including Children's Online Privacy Protection Rule: Six Step Compliance Plan for Your Business. See also Marketing Your Mobile App: Get it Right From the Start. These materials can provide you with helpful guidance. You might also choose to consult with one of the Commission-approved COPPA Safe Harbor Programs or seek the advice of counsel.

5. Are websites and online services operated by nonprofit organizations subject to the Rule?

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. In general, because many types of nonprofit entities are not subject to Section 5 of the FTC Act, these entities are not subject to the Rule. However, nonprofit entities that operate for the profit of their commercial members may be subject to the Rule. See FTC v. California Dental Association, 526 U.S. 756 (1999). 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.

6. Does COPPA apply to websites and online services operated by the Federal Government?

As a matter of federal policy, all websites and online services operated by the Federal Government and contractors operating on behalf of federal agencies must comply with the standards set forth in COPPA. See OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002 (Sept. 2003).

7. The Internet is a global medium. Do websites and online services developed and run abroad have to comply with the Rule?

Foreign-based websites and online services must comply with COPPA if they are directed to children in the United States, or if they knowingly collect personal information from children in the U.S. The law's definition of "operator" includes foreign-based websites and online services that are involved in commerce in the United States or its territories. As a related matter, U.S.-based sites and services that collect information from foreign children also are subject to COPPA.

C. PRIVACY POLICIES AND DIRECT NOTICES TO PARENTS

1. My child-directed website doesn't collect any personal information. Do I still need to post a privacy policy online?

COPPA applies only to those websites and online services that collect, use, or disclose personal information from children. However, the FTC recommends that all websites and online services - particularly those directed to children - post privacy policies online so visitors can easily learn about the operator's information practices. See Mobile Apps for Kids: Disclosures Still Not Making the Grade (Dec. 2012) and Mobile Apps for Kids: Current Privacy Disclosures are Disappointing (Feb. 2012).

2. What information must I include in my online privacy policy?

Section 312.4(d) of the Rule identifies the three categories of information that you must disclose in your online privacy policy:

The name, address, telephone number, and email address of all operators collecting or maintaining personal information through the site or service (or, after listing all such operators, provide the contact information for one that will handle all inquiries from parents);

A description of what information the operator collects from children, including whether the operator enables children to make their personal information publicly available, how the operator uses such information, and the operator's disclosure practices for such information; and

That the parent can review or have deleted the child's personal information and refuse to permit its further collection or use. You must also state the procedures for doing so. See 16 C.F.R. § 312.4(d).

3. May I include promotional materials in my privacy policy?

No. The Rule requires that privacy policies must be "clearly and understandably written, complete, and must contain no unrelated, confusing, or contradictory materials." See 16 C.F.R. § 312.4(a) ("General principles of notice").

4. Do I have to list the names and contact information of all the operators collecting information at my website? This will make my online privacy policy very long and confusing.

The Rule provides that, if there are multiple operators collecting information through your site (including via plug-ins), you may list the name, address, phone number, and email address of one operator who will respond to all inquiries from parents regarding all of the operators' privacy policies and use of children's information, as long as the names of all the operators are also listed in this online notice. See 16 C.F.R. § 312.4(d)(1). If you wish to keep your online privacy policy simple, you may include a clear and prominent link in the privacy policy to the complete list of operators, as opposed to listing every operator in the policy itself. You must ensure, however, that your privacy policy signals parents to, and enables them easily to access, this list of operators. See .com Disclosures: How to Make Effective Disclosures in Digital Advertising (Mar. 2013), at ii.

5. Do I have to disclose in my privacy policy and direct notices to parents the collection of "cookies," "GUIDs," "IP addresses," or other passive information collection technologies on or through my site?

The Rule defines "personal information" to include persistent identifiers, such as a customer number held in a cookie, an IP address, a processor or device serial number, or a unique device identifier that can be used to recognize a user over time and across different websites or online services. Therefore, you will need to disclose in your privacy policy (see FAQ C.2), and in your direct notice to parents (see FAQ C.9), your collection, use or disclosure of such persistent identifiers unless (1) you collect no other "personal information," and (2) such persistent identifiers are collected on or through your site or service solely for the purpose of providing "support for the internal operations" of your site or service. For more detailed information about activities considered support for internal operations, see FAQs J.5-8, below.

6. Where should I post links to my privacy policy? If I have an app, do I need to make sure that my privacy policy is included in the app store, at the point of purchase or download?

The Rule requires that the operator post a clearly and prominently labeled link to the online privacy policy on the home or landing page or screen of the website or online service, and at each area of the site or service where personal information is collected from children. This link must be in close proximity to the requests for information in each such area. 16 C.F.R. § 312.4(d). In addition, an operator of a general audience website or online service that has a separate children's area must post a link to its notice of information practices with regard to children on the home or landing page or screen of the children's area. See 16 C.F.R. § 312.4(d).

In the case of an app, the link to the privacy policy must be on the home page of the app. The Rule does not mandate that a privacy policy be posted at the point of purchase, such as in the app store. However, there is a substantial benefit in providing greater transparency about the data practices and interactive features of child-directed apps at the point of purchase and we encourage it as a best practice. In fact, the FTC Staff Report, Mobile Apps for Kids: Disclosures Still Not Making the Grade (Dec. 2012), notes that "information provided prior to download is most useful in parents' decision-making since, once an app is downloaded, the parent already may have paid for the app. . ." See p. 7. In addition, if a child-directed app were designed to collect personal information as soon as it is downloaded, it would be necessary to provide the direct notice and obtain verifiable consent at the point of purchase or to insert a landing page where a parent can receive notice and give consent before the download is complete.

7. Is it okay for the link to my privacy policy to be located at the bottom of the home page of my website?

The Rule states that the "operator must post a prominent and clearly labeled link to an online notice of its information practices with regard to children on the home or landing page or screen of its Web site or online service, and, at each area of the Web site or online service where personal information is collected from children." 16 C.F.R. § 312.4(d). In the 1999 Statement of Basis and Purpose, the Commission explained that "'clear and prominent' means that the link must stand out and be noticeable to the site's visitors through use, for example, of a larger font size in a different color on a contrasting background. The Commission does not consider 'clear and prominent' a link that is in small print at the bottom of the home page, or a link that is indistinguishable from a number of other, adjacent links." See 64 Fed. Reg. 59888, 59894. A link that is at the bottom of the page may be acceptable if the manner in which it is presented makes it clear and prominent.

8. I operate a general audience website that contains a specific children's section. May I post a single privacy policy for the entire site that combines information about my children's and general information practices, or must I have a separate privacy policy for children's data?

In the 1999 Statement of Basis and Purpose, the Commission noted that "operators are free to combine the privacy policies into one document, as long as the link for the children's policy takes visitors directly to the point in the document where the operator's policies with respect to children are discussed, or it is clearly disclosed at the top of the notice that there is a specific section discussing the operator's information practices with regard to children." See 64 Fed. Reg. 59888, 59894 n.98. This advice remains in effect. Operators should also ensure that the link for the children's portion of the privacy policy appears on the home page or screen of the children's area of the site or service, and at each area where personal information is collected from children. See 16 C.F.R. § 312.4(d).

9. I know that the Rule requires that I provide a direct notice to parents before I collect personal information from children. What information must be included in the direct notice?

The Rule requires operators to make reasonable efforts, taking into account available technology, to ensure that a parent of a child receives direct notice of the operator's practices with regard to the collection, use, or disclosure of personal information from children, including notice of any material changes to practices to which the parent previously consented. The Rule provides a very detailed roadmap of what information must be included in your direct notice in four specific instances.

First: Where an operator collects the name or online contact information of a parent or child in order to obtain a parent's verifiable consent prior to the collection, use, or disclosure of a child's personal information. In this case, the direct notice must:

State that the operator has collected the parent's online contact information from the child, and, if such is the case, the name of the child or the parent, in order to obtain the parent's consent;

State that the parent's consent is required for the collection, use, or disclosure of such information, and that the operator will not collect, use, or disclose any personal information from the child if the parent does not provide such consent;

Set forth the additional items of personal information the operator intends to collect from the child, or the potential opportunities for the disclosure of personal information, should the parent provide consent;

Contain a hyperlink to the operator's online notice of its information practices (i.e., its privacy policy); Provide the means by which the parent can provide verifiable consent to the collection, use, and disclosure of the information; and

State that if the parent does not provide consent within a reasonable time from the date the direct notice was sent, the operator will delete the parent's online contact information from its records. See 16 C.F.R. § 312.4(c)(1).

Second: Where an operator voluntarily seeks to provide notice to a parent of a child's online activities that do not involve the collection, use or disclosure of personal information. In this case, the direct notice must:

State that the operator has collected the parent's online contact information from the child in order to provide notice to, and subsequently update the parent about, a child's participation in a website or online service that does not otherwise collect, use, or disclose children's personal information;

State that the parent's online contact information will not be used or disclosed for any other purpose;

State that the parent may refuse to permit the child's participation in the website or online service and may require the deletion of the parent's online contact information, and how the parent can do so; and

Provide a hyperlink to the operator's online notice of its information practices. See 16 C.F.R. § 312.4(c)(2).

Third: Where an operator intends to communicate with the child multiple times via the child's online contact information and collects no other information. In this case, the direct notice must:

State that the operator has collected the child's online contact information from the child in order to provide multiple online communications to the child;

State that the operator has collected the parent's online contact information from the child in order to notify the parent that the child has registered to receive multiple online communications from the operator;

State that the online contact information collected from the child will not be used for any other purpose, disclosed, or combined with any other information collected from the child;

State that the parent may refuse to permit further contact with the child and require the deletion of the parent's and child's online contact information, and how the parent can do so;

State that if the parent fails to respond to this direct notice, the operator may use the online contact information collected from the child for the purpose stated in the direct notice; and

Provide a hyperlink to the operator's online notice of its information practices. See 16 C.F.R. § 312.4(c)(3)

Fourth: Where the operator's purpose for collecting a child's and a parent's name and online contact information is to protect a child's safety and the information is not used or disclosed for any other purpose. In this case, the direct notice must:

State that the operator has collected the name and the online contact information of the child and the parent in order to protect the safety of a child;

State that the information will not be used or disclosed for any purpose unrelated to the child's safety;

State that the parent may refuse to permit the use, and require the deletion, of the information collected, and how the parent can do so;

State that if the parent fails to respond to this direct notice, the operator may use the information for the purpose stated in the direct notice; and

Provide a hyperlink to the operator's online notice of its information practices. See 16 C.F.R. § 312.4(c)(4).

10. When I send a direct notice to parents, may I send them a simple email containing a link to my online privacy policy?

No. As described in FAQ C.9 above, the Rule makes clear that the direct notice to parents must contain certain key information within the four corners of the notice itself, depending on the purpose for which the information is being collected. Therefore, you may not simply link to a separate online notice. Note, however, that the Rule requires that each direct notice you send also contain a link to your online privacy policy. The intention is to help ensure that the direct notice functions as an effective "just-in-time" message to parents about an operator's information practices, while also directing parents online to view any additional information contained in the operator's online notice.

11. I have an app directed to children. At what point in the download process should I send parents my direct notice?

Unless one of the limited exceptions applies (see FAQ I.2), the Rule requires that you send parents the direct notice prior to the collection of any personal information from the child. The limited exception to this is that you may collect the parent's online contact information for the sole purpose of sending the parent the direct notice. Alternatively, you may provide the direct notice to the parent through other means, such as through the device onto which the app is downloaded, if the mechanisms both (1) provide such notice and obtain the parent's consent before any collection of personal information and (2) are reasonably designed to ensure that it is the parent who receives the notice and provides the consent.

D. WEBSITES AND ONLINE SERVICES DIRECTED TO CHILDREN, INCLUDING MIXED AUDIENCE SITES AND SERVICES

1. COPPA applies to websites or online services that are "directed to children." What determines whether or not a website or online service is directed to children?

The Rule sets out a number of factors for determining whether a website or online service is directed to children. These include:

the subject matter;

visual content;

the use of animated characters or child-oriented activities and incentives;

music or other audio content;

age of models;

presence of child celebrities or celebrities who appeal to children;

language or other characteristics of the website or online service;

whether advertising promoting or appearing on the website or online service is directed to children;

competent and reliable empirical evidence regarding audience composition; and

evidence regarding the intended audience of the site or service.

See 16 C.F.R. § 312.2 (definition of "Web site or online service directed to children," paragraph (1)).

As described in FAQ E.1 below, the Rule also considers a website or online service to be "directed to children" where it has actual knowledge that it is collecting personal information directly from users of another website or online service that is directed to children. See 16 C.F.R. § 312.2 (definition of "Web site or online service directed to children," paragraph (2)).

2. I post videos for a commercial purpose on a general audience platform that hosts a wide variety of user-generated content. Do I need to comply with COPPA?

It depends. COPPA applies to commercial websites and online services that are directed to children. If the content you post on the platform is directed to kids, and personal information is collected by you or on your behalf (such as a persistent identifier used to serve targeted advertising), you will be deemed an operator of an online service that needs to comply with COPPA. By the same token, if the platform has actual knowledge that your content is directed to children and is collecting personal information, it will also need to comply with COPPA.

3. I don't know whether kids watch the videos I post on the general audience platform. How do I determine if my videos are directed to kids?

The Rule sets out a number of factors for determining whether a website or online service is directed to children (See FAQ D.1). The FTC staff recognizes that the determination of whether content is child-directed will be clearer in some contexts than in others. We can, however, provide some general guidance.

Your website or online service will not be considered "directed to children" just because some children visit your site or use your service. However, if your intended audience includes kids under 13, even if that is only a portion of your intended audience, you must comply with the Rule's requirements if you are collecting personal information from your users, or it is being collected on your behalf.

Unless you are affirmatively targeting kids, there are many subject matter categories where COPPA clearly wouldn't apply, such as those involving traditionally adult activities like employment, finances, politics, home ownership, home improvement, or content aimed at college students. On the other hand, if your content involves traditionally child-oriented activities, such as dress up games or playing with toys, you may be child-directed.

Consider the context of your videos when determining whether your content is child-directed. Although the use of bright colors and animated characters are some of the factors the FTC and courts consider in determining whether a site or service is directed to kids, the FTC recognizes that some animated characters are directed to a general audience.

Finally, you may want to consider whether there is empirical evidence about your audience composition, or other indicia about your actual audience.

Unfortunately, the FTC cannot provide an opinion on whether a specific site or service is directed to children. If you continue to have questions about whether your content is directed to children, consider contacting an attorney or consulting one of the COPPA Safe Harbor programs - self-regulatory groups that offer guidance on how operators can comply with the law.

4. I run a child-directed app. I would like to screen users so that I only have to get parental consent from children under age 13, not from everyone who uses the app. May I?

It depends. Because of its very nature, in most instances, a website or online service (such as an app) directed to children must treat all visitors as children and provide COPPA's protections to every such visitor. This means that for the most part, a website or online service directed to children may not screen users for age.

However, the Rule provides a narrow exception for a site or service that may be directed to children under the criteria set forth in FAQ D.1 above, but that does not target children as its primary audience (sometimes referred to as "mixed audience"). If your site or service targets children under age 13, but children under 13 are not your primary audience (e.g., your site also targets adults or older teens), you can take advantage of this exception . You can implement an age screen; for users who indicate they are children under 13, you can ensure that you do not collect personal information from those users, or you can obtain verifiable parental consent. It is important to emphasize that the "mixed audience" category is a subset of the "directed to children" category, and a general audience site does not become "mixed audience" just because some children use the site or service.

An operator of a site or service meeting this standard may age-screen its users if it: (1) does not collect personal information from any visitor prior to collecting age information, and (2) prevents the collection, use, or disclosure of personal information from visitors who identify themselves as under age 13 without first complying with the Rule's notice and parental consent provisions. See 16 C.F.R. § 312.2 (definition of "Web site or online service directed to children," paragraph (3)). Keep in mind that unlike a general audience website or service, as an operator of a website or online service directed to children, you may not block children from participating in the website or online service.

5. What evidence would I need to demonstrate whether children under age 13 are or are not the primary audience for my website or online service?

As the operator, you should carefully analyze who your intended audience is, the actual audience, and in many instances, the likely audience for your website or online service. In making these determinations, you should keep in mind the factors for a "Web site or online service directed to children" contained in paragraph (1) of 16 C.F.R. § 312.2. See FAQ D.1 and D.3 above. You may also get a better sense of your site or service once it has been in operation, and may need to make some changes accordingly.

6. I run a site that I believe may fall within the FTC's sub-category of a website directed to children but where it is acceptable to age-screen users because children are not the primary audience (i.e., "mixed audience"). Can I age-screen and completely block users who identify as being under age 13 from participating on my site?

No. If your site is "mixed audience" (i.e., it falls within the definition of a "Web site or online service directed to children" as set forth in paragraph (3) of 16 C.F.R. § 312.2), then you may age screen your users, but you may not block children from participating altogether. Instead, the Rule permits you to use an age screen in order to differentiate between users under age 13 and other users. You may decide to offer different activities, or functions, to your users depending upon age, but you may not collect personal information from users who have indicated they are under 13 without first obtaining verifiable parental consent.

7. I have a "mixed audience" app and would like to age screen my users. Are there specific requirements for the age screen?

In designing your age screen, you should ask age information in a neutral manner, making sure the data entry point allows users to enter their age accurately and does not default to an age 13 or over. An example of a neutral age screen would be a system that allows a user freely to enter the month and year of birth. Avoid encouraging children to falsify age information by, for example, stating that certain features will not be available to users under age 13. In addition, consistent with long standing Commission advice, FTC staff recommends using technical means, such as a cookie, to prevent children from back-buttoning to enter a different age.

8. I have a "mixed audience" app and would like to have an age screen. Can I ask a question that a child is unlikely to be able to answer, such as a math problem, to determine whether a user is 13 or over instead of asking age directly?

No. Requiring a child to answer a question he or she is unlikely to be able to answer, without more, is inadequate for determining the age of the user. There are many children under 13, for example, that can perform complex math problems, and some users over 13 that may have difficulty with those same complex problems. You may, however, use a math problem in addition to asking the age of the user, as described in FAQ D.7 above.

9. Am I required to inform third parties that my website or online service is directed to children? Even if I am not required to do so, how can I do this? If I signal the nature of my site or service, will this protect me from liability under COPPA?

The Rule does not require you to inform third parties of the child-directed nature of your site or service, and doing so, without more, will not relieve you of your obligations under COPPA. Remember, you are responsible for the collection of personal information from your users, no matter who is doing the collection; therefore, you will need to do more than simply identify yourself to third parties. As a child-directed property, absent an exception under the Rule (see FAQ I.2 below), you must: (1) not collect or allow any other entity to collect personal information from your visitors; or (2) provide notice and obtain prior parental consent before collecting or allowing any entity to collect personal information from your visitors, as well as provide all of the other COPPA protections. In addition, Commission staff recommends that operators of child-directed websites or services signal their status to third parties and you may arrange with the third party collecting the personal information to provide adequate COPPA protections.

10. I want to run ads on my child-directed websites and apps. What do I need to know to make sure that I am complying with COPPA?

There are a number of questions you must find answers to before you enter into an arrangement with any entity to serve advertising to run on your child-directed sites and services. These include:

Is there a way to control the type of advertising that appears on the sites and services? (e.g., can you stipulate and contract only for contextual advertising, and can you prohibit behavioral advertising or retargeting?)

What categories of information will be collected from users on the sites and services in connection with the ads they are served? Will persistent identifiers be collected for purposes other than support for internal operations? Will geolocation information be collected in connection with the ads served?

You should make informed decisions before you permit advertising to run on your sites and services. Depending on what advertising choices you make, you may be required to notify parents in your online privacy policies and in a direct notice, and obtain verifiable parental consent, before you permit advertising to occur. Remember that the Rule holds you liable for the collection of information that occurs on or through your sites and services, even if you yourself do not engage in such collection.

11. I have no idea what information the third parties whose content I have embedded in my kids' app might collect from my users. Do I need to know this information?

Yes. As the operator of a child-directed app, you must conduct an inquiry into the information collection practices of every third party that can collect information via your app. You need to determine each third party's information collection practices so that you can make an informed decision as to whether its presence on your app will require you to give parents notice and obtain their consent prior to their collection of personal information from children. See FAQ D.9 above.

12. I operate a child-directed app that allows kids to make paintings. I don't collect the paintings - they rest on the device - but the app includes buttons for popular email and social media providers that kids can click on within the app. The buttons open the email program or social network, populate it with the painting, and allow the child to share it along with a message. I don't collect or share any other personal information through the app. Do I have to seek verifiable parental consent?

Yes. The COPPA rule defines "collection" to include requesting, prompting, or encouraging a child to submit personal information online, and enabling a child to make personal information publicly available in identifiable form. In addition, under the COPPA Rule, "disclosure" includes making a child's personal information publicly available in identifiable form through an email service or other means, such as a social network. You must get verifiable parental consent before enabling children to share personal information in this manner, even through third parties on your app. This is true unless an exception applies. (See Section I, Exceptions to Prior Parental Consent). However, in the situation you describe - where a child can email a painting and a message or post content on his or her social networking page through your app - no exception applies.

E. THIRD PARTIES, SUCH AS AD NETWORKS AND PLUG-INS, COLLECTING PERSONAL INFORMATION ON SITES DIRECTED TO CHILDREN

1. I operate an advertising network service. Under what circumstances will I be held to have "actual knowledge" that I have collected personal information directly from users of another website or online service directed to children?

The circumstances under which you will be deemed to have acquired "actual knowledge" that you have collected personal information directly from users of a child-directed site or service will depend a lot on the particular facts of your situation. In the 2013 Statement of Basis and Purpose, the Commission set forth two cases where it believes that the actual knowledge standard will likely be met:

1. where a child-directed content provider (which is strictly liable for any collection) directly communicates the child-directed nature of its content to you, the ad network; or

2. where a representative of your ad network recognizes the child-directed nature of the content.

Under the first scenario, any direct communications that the child-directed provider has with you that indicate the child-directed nature of its content would give rise to actual knowledge. In addition, if a formal industry standard or convention is developed through which a site or service could signal its child-directed status to you, that would give rise to actual knowledge. Under the second scenario, whether a particular individual can obtain actual knowledge on behalf of your business depends on the facts. Prominently disclosing on your site or service methods by which individuals can contact your business with COPPA information - such as: 1) contact information for designated individuals, 2) a specific phone number, and/or 3) an online form or email address - will reduce the likelihood that you would be deemed to have gained actual knowledge through other employees. (See also FAQ E.2 below).

2. I operate a social media plug-in. I receive a list of websites from a parents' organization, advocacy group or someone else, which says that these websites are using my plug-in and are child-directed. Does this give me actual knowledge of the child-directed nature of these sites?

It's unlikely the receipt of a list of purportedly child-directed websites alone would constitute actual knowledge. You would have no duty to investigate. It's possible, however, that you will receive screenshots or other forms of concrete information that do give you actual knowledge that the website is directed at children. If you receive information and are uncertain whether the site is child-directed, you may ordinarily rely on a specific affirmative representation from the website operator that its content is not child-directed. For this purpose, a website operator would not be deemed to have provided a specific affirmative representation if it merely accepts a standard provision in your Terms of Service stating that, by incorporating your code, the first party agrees that it is not child directed.

3. I operate an ad network and am considering participating in a system in which first-party sites could signal their child-directed status to me, such as by explicit signaling from the embedding webpage to ad networks. I understand that I would have "actual knowledge" if I collect information from users on a first-party site that has signaled its child-directed status. Are there any benefits to me if I participate in such a system?

Such a system could provide more certainty for you. If the system requires the first-party site to affirmatively certify whether it is "child-directed" or "not child-directed," and the site signals that it is "not child-directed," you may ordinarily rely on such a representation. Such reliance is advisable, however, only if first parties affirmatively signal that their sites or services are "not child-directed." You could not set that option for them as the default.

Remember, though, that you may still be faced with screenshots or other concrete information that gives you actual knowledge of the child-directed nature of the website despite a contradictory representation by the site. If, however, such information is inconclusive, you may ordinarily continue to rely on a specific affirmative representation made through a system that meets the criteria above.

F. PHOTOS, VIDEOS, AND AUDIO RECORDINGS

1. I run a moderated website that is directed to children and I prescreen all children's submissions in order to delete personal information before postings go live. Do I have to get parental consent if I allow children to post photos of themselves but no other personal information?

Yes. The Rule considers photos, videos, and audio recordings that contain a child's image or voice to be personal information. This means that prior to posting photos, videos, and audio recordings that contain a child's image or voice, operators covered by COPPA must either (i) prescreen and delete from children's submissions any photos, videos, or audio recordings of themselves or other children or (ii), first give parents notice and obtain their consent prior to permitting children to upload any photos, videos, or audio recordings of themselves or other children.

2. I want to offer a child-directed app. The app would allow children to upload pictures of their favorite pets or places. I do not ask children to provide their email addresses or their names, or really any personal information for that matter. How does COPPA apply to me?

COPPA applies to photos, videos, and audio files that contain children's images or voices. It also applies to geolocation data contained in these files sufficient to identify street name and name of city or town. Finally, it applies to any persistent identifiers collected via the children's upload of their photos. Therefore, in order to offer an app without parental notice and consent, the operator must take the following steps:

1. Pre-screen the children's photos in order to delete any that depict images of children or to delete the applicable portion of the photo, if possible. The operator must also delete any other personal information, for example, geolocation metadata, contained in the photos prior to posting them through the app. Note that if an operator does not pre-screen, then it may be subject to civil penalties under COPPA if any personal information is collected from children without the operator first notifying parents and obtaining their consent; and

2. Ensure that any persistent identifiers are used only to support the internal operations of the app (as that term is defined in the Rule - see 16 C.F.R. 312.2) and are not used or disclosed to contact a specific individual, including through behavioral advertising, to amass a profile on a specific individual, or for any other purpose.

3. Do I have to get parental consent if first I blur images in the children's photos so that you cannot see any facial features when the pictures go live on my site?

An operator of a site directed to children does not need to notify parents or obtain their consent if it blurs the facial features of children in photos before posting them on its website. See 2013 Statement of Basis and Purpose, 78 Fed. Reg. 3972, 3982 n.123. The same goes for a site that has actual knowledge it has collected the photos from children. Before posting such photos, however, the operator must also remove any other personal information they contain, such as geolocation metadata, and ensure that it is not using or disclosing persistent identifiers collected from children in a manner that violates the Rule.

4. Does the Rule prohibit adults, such as parents, grandparents, teachers, or coaches from uploading photos of children?

COPPA only covers information collected online from children. It does not cover information collected from adults that may pertain to children. Thus, COPPA is not triggered by (1) an adult uploading photos of children on a general audience site, (2) an adult uploading photos of children in the non-child directed portion of an otherwise child-directed website (e.g., a parent's corner), or (3) an age-screened user (age 13 or older) uploading photos of children on a mixed audience site or service.

However, operators of websites or online services that are primarily directed to children (as defined by the Rule) must assume that the person uploading a photo is a child and they must design their systems either to: (1) give notice and obtain prior parental consent, or (2) remove any child images and metadata prior to posting.

5. My app is directed to children. A child can upload photos into the app and manipulate and decorate the photos in different ways, but the app does not transmit any personal information (photos or otherwise) from the child's device. Am I "collecting" personal information because the child is interacting with a photo stored on the device?

No. You are not collecting personal information simply because your app interacts with personal information that is stored on the device and is never transmitted.

6. I have a child-directed toy that includes an Internet-connected search function. The toy uses a microphone to allow the child to ask the toy a question, which the toy does by conducting an Internet search and speaking the answer back to the child. Do I need to get verifiable parental consent?

It depends. Audio files of a child's voice, like photographs and videos containing a child's image, are personal information in and of themselves and require verifiable parental consent. However, the Commission has issued an enforcement policy statement that states that when an operator collects an audio file containing a child's voice solely as a replacement for written words, such as to perform a search or fulfill a verbal instruction or request, and only maintains the file for the brief time necessary for that purpose, the FTC will not take an enforcement action against the operator for failing to obtain parental consent. The operator must, however, provide a clear online notice of its collection, use, and deletion policy regarding these audio files. The Commission reasoned that, where an operator collects an audio file in these circumstances, there is little risk that the file will be used to contact an individual child.

There are limitations on this non-enforcement policy. First, this policy is not applicable when the operator requests information via voice that otherwise would be considered personal information under the Rule, such as a name. Second, as described above, the operator must provide clear notice of its information, use, and deletion policy for these audio files in its privacy policy. Third, the operator may not make any other use of the audio file in the brief period before the file is destroyed. Finally, this policy does not affect the operator's COPPA compliance requirements in any other respect. In other words, if the operator is collecting other types of personal information, it must obtain verifiable parental consent.

G. GEOLOCATION DATA

1. I automatically collect geolocation information from users of my children's app, but I do not use this information for anything. Am I responsible for notifying parents and getting their consent to such collection?

Yes. COPPA covers the collection of geolocation information, not just its use or disclosure.

2. What if I give my users a choice to turn off geolocation information? Do I still have to notify parents and get prior parental consent?

COPPA is designed to notify parents and give them the choice to consent. Therefore, it is not sufficient to provide such notification and choice to the child user of a website or service. If the operator intends to collect geolocation information, the operator will be responsible for notifying parents and obtaining their consent prior to such collection.

3. The Rule covers "geolocation information sufficient to identify street name and name of city or town." What if my children's app only collects coarse geolocation information, tantamount to collecting a ZIP code but nothing more specific?

COPPA does not require an operator to notify parents and obtain their consent before collecting the type of coarse geolocation services described. However, the operator should be quite certain that, in all instances, the geolocation information it collects is more general than that sufficient to identify street name and name of city or town.

4. The geolocation information I collect through my app provides coordinate numbers. It does not specifically identify a street name and name of city or town. Do I have to notify parents and get their consent in this instance? What if I collect other types of information, such as wireless network information, that can be used to determine precise location?

COPPA covers the collection of geolocation information "sufficient" to identify street name and name of city or town. COPPA applies even if the child is not asked to provide an actual street address. For example, COPPA would apply if an app collects the user's longitude and latitude. Similarly, the Commission alleged that COPPA applied in United States v. InMobi Pte Ltd., where the company collected wireless network identifiers to infer the child's precise location without providing notice or obtaining verifiable parental consent.

H. GENERAL AUDIENCE AND TEEN SITES OR SERVICES

1. Am I responsible if children lie about their age during the registration process on my general audience website?

The Rule does not require operators of general audience sites to investigate the ages of visitors to their sites or services. See 1999 Statement of Basis and Purpose, 64 Fed. Reg. 59888, 59892. However, operators will be held to have acquired actual knowledge of having collected personal information from a child where, for example, they later learn of a child's age or grade from a concerned parent who has learned that his child is participating on the site or service.

2. I have an online service that is intended for teenagers. How does COPPA affect me?

COPPA applies to websites and online services that are directed to children under 13. However, although you may intend to operate a "teen service," in reality, your site may attract a substantial number of children under 13, and thus may be considered a "Web site or online service directed to children" under the Rule. Just as the Commission considers several factors in determining whether a site or service is directed to children, you too should consider your service's subject matter, visual content, character choices, music, and language, among other things. If your service targets children as one of its audiences - even if children are not the primary audience - then your service is "directed to children." If children are not your primary audience, however, you may employ a neutral age screen in order to provide COPPA's protections to only those visitors who indicate they are under age 13. See Section D above for more information on mixed audience sites. Note that sites or services directed to children cannot use the age screen to block children under age 13. See FAQ D.4 above. Once you identify child visitors, you may choose to:

1. Collect parents' online contact information to provide direct notice in order to obtain parents' consent to your information collection, use and disclosure practices; or

2. Direct child visitors to content that does not involve the collection, use, or disclosure of personal information.

3. Can I block children under 13 from my general audience website or online service?

Yes. COPPA does not require you to permit children under age 13 to participate in your general audience website or online service, and you may block children from participating if you so choose. By contrast, you may not block children from participating in a website or online service that is directed to children as defined by the Rule, even if the website or online service is also directed to users age 13 or older. See FAQ D.4 above.

If you choose to block children under 13 on your general audience site or service, you should take care to design your age screen in a manner that does not encourage children to falsify their ages to gain access to your site or service. Ask age information in a neutral manner at the point at which you invite visitors to provide personal information or to create a user ID.

In designing a neutral age-screening mechanism, you should consider:

Making sure the data entry point allows users to enter their age accurately. An example of a neutral age-screen would be a system that allows a user freely to enter month and year of birth. A site that includes a drop-down menu that only permits users to enter birth years making them 13 or older would not be considered a neutral age-screening mechanism since children cannot enter their correct ages on that site.

Avoiding encouraging children to falsify their age information, for example, by stating that visitors under 13 cannot participate or should ask their parents before participating. In addition, simply including a check box stating, "I am over 12 years old" would not be considered a neutral age-screening mechanism.

In addition, consistent with long standing Commission advice, FTC staff recommends using a cookie to prevent children from back-buttoning to enter a different age. Note that if you ask participants to enter age information, and then you fail either to screen out children under age 13 or to obtain their parents' consent to collecting these children's personal information, you may be liable for violating COPPA. See, e.g., the FTC's COPPA cases against Path, Inc., Playdom, Inc., Sony BMG Music Entertainment, and Yelp.

4. I operate a general audience video game service and do not ask visitors to reveal their ages. I do permit users to submit feedback, comments, or questions by email. What are my responsibilities if I receive a request for an email response from a player who indicates that he is under age 13?

Under the Rule's one-time response exception (16 C.F.R. § 312.5(c)(3)) you are permitted to send a response to the child, via the child's online contact information, without sending notice to the parent or obtaining parental consent. However, you must delete the child's online contact information from your records promptly after you send your response. You may not use the child's online contact information to re-contact the child (or for any other purpose), or disclose the child's online contact information. Note that if you choose not to respond to the child's inquiry, you must still immediately delete the child's personal information from your records. Additionally, such an email may give you actual knowledge that you have collected personal information from a child (e.g., if you had previously collected the child's email address as part of a website registration process). In such a circumstance, you would need to take steps to ensure that you are complying with COPPA, such as obtaining parental consent or immediately deleting any personal information collected from the child.

5. I run a video game website that has some child users, but also many adult and teen users. How do I determine if my site is "mixed audience" (i.e., directed to children but where it is acceptable to age screen) or general audience (where COPPA does not apply)?

In determining whether a website or online service is directed to children, you should carefully consider the factors set forth in the Rule, including the subject matter of the game, visual content, use of animated characters or child-oriented activities and incentives, music or other audio content, age of models, presence of child celebrities or celebrities who appeal to children, language or other characteristics of the website or online service, and whether advertising promoting or appearing on the site or service is directed to children. You should also consider any competent and empirical evidence regarding your audience composition, and who your intended audience is. The Commission considers the totality of the circumstances in determining whether a website or online service is directed to children, and no single factor is determinative. If after considering these factors you determine that your site or service is directed to children, then you can separately determine whether your site falls in the "mixed audience" subcategory - i.e., whether children are not your primary audience.

Importantly, "mixed audience" sites or services are a subcategory of "directed to children." In other words, a website or online service that is appealing to all ages and not specifically directed at children is not deemed "mixed audience" simply because some children may use the site or service. In determining whether your site or service is mixed audience, you should consider your intended audience (are you marketing to under 13 users, such as through selling related toys, for example). You should also determine whether your site or service involves child-oriented activities, such as a dress up game, and whether you have empirical evidence as to the actual users of your video game site. If you continue to have questions about whether your content is mixed audience, consider contacting an attorney or consulting one of the COPPA Safe Harbor programs - self-regulatory groups that offer guidance on how operators can comply with the law.

6. I operate a general audience online service and do not ask visitors to reveal their ages. However, I do permit users to create their own blog pages, and my service has a number of online forums. What happens if a child registers on my service and posts personal information (e.g., on a comments page) but does not reveal her age anywhere? What if a child announces her age in an online forum?

The COPPA Rule applies to an operator of a general audience website if it has actual knowledge that a particular visitor is a child. If a child posts personal information on a general audience site or service but does not reveal her age, and if the operator has no other information that would lead it to know that the visitor is a child (such as the child posting that she attends an elementary school), then the operator would not be deemed to have acquired "actual knowledge" under the Rule and would not be subject to the Rule's requirements.

Even where the child does reveal age-identifying information, if no one in your organization is aware of the post, then you may not have the requisite actual knowledge under the Rule. However, you may be considered to have actual knowledge where a child announces her age under certain circumstances, for example, if you monitor user posts, if a responsible member of your organization sees the post, or if someone alerts you to the post (e.g., a concerned parent who learns that his child is participating on your site). Where an operator knows that a particular visitor is a child, the operator must either meet COPPA's notice and parental consent requirements or delete the child's information.

I. VERIFIABLE PARENTAL CONSENT

1. When do I have to get verifiable parental consent?

The Rule provides generally that an operator must obtain verifiable parental consent before collecting any personal information from a child, unless the collection fits into one of the Rule's exceptions described in various FAQs herein. See 16 C.F.R. § 312.5(c).

2. May I first collect personal information from the child, and then get parental permission to such collection if I do not use the child's information before getting the parent's consent?

As a general rule, operators must get verifiable parental consent before collecting personal information online from children under 13. Certain, limited exceptions let operators collect certain personal information from a child before obtaining parental consent. See 16 C.F.R. § 312.5(c). These exceptions include:

Where the sole purpose of collecting the name or online contact information of the parent or child is to provide notice to the parent and obtain parental consent. Note that under this exception, if the operator has not obtained parental consent after a reasonable time from the date of the information collection, the operator must delete such information from its records;

Where the sole purpose of collecting a parent's online contact information is to provide voluntary notice about the child's participation in a website or online service that does not otherwise collect, use, or disclose children's personal information. Such information cannot be used or disclosed for any other purpose and the operator must make reasonable efforts, taking into consideration available technology, to provide a parent with appropriate notice;

Where the sole purpose of collecting online contact information from a child is to respond directly on a one-time basis to a specific request from the child, and where such information is not used to re-contact the child or for any other purpose, is not disclosed, and is deleted by the operator from its records promptly after responding to the child's request;

Where the purpose of collecting a child's and a parent's online contact information is to respond directly more than once to the child's specific request, such as to receive a monthly newsletter, and where such information is not used for any other purpose, disclosed, or combined with any other information collected from the child. Here, the operator must provide parents with notice and the means to opt out of allowing the site's future contact of the child. In providing such notice, the operator must make reasonable efforts, taking into consideration available technology, to ensure that the parent receives appropriate notice and will not be deemed to have made reasonable efforts where the notice to the parent was unable to be delivered;

Where the purpose of collecting a child's and a parent's name and online contact information, is to protect the safety of a child, and where such information is not used or disclosed for any purpose unrelated to the child's safety. Here, the operator must make reasonable efforts, taking into consideration available technology, to provide a parent with appropriate notice;

Where the purpose of collecting a child's name and online contact information is to:

Protect the security or integrity of its website or online service;

Take precautions against liability;

Respond to judicial process; or

To the extent permitted under other provisions of law, to provide information to law enforcement agencies or for an investigation on a matter related to public safety;

Where an operator collects a persistent identifier and no other personal information and such identifier is used for the sole purpose of providing support for the internal operations of the website or online service as outlined in FAQ J.5 below; or

Where a third-party operator has actual knowledge that it has a presence on a child-directed site (e.g., through a social widget or plug-in embedded on the site), it collects a persistent identifier and no other personal information from a visitor of the child-directed site, and the third-party operator's previous affirmative interaction with that user confirmed the user was not a child (e.g., an age-gated registration process).

3. I collect personal information from children who use my online service, but I only use the personal information I collect for internal purposes and I never give it to third parties. Do I still need to get parental consent before collecting that information?

It depends. First, you should determine whether the information you collect falls within one of the Rule's limited exceptions to parental consent outlined in FAQ I.2 above. If you fall outside of one of those exceptions, you must notify parents and obtain their consent. However, if you only use the information internally, and do not disclose it to third parties or make it publicly available, then you may obtain parental consent through use of the Rule's "email plus" mechanism, as outlined in FAQ I.4 below. See 16 C.F.R. § 312.5(b)(2).

4. How do I get parental consent?

You may use any number of methods to obtain verifiable parental consent, as long as the method you choose is reasonably calculated to ensure that the person providing consent is the child's parent. The Rule sets forth several non-exhaustive options, and you can apply to the FTC for pre-approval of a new consent mechanism, as set out in FAQ I.12 below.

If you are going to disclose children's personal information to third parties, or allow children to make it publicly available (e.g., through a social networking service, online forums, or personal profiles) then you must use a method that is reasonably calculated, in light of available technology, to ensure that the person providing consent is the child's parent. Specific methods identified in the Rule or otherwise approved by the Commission include:

Providing a consent form to be signed by the parent and returned via U.S. mail, fax, or electronic scan (the "print-and-send" method);

Requiring the parent, in connection with a monetary transaction, to use a credit card, debit card, or other online payment system that provides notification of each discrete transaction to the primary account holder;

Having the parent call a toll-free telephone number staffed by trained personnel, or have the parent connect to trained personnel via video-conference;

Verifying a parent's identity by checking a form of government-issued identification against databases of such information, provided that you promptly delete the parent's identification after completing the verification;

Requiring a parent to answer a series of knowledge-based challenge questions that would be difficult for someone other than the parent to answer, as separately approved by the Commission using the procedures set forth in FAQ I.12;

Verifying a picture of a driver's license of other photo ID submitted by the parent and then comparing that photo to a second photo submitted by the parent, using facial recognition technology, as separately approved by the Commission using the procedures set forth in FAQ I.12; and

If you are going to use children's personal information only for internal purposes - that is, you will not be disclosing the information to third parties or making it publicly available - then you can use any of the above methods or you can use the "email plus" method of parental consent. "Email plus" allows you to request (in the direct notice sent to the parent's online contact address) that the parent indicate consent in a return message. To properly use the email plus method, you must take an additional confirming step after receiving the parent's message (this is the "plus" factor). The confirming step may be:

Requesting in your initial message to the parent that the parent include a phone or fax number or mailing address in the reply message, so that you can follow up with a confirming phone call, fax or letter to the parent; or

After a reasonable time delay, sending another message via the parent's online contact information to confirm consent. In this confirmatory message, you should include all the original information contained in the direct notice, inform the parent that he or she can revoke the consent, and inform the parent how to do so.

5. I would like to get consent by collecting a credit card or debit card number from the parent, but I don't want to engage in a monetary transaction. Is this ok?

It depends. The general rule is that any parental consent mechanism "must be reasonably calculated, in light of available technology, to ensure that the person providing consent is the child's parent." The Rule lists several methods that automatically meet this standard, one of which is the use of a credit card, debit card, or other online payment system in connection with a monetary transaction. Importantly, the listed methods are not exhaustive; you may use other methods as long as they are "reasonably calculated" to ensure that the consent is being provided by the parent. Although collecting a 16-digit credit or debit card number alone would not satisfy the method listed in the Rule, there may be circumstances in which collection of the card number - in conjunction with implementing other safeguards - would suffice to meet the standard for verifiable parental consent. For example, you could supplement the request for credit card information with special questions to which only parents would know the answer and find supplemental ways to contact the parent.

6. I would like to use a credit card or a government-issued identification as a method of parental consent. I am worried, however, that I will not know whether it is the child's parent or another adult who is submitting identification for consent. Do I need to collect additional information to confirm that, in fact, it is the parent?

No. By providing appropriate notice and obtaining consent in connection with the Rule's proper use of a credit card or government identification, the operator will be deemed to fulfill its obligation under the Rule.

7. What do I do if some parents cannot or will not use the consent method I have chosen? For instance, some parents might not have a credit card, or might feel uncomfortable providing government identification information online.

Many operators find it useful to offer a choice of consent methods for those parents who cannot, or will not, use their primary consent mechanism. At the very least, you might consider offering one alternate method that parents might be more comfortable with, such as a print-and-send form.

8. Should I give out passwords or PIN numbers to parents to confirm their identity in any future contact with them?

Once you have notified a parent and obtained verifiable consent, providing a password or a PIN number is a good way to confirm a parent's identity for any future contact you might have with that parent. Remember that if you change your information practices in a material way in the future, you will have to send a new parental notice and obtain an updated consent to the new practices. Obtaining an updated consent may be easier if you have given the parent a password or a PIN number in your initial consent process.

In addition, the Rule requires you to give a parent access to any personal information you have collected from the child. Before you provide that information, you will need to confirm that the person requesting the information is the child's parent. Again, providing the parent a password or a PIN number makes it easier to confirm the parent's identity if the parent requests access to the child's personal information.

9. I know that I must allow parents to consent to my collection and use of their children's information, while giving them the option of prohibiting me from disclosing that information to third parties. Does that mean that if I operate a social networking site, or have chat rooms or message boards, I have to offer the same kind of "choice" about these types of sites as well?

The Rule requires an operator to give parents the option to consent to the collection and use of a child's personal information without consenting to the disclosure of such information to third parties. See 16 C.F.R. § 312.5(a)(2). However, an operator need provide this choice only where the disclosure of the information is not inherent in the activity to which the parent is consenting.

You should note that the Rule's definition of "disclosure" is broader than merely "releasing" personal information to third parties. Under the Rule, "disclosure" includes "[m]aking personal information collected by an operator from a child publicly available in identifiable form by any means, including but not limited to a public posting through the Internet, or through a personal home page or screen posted on a website or online service; a pen pal service; an electronic mail service; a message board; or a chat room." See 16 C.F.R. § 312.2.

In the case of social networking sites, chat rooms, message boards, and other similar online services, sharing personal information is a central feature of the site. Therefore, in these cases, you are not required to give parents the choice to allow you to collect and use their children's personal information, but not disclose it to third parties. However, you must clearly disclose your information collection, use, and disclosure practices in your direct notice and online privacy policy so that parents can make an informed decision about their children's participation in your site or service.

10. I am the developer of an app directed to kids. Can I use a third party, such as one of the app stores, to get parental consent on my behalf?

Yes. The Commission recognized in the 2013 Statement of Basis and Purpose that common consent mechanisms, such as one done through an app store or other platform, could benefit operators (especially smaller ones) and parents if they offer a proper means for providing notice and obtaining verifiable parental consent, as well as ongoing controls for parents to manage their children's accounts. See 78 Fed. Reg. 3972, 3989. When using a common consent method, however, you must ensure that COPPA requirements are being met. For example, you must make sure that the third party is obtaining consent in a way that is reasonably calculated, in light of available technology, to ensure that the person providing consent is the child's parent. The mere entry of an app store account number or password, for example, without other indicia of reliability (e.g., knowledge-based authentication questions or verification of government identification), does not provide sufficient assurance that the person entering the account or password information is the parent, and not the child. In addition, as the operator, you are responsible for ensuring that your direct notice accurately and completely reflects your information collection practices.

11. What types of information can I collect to obtain or confirm parental consent? Can I use a parent's mobile phone number to obtain or confirm parental consent?

The Rule permits you to collect the parent's "online contact information," defined as an email address, an IM user identifier, a VOIP identifier, a video chat user identifier, or other substantially similar identifier. A mobile phone number is not online contact information and therefore cannot be collected from the child as part of the consent initiation process. However, once you have connected with the parent via the parent's online contact information, you may request a parent's mobile phone number in order to further communicate with him or her.

12. Can I apply to the FTC for pre-approval of a new consent mechanism?

Yes. The Rule provides a mechanism for interested parties to file a written request for Commission approval of parental consent methods not currently enumerated in 16 C.F.R. § 312.5(b). See 16 C.F.R. § 312.12(a). See FTC's Verifiable Parental Consent page for information on previous requests.

13. I would like to apply to the FTC for approval of a new method of parental consent that I have developed, but I am concerned about having my trade secrets publicly posted. Is there a way to prevent this?

The Commission recognized this concern in the 2013 Statement of Basis and Purpose, noting that, "just as the Commission has done for COPPA safe harbor applicants, it would permit those entities that voluntarily seek approval of consent mechanisms to seek confidential treatment for those portions of their applications that they believe warrant trade secret protection. In the event an applicant is not comfortable with the Commission's determination as to which materials will be placed on the public record, it will be free to withdraw the proposal from the approval process." See 78 Fed. Reg. 3972, 3992.

14. I run an app store, and would like to help app developers that operate on my platform by providing a verifiable parental consent mechanism for them to use. Under what circumstances will this expose me to liability under COPPA?

The Commission recognized in the 2013 Statement of Basis and Purpose that platform methods of parental consent could benefit operators (especially smaller ones) and parents, and has made clear that operators may use one so long as it meets the Rule's notice and consent requirements. See 78 Fed. Reg. 3972, 3989. To the extent you are simply providing a verifiable parental consent mechanism - and are therefore not an "operator" under COPPA - you will not be liable under COPPA for failing to investigate the privacy practices of the operators for whom you obtain consent. At the same time, you should also evaluate your potential liability under Section 5 of the FTC Act. For example, it could be a deceptive practice to misrepresent the level of oversight you provide for a child-directed app.

J. EXCEPTIONS TO PRIOR PARENTAL CONSENT

1. I want to have a contest on my child-directed website. Can I use the Rule's "one-time contact" exception and not obtain parental consent?

Yes, if you properly design your contest. You may use the "one time contact" exception if you collect children's online contact information, and only this information, to enter them in the contest, and then only contact such children once when the contest ends to notify them if they have won or lost. At that point, you must delete the online contact information you have collected.

If, however, you expect to contact the children more than one time, you must use the "multiple-contact" exception, for which you must also collect a parent's online contact information and provide parents with direct notice of your information practices and an opportunity to opt out. In either case, the Rule prohibits you from using the children's online contact information for any other purpose, and requires you to ensure the security of the information, which is particularly important if the contest runs for any length of time.

If you wish to collect any information from children online beyond online contact information in connection with contest entries - such as collecting a winner's home address to mail a prize - you must first provide parents with direct notice and obtain verifiable parental consent, as you would for other types of personal information collection beyond online contact information. If you do need to obtain a mailing address and wish to stay within the one-time exception, you may ask the child to provide his parent's online contact information and use that identifier to notify the parent if the child wins the contest. In your prize notification message to the parent, you may ask the parent to provide a home mailing address to ship the prize, or invite the parent to call a telephone number to provide the mailing information.

2. I have a child-directed website that has an "Ask the Author" corner where children can email questions to featured authors. Do I need to provide notice and obtain parental consent?

If you simply answer the child's question and then delete the child's email address (and do not otherwise maintain or store the child's personal information in any form), then you fall into the Rule's "one-time contact" exception and do not need to obtain parental consent.

3. I offer e-cards and the ability for children to forward items of interest to their friends on my child-directed app. Can I take advantage of one of the Rule's exceptions to parental consent or must I notify parents and obtain consent for this activity?

The answer depends on how you design your e-card or forward-to-a-friend system. Any system providing any opportunity to reveal personal information other than the recipient's email address requires you to obtain verifiable consent from the sender's parent (not email plus), and does not fall within one of COPPA's limited exceptions. This means that if your e-card/forward-to-a-friend system permits personal information to be disclosed either in the "from" or "subject" lines, or in the body of the message, then you must notify the sender's parent and obtain verifiable parental consent before collecting any personal information from the child.

In order to take advantage of COPPA's "one-time contact exception" for your e-cards, you may only collect the recipient's email address (and, if desired, the sender or recipient's first name); you may not collect any other personal information either from the sender or the recipient, including persistent identifiers that track the user over time and across sites. Moreover, in order to meet this one-time contact exception, your e-card system must not allow the sender to enter her full name, her email address, or the recipient's full name. Nor may you allow the sender to freely type messages either in the subject line or in any text fields of the e-card.

Finally, you should send the e-card immediately and automatically delete the recipient's email address immediately after sending. If you choose to retain the recipient's email address until some point in the future (e.g., until the e-card is opened by the recipient, or you allow the sender to indicate a date in the future when the e-card should be sent), then this collection parallels the conditions for the Rule's "multiple contact exception" for obtaining verifiable parental consent. In this scenario, you must collect the sender's parent's email address and provide notice and an opportunity to opt out to the sender's parent before the e-card is sent. See 1999 Statement of Basis and Purpose, 64 Fed. Reg. 59888, 59902 n.222.

4. I would like to collect email address, but no other personally identifying information, during my website's registration process. I intend to use the email address only for the purpose of providing password reminders to users who register on my site. Do I first have to provide notice and obtain parental consent before collecting a child's email address?

If you plan to retain the child's email address in retrievable form after the initial collection, to be used, for example, to email children reminders of their passwords, then you must provide notice to parents and the opportunity to opt out under the Rule's multiple-contact exception. See 16 C.F.R. § 312.5(c)(4).

However, you may collect a child's email address to be used to authenticate the child for purposes of generating a password reminder without first providing parental notice and giving a parent the opportunity to opt out if you meet the following conditions: (1) you do not collect any personal information from the child other than the child's email address; (2) the child cannot disclose any personal information on your website; and (3) you immediately and permanently alter the email address (e.g., through "hashing") such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child. You should explain this process in a clear and conspicuous manner, both at the point of collection and in your site's online privacy policy, so that your users and their parents are informed about how the email addresses will be used. This will prevent confusion by visitors and others who may otherwise assume that your site is improperly collecting and retaining email addresses without any form of parental notice.

5. What does "support for the internal operations of the Web site or online service" mean?

"Support for the internal operations of the Web site or online service," as defined in 16 C.F.R. 312.2, means activities necessary for the site or service to maintain or analyze its functioning; perform network communications; authenticate users or personalize content; serve contextual advertising or cap the frequency of advertising; protect the security or integrity of the user, website, or online service; ensure legal or regulatory compliance; or fulfill a request of a child as permitted by § 312.5(c)(3) and (4). The Commission has separately noted that encompassed within the activities necessary for the site or service to maintain or analyze its functioning are intellectual property protection, payment and delivery functions, spam protection, optimization, statistical reporting, and debugging. See 2013 Statement of Basis and Purpose, 78 Fed Reg. 3972, 3981. Persistent identifiers collected for the sole purpose of providing support for the internal operations of the website or online service do not require parental notice or consent, so long as no other personal information is collected and the persistent identifiers are not used or disclosed to contact a specific individual, including through behavioral advertising; to amass a profile on a specific individual; or for any other purpose.

6. Can both a child-directed website and a third-party plug-in that collect persistent identifiers from users of that child-directed site rely on the Rule's exception for "support for internal operations"?

Yes. A child-directed site and a third-party plug-in collecting persistent identifiers from users of that child-directed site can both rely upon the Rule's "support for internal operations" exception where the only personal information collected from such users are persistent identifiers for purposes outlined in the "support for internal operations" definition. The persistent identifier information collected by the third-party plug-in may in some instances support only the plug-in's internal operations; in other instances, it may support both its own internal operations and the internal operations of the child-directed site.

7. Does the exception for "support for internal operations" allow me to perform, or retain another party to perform, site analytics?

Yes. Where you, a service provider, or a third party collects persistent identifier information from users of your child-directed site to perform analytics encompassed by the Rule's "support for internal operations" definition, and the information is not used for any other purposes not covered by the support for internal operations definition, then you can rely upon the Rule's exemption from parental consent.

8. I am an ad network that uses persistent identifiers to personalize advertisements on websites. I know that I operate on a child-directed site, but isn't personalization considered "support for internal operations"?

No. The term "support for internal operations" does not include behavioral advertising. The inclusion of personalization within the definition of support for internal operations was intended to permit operators to maintain user driven preferences, such as game scores, or character choices in virtual worlds. "Support for internal operations" does, however, include the collection or use of persistent identifiers in connection with serving contextual advertising on the child-directed site.

9. I have a child-directed app and want to send push notifications. Do I need to get parental consent?

The information you collect from the child's device used to send push notifications is online contact information - it permits you to contact the user - and is therefore personal information under the Rule. To the extent the child has specifically requested push notifications, however, you may be able to rely on the "multiple-contact" exception to verifiable parental consent, for which you must also collect a parent's online contact information and provide parents with direct notice of your information practices and an opportunity to opt-out. See FAQ I.2. Importantly, in order to fit within this exception, your push notifications must be reasonably related to the content of your app. If you want to combine this online contact information with other personal information collected from the child, you cannot rely on this exception and must provide parents with direct notice and obtain verifiable parental consent prior to sending push notifications to the child.

10. I have a child-directed website. Can I put a plug-in, such as a Facebook Like button, on my site without providing notice and obtaining verifiable parental consent?

In determining whether you must provide notice and obtain verifiable parental consent, you will need to evaluate whether any exceptions apply. Section 312.5(c)(8) of the Rule has an exception to its notice and consent requirements where:

1. a third-party operator only collects a persistent identifier and no other personal information;

2. the user affirmatively interacts with that third-party operator to trigger the collection;and

3. the third-party operator has previously conducted an age-screen of the user, indicating the user is not a child.

If the third-party operator meets all of those requirements, and if your site doesn't collect personal information (except for that covered by an exception), you don't need to provide notice or obtain consent.

This exception doesn't apply to types of plug-ins where the third party collects more information than a persistent identifier - for example, where the third party also collects user comments or other user-generated content. In addition, a child-directed website can't rely on this exception to treat particular visitors as adults and track their activities.

If your inclusion of the plug-in satisfies all the criteria of section 312.5(c)(8) outlined above and/or satisfies another exception to the notice and consent requirements in the Rule (see, for example, the "support for internal operations" exception discussed in FAQ J.5 and J.6 above), you do not have to provide notice and obtain verifiable parental consent.

K. PARENTAL ACCESS TO CHILDREN'S PERSONAL INFORMATION

1. Do I have to keep all information I have ever collected online from a child in case a parent may want to see it in the future?

No. In fact, the Rule specifically states that operators should retain personal information collected online from a child for only as long as is reasonably necessary to fulfill the purpose for which the information was collected. As the Commission noted in the 1999 Statement of Basis and Purpose, "if a parent seeks to review his child's personal information after the operator has deleted it, the operator may simply reply that it no longer has any information concerning that child." See 64 Fed. Reg. 59888, 59904.

2. What if, despite my most careful efforts, I mistakenly give out a child's personal information to someone who is not that child's parent or guardian?

The Rule requires you to provide parents with a means of reviewing any personal information you collect online from children. Although the Rule provides that the operator must ensure that the requestor is a parent of the child, it also notes that if you follow reasonable procedures in responding to a request for disclosure of this personal information, you will not be liable under any federal or state law if you mistakenly release a child's personal information to a person other than the parent. See 16 C.F.R. § 312.6(a)(3)(i) and (b).

L. DISCLOSURE OF INFORMATION TO THIRD PARTIES

1. If I want to share children's personal information with a service provider or a third party, how should I evaluate whether the security measures that entity has in place are "reasonable" under the Rule?

Before sharing information with such entities, you should determine what the service providers' or third parties' data practices are for maintaining the confidentiality and security of the data and preventing unauthorized access to or use of the information. Your expectations for the treatment of the data should be expressly addressed in any contracts that you have with service providers or third parties. In addition, you must use reasonable means, such as periodic monitoring, to confirm that any service providers or third parties with which you share children's personal information maintain the confidentiality and security of that information.

M. REQUIREMENT TO LIMIT INFORMATION COLLECTION

1. If I operate a social networking service and a parent revokes her consent to my maintaining personal information collected from the child, can I deny that child access to my service?

Yes. If a parent revokes consent and directs you to delete the personal information you had collected from the child, you may terminate the child's use of your service. See 16 C.F.R. § 312.6(c).

2. I know that the Rule says I cannot condition a child's participation in a game or prize offering on the child disclosing more information than is reasonably necessary to participate in those activities. Does this limitation apply to other online activities?

Yes. The applicable Rule provision is not limited to games or prize offerings, but includes "another activity." See 16 C.F.R. § 312.7. This means that you must carefully examine the information you intend to collect in connection with every activity you offer in order to ensure that you are only collecting information that is reasonably necessary to participate in that activity. This guidance is in keeping with the Commission's general guidance on data minimization. There are some sites or services, however, where the sharing of personal information is a central feature, such as social networking sites or chat rooms. This provision does not prohibit these types of sites from allowing children to share personal information. See FAQ I.9.

N. COPPA AND SCHOOLS

1. Can an educational institution consent to a website or app's collection, use or disclosure of personal information from students?

Yes. Many school districts contract with third-party website operators to offer online programs solely for the benefit of their students and for the school system - for example, homework help lines, individualized education modules, online research and organizational tools, or web-based testing services. In these cases, the schools may act as the parent's agent and can consent under COPPA to the collection of kids' information on the parent's behalf. However, the school's ability to consent for the parent is limited to the educational context - where an operator collects personal information from students for the use and benefit of the school, and for no other commercial purpose. Whether the website or app can rely on the school to provide consent is addressed in FAQ N.2. FAQ N.5 provides examples of other "commercial purposes." Importantly, operators should not state in Terms of Service or anywhere else that the school is responsible for complying with COPPA, as it is the responsibility of the operator to comply with the Rule.

In order for the operator to rely on consent obtained from the school under COPPA instead of the parent, the operator must provide the school with the same type of direct notice regarding its practices as to the collection, use, or disclosure of personal information from children as it would otherwise provide to the parent. In addition, the operator, upon request from the school, must provide the school a description of the types of personal information collected; an opportunity to review the child's personal information and the right to have the information deleted; and the opportunity to prevent further use or online collection of a child's personal information. As long as the operator limits use of the child's information to the educational context authorized by the school, the operator can presume that the school's authorization is based on the school's having obtained the parent's consent. However, as a best practice, schools should consider making such notices available to parents, and consider the feasibility of allowing parents to review the personal information collected. See FAQ N.4. Schools also should ensure operators delete children's personal information once the information is no longer needed for its educational purpose.

In addition, schools and operators should consider their obligations under the Family Educational Rights and Privacy Act (FERPA), which gives parents certain rights with respect to their children's education records. FERPA provides parents with rights to access their student's education records, protect against unauthorized disclosures of the personally identifiable information from those records, and other related rights. FERPA is administered by the U.S. Department of Education (ED) and applies to educational agencies and institutions that are funded by a program administered by ED. The school's agreement with a third party operator must also be reviewed under the school official exception or other applicable exception under FERPA. For general information on FERPA, see https://studentprivacy.ed.gov/. Schools and operators also must comply with the Individuals with Disabilities Education Act and Protection of Pupil Rights Amendment (PPRA), which are also administered by ED. See https://studentprivacy.ed.gov/ and https://sites.ed.gov/idea/; see also FAQ N.5 for more information on the PPRA.)

Student data may be protected under state law, too. For example, California's Student Online Personal Information Protection Act, among other things, places restrictions on the use of K-12 students' information for targeted advertising, profiling, or onward disclosure. States such as Oklahoma, Idaho, and Arizona require educators to include express provisions in contracts with private vendors to safeguard privacy and security or to prohibit secondary uses of student data without parental consent.

2. Under what circumstances can an operator of a website or online service rely upon an educational institution to provide consent?

Where a school has contracted with an operator to collect personal information from students for the use and benefit of the school, and for no other commercial purpose, the operator is not required to obtain consent directly from parents under COPPA, and can presume that the school's authorization for the collection of students' personal information is based upon the school having obtained the parents' consent. However, the operator must provide the school with full notice of its collection, use, and disclosure practices in the same way that it is otherwise required to do for a parent.

If, however, an operator intends to use or disclose children's personal information for its own commercial purposes in addition to the provision of services to the school, it will need to obtain parental consent. Operators may not use the personal information collected from children based on a school's consent for another commercial purpose because the scope of the school's authority to act on behalf of the parent is limited to the school context.

Where an operator gets consent from the school rather than the parent, the operator's method must be reasonably calculated, in light of available technology, to ensure that a school is actually providing consent, and not a child pretending to be a teacher, for example.

3. Who should provide consent - an individual teacher, the school administration, or the school district?

As a best practice, we recommend that schools or school districts decide whether a particular site's or service's information practices are appropriate, rather than delegating that decision to the teacher. Many schools have a process for assessing sites' and services' practices so that this task does not fall on individual teachers' shoulders. School districts and schools have separate specific obligations under FERPA. See https://studentprivacy.ed.gov for more information.

4. When the school gives consent, what are the school's obligations regarding notifying the parent?

As a best practice, the school should consider providing parents with a notice of the websites and online services whose collection it has consented to on behalf of the parent under COPPA. Schools can identify, for example, sites and services that have been approved for use district-wide or for the particular school.

In addition, the school may want to make the operators' direct notices regarding their information practices available to interested parents. Many school systems have implemented Acceptable Use Policies for Internet use (AUPs) to educate parents and students about in-school Internet use. The school could maintain this information on a website or provide a link to the information at the beginning of the school year. There are separate parent notification requirements under FERPA. See https://studentprivacy.ed.gov for more information.

5. What information should a school seek from an operator before entering into an arrangement that permits the collection, use, or disclosure of personal information from students?

In deciding whether to use online technologies with students, a school should be careful to understand how an operator will collect, use, and disclose personal information from its students. Among the questions that a school should ask potential operators are:

What types of personal information will the operator collect from students?

How does the operator use this personal information?

Does the operator use or share the information for commercial purposes not related to the provision of the online services requested by the school? For instance, does it use the students' personal information in connection with online behavioral advertising, or building user profiles for commercial purposes not related to the provision of the online service? If so, the school cannot consent on behalf of the parent.

Does the operator enable the school to review and have deleted the personal information collected from their students? If not, the school cannot consent on behalf of the parent.

What measures does the operator take to protect the security, confidentiality, and integrity of the personal information that it collects?

What are the operator's data retention and deletion policies for children's personal information?

Schools also should keep in mind that under the Protection of Pupil Rights Amendment, Local Educational Agencies (LEAs) must adopt policies and must provide direct notification to parents at least annually regarding the specific or approximate dates of, and the rights of parents to opt their children out of participation in, activities involving the collection, disclosure, or use of personal information collected from students for the purpose of marketing or selling that information (or otherwise providing the information to others for that purpose).

O. COPPA SAFE HARBOR PROGRAMS

1. How can I qualify as a Commission-approved COPPA safe harbor program?

To be considered for COPPA safe harbor status, an industry group or other person must submit its self-regulatory guidelines to the FTC for approval. The Rule requires the Commission to publish the safe harbor application in the Federal Register seeking public comment. The Commission then is required to make a written determination on the application within 180 days after its filing.

COPPA safe harbor applications must contain:

A detailed explanation of the applicant's business model and technological capabilities and mechanisms it will use to assess member operator's information collection practices;

A copy of the full text of the safe harbor program's guidelines and any accompanying commentary;

A comparison of each program guideline with each corresponding Rule provision and a statement of how each guideline meets the Rule's requirements; and

A statement of how the assessment mechanisms and disciplinary consequences provide effective COPPA enforcement.

The Rule sets forth the key criteria the FTC will consider in reviewing a safe harbor application:

Whether the applicant's program includes guidelines that provide substantially the same or greater protection than the standards set forth in the COPPA Rule;

Whether the program includes an effective, mandatory mechanism to independently assess member operators' compliance with the program's guidelines, which at a minimum must include a comprehensive annual review by the safe harbor program of each member operator;

Whether the program includes effective disciplinary actions for member operators who do not comply with the safe harbor program guidelines.

See 16 C.F.R. § 312.11.

2. What should I do if I am interested in submitting my self-regulatory program to the FTC for approval under the safe harbor provision?

Information about applying for FTC approval of a safe harbor program is provided in Section 312.11 of the Rule and online at the COPPA Safe Harbor Program portion of the FTC's Business Center website. In addition, you may send an email to CoppaHotLine@ftc.gov, and a member of the FTC staff will help answer your questions.

3. How can I learn about safe harbor programs that have been approved by the Commission?

Information about the applicants who have sought safe harbor status can be found online at the COPPA Safe Harbor Program portion of the FTC's Business Center website. The site includes each organization's applications and guidelines, along with comments submitted by the public, and the basis for the Commission's written determination of each application.

YOUR OPPORTUNITY TO COMMENT

The National Small Business Ombudsman and 10 Regional Fairness Boards collect comments from small businesses about federal compliance and enforcement activities. Each year, the Ombudsman evaluates the conduct of these activities and rates each agency's responsiveness to small businesses. Small businesses can comment to the Ombudsman without fear of reprisal. To comment, call toll-free 1-888-REGFAIR (1-888-734-3247) or go to www.sba.gov/ombudsman.

[Note: Edited January 2024 to reflect Inflation-Adjusted Civil Penalty Maximums.]

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Complying with COPPA: Frequently Asked Questions

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A GUIDE FOR BUSINESS AND PARENTS AND SMALL ENTITY COMPLIANCE GUIDE The following FAQs are intended to supplement the compliance materials available on the FTC website. In addition, you may send questions or comments to the FTC staff's COPPA mailbox, CoppaHotLine@ftc.gov.

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Applies to the release of student data and records.

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"Law enforcement unit records" (i.e., records created by a law enforcement unit at the educational agency or institution, created for a law enforcement purpose, and maintained by the law enforcement unit) are not "education records" subject to the privacy protections of FERPA. As such, the law enforcement unit may refuse to provide a parent or eligible student with an opportunity to inspect and review law enforcement unit records, and it may disclose law enforcement unit records to third parties without the parent's or eligible student's prior written consent.

Resources:
FERPA General Guidance for Parents

Yes. Under the studies exception, the school or LEA may non-consensually disclose PII from education records to the community-based organization only if

1. The study is conducted in a manner that does not permit personal identification of parents and students by individuals other than representatives of the organization that have legitimate interests in the information;

2. The information is destroyed when no longer needed for the purposes for which the study was conducted; and

3. The school or LEA enters into a written agreement with the community-based organization.

Yes. Under FERPA, a school may share PII from education records with school officials within the school whom the school has determined to have legitimate educational interests in the behavior of a student who has been disciplined for conduct that posed a significant risk to the safety or well-being of that student, other students, or other members of the school community. See § 99.36(b)(2) and Q&A 9 and § 99.36(b)(1) and (2).

The school may also disclose PII from education records about a student who has been disciplined for conduct that posed a significant risk to the safety or well-being of that student, other students, or other members of the school community, to school officials at another school who have been determined to have legitimate educational interests in the behavior of the student, if deemed necessary.

For instance, if a school official knows that a student, who has been disciplined for bringing a gun or knife to school or threatened to hurt students and/or teachers, is planning to attend a school-sponsored activity at another high school, FERPA would allow that school official to notify school officials at the other high school who have been determined to have legitimate educational interests in the behavior of the student. See § 99.36(b)(3).

The U.S. Department of Education (ED) is working with Census to share updates on the 2020 Census.

Census has posted an updated document here.

Given that many students who usually reside on college campuses may not currently be on campus, Census has 3 updates/reminders:

Colleges that chose the paper (drop off/pick up) method are urged to move to e-response;
In most cases, students who would ordinarily be on campus full-time but are living away from home at school should be counted at school, even if they are temporarily elsewhere (such as home) due to the COVID-19 pandemic; and
Off-campus students can complete a response through the Internet at my2020census.gov.
The Student Privacy Policy Office or SPPO has provided information on the implications of FERPA under each of the enumeration methods here.

Please contact SPPO at FERPA@ed.gov if you have questions.

The Department recently issued techncial assistance on the applicability of the Family Educational Rights and Privacy Act (FERPA) to the disclosure by IHEs or postsecondary institutions of certain personally identifiable information (PII) from student education records to representatives of the U.S. Census Bureau (Bureau) in connection with the 2020 Census.
Department of Education Resources Census Resources

No. An SRO typically serves as an on-site law enforcement officer and as a liaison with the local police or sheriff's department. An SRO also works with teachers and school administrators to promote school safety and to help ensure physical security. An SRO may be designated by the school as a "law enforcement unit" official under FERPA (§ 99.8). However, in order for a school to disclose personally identifiable information (PII) from education records to an SRO, the SRO must be considered a "school official" under FERPA in accordance with § 99.31(a)(1)(i)(B) concerning outsourcing. A school may only non-consensually disclose PII from students' education records to its law enforcement unit if those individuals in the law enforcement unit meet the requirements set forth in FERPA's school official exception or if some other FERPA exception to the general consent rule applies.

A school must have direct control over an SRO's maintenance and use of education records in providing SRO services in order for the SRO to be considered a school official. Further, under the school official exception (as well as any FERPA exception to consent), SROs may only use the PII from education records for the purposes for which the disclosure was made, e.g., to promote school safety and the physical security of the students. See §§ 99.31(a)(1)(i)(B)(3) and 99.33(a)(2). In addition, SROs are subject to the redisclosure requirements of § 99.33(a). This means that an SRO who is serving as a "school official" under FERPA may not disclose PII from education records to others, including other employees of his or her local police department who are not acting as school officials, without consent unless the redisclosure fits within one of the exceptions to FERPA's consent requirement.

There are exceptions to consent in FERPA that permit, but do not require, local educational agencies (LEAs) and schools to disclose personally identifiable information (PII) from education records under certain conditions without the written consent of the parent or eligible student. FERPA permits LEAs and schools to disclose education records of students placed in foster care, without consent of the parent or eligible student, to an agency caseworker or other representative of a state or local child welfare agency (CWA) or tribal organization authorized to access a student's case plan, when such agency or organization is legally responsible, in accordance with state or tribal law, for the care and protection of the student.

A "case plan" is defined at 42 U.S.C. 675(1) as a written document that must include a number of specified items that, among other things, must address both the proper care of children in foster care placement. The plan also addresses the services that are provided to children in foster care placement, their parents, and their foster parents. The plan also includes, but is not limited to, ensuring the educational stability of children in foster care.

This exception to FERPA only applies to those children for whom the CWA or tribal organization is legally responsible, in accordance with state or tribal law, for the care and protection of a child in foster care placement. FERPA would not permit LEAs and schools and to disclose PII from education records to the CWA or tribal organization for children who are not in foster care placement, even if those children are receiving other services through the CWA or tribal organization (e.g., vocational and skill assessments, training, tutoring, educational services, family services, and community enrichment activities).

Yes. Under FERPA, a school or school district may disclose personally identifiable information (PII) from education records without consent to threat assessment team members who are not employees of the school or school district if they qualify as "school officials" with "legitimate educational interests."

In establishing a threat assessment team, the school must follow the FERPA provisions in § 99.31(a)(1)(i)(B) concerning outsourcing this function if team members will be privy to PII from students' education records. While not a requirement of FERPA, one way to ensure that members of the team do not redisclose PII obtained from education records would be to have a written agreement with each of the team members specifying their requirements and responsibilities.

Schools are reminded that members of the threat assessment team may only use PII from education records for the purposes for which the disclosure was made, i.e., to conduct threat assessments, and must be subject to FERPA's redisclosure requirements in § 99.33(a). For example, a representative from the city police who serves on a school's threat assessment team generally could not give the police department any PII from a student's education records to which he or she was privy as a member of the team. However, if the threat assessment team determines that a health or safety emergency exists, then the police officer may disclose, on behalf of the school, PII from a student's education records to appropriate officials under the health or safety emergency exception under §§ 99.31(a)(10) and 99.36, as discussed below.

1. When is a photo or video of a student an education record under FERPA?

As with any other "education record," a photo or video of a student is an education record, subject to specific exclusions, when the photo or video is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution. (20 U.S.C. 1232g(a)(4)(A); 34 CFR § 99.3 "Education Record")[1]
Directly Related to a Student:
FERPA regulations do not define what it means for a record to be "directly related" to a student. In the context of photos and videos, determining if a visual representation of a student is directly related to a student (rather than just incidentally related to him or her) is often context-specific, and educational agencies and institutions should examine certain types of photos and videos on a case by case basis to determine if they directly relate to any of the students depicted therein. Among the factors that may help determine if a photo or video should be considered "directly related" to a student are the following:

The educational agency or institution uses the photo or video for disciplinary action (or other official purposes) involving the student (including the victim of any such disciplinary incident);

The photo or video contains a depiction of an activity:

that resulted in an educational agency or institution's use of the photo or video for disciplinary action (or other official purposes) involving a student (or, if disciplinary action is pending or has not yet been taken, that would reasonably result in use of the photo or video for disciplinary action involving a student);

that shows a student in violation of local, state, or federal law;

that shows a student getting injured, attacked, victimized, ill, or having a health emergency;

The person or entity taking the photo or video intends to make a specific student the focus of the photo or video (e.g., ID photos, or a recording of a student presentation); or

The audio or visual content of the photo or video otherwise contains personally identifiable information contained in a student's education record.

A photo or video should not be considered directly related to a student in the absence of these factors and if the student's image is incidental or captured only as part of the background, or if a student is shown participating in school activities that are open to the public and without a specific focus on any individual.

Examples of situations that may cause a video to be an education record:

A school surveillance video showing two students fighting in a hallway, used as part of a disciplinary action, is directly related to the students fighting.

A classroom video that shows a student having a seizure is directly related to that student because the depicted health emergency becomes the focus of the video.

If a school maintains a close-up photo of two or three students playing basketball with a general view of student spectators in the background, the photo is directly related to the basketball players because they are the focus of the photo, but it is not directly related to the students pictured in the background. Schools often designate photos or videos of students participating in public events (e.g., sporting events, concerts, theater performances, etc.) as directory information and/or obtain consent from the parents or eligible students to publicly disclose photos or videos from these events.

A video recording of a faculty meeting during which a specific student's grades are being discussed is directly related to that student because the discussion contains PII from the student's education record.

Maintained by an educational agency or institution:
To be considered an education record under FERPA, an educational agency or institution, or a party acting for the agency or institution, also must maintain the record. Thus, a photo taken by a parent at a school football game would not be considered an education record, even if it is directly related to a particular student, because it is not being maintained by the school or on the school's behalf. If, however, the parent's photo shows two students fighting at the game, and the parent provides a copy of the photo to the school, which then maintains the photo in the students' disciplinary records, then the copy of the photo being maintained by the school is an education record.
Exclusion for Law Enforcement Unit Records
The FERPA statute and regulations (20 U.S.C. 1232g(a)(4)(B)(ii) and 34 CFR §§ 99.3 and 99.8) exclude from the definition of education records those records created and maintained by a law enforcement unit of an educational agency or institution for a law enforcement purpose. Thus, if a law enforcement unit of an educational agency or institution creates and maintains the school's surveillance videos for a law enforcement purpose, then any such videos would not be considered to be education records. If the law enforcement unit provides a copy of the video to another component within the educational agency or institution (for example, to maintain the record in connection with a disciplinary action), then the copy of the video may become an education record of the student(s) involved if the video is not subject to any other exclusion from the definition of "education records" and the video is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution.

2. Can the same recorded image be the education record of more than one student under FERPA?

Yes. For example, a surveillance video that shows two students fighting on a school bus that the school uses and maintains to discipline the two students, would be "directly related to" and, therefore, the education record of both students.

3. If a video is an education record for multiple students, can a parent of one of the students or the eligible student view the video?

When a video is an education record of multiple students, in general, FERPA requires the educational agency or institution to allow, upon request, an individual parent of a student (or the student if the student is an eligible student) to whom the video directly relates to inspect and review, or "be informed of" the content of the video, consistent with the FERPA statutory provisions in 20 U.S.C. § 1232g(a)(1)(A) and regulatory provisions at 34 CFR § 99.12(a). FERPA generally does not require the educational agency or institution to release copies of the video to the parent or eligible student.

In providing access to the video, the educational agency or institution must provide the parent of the student (or the student if the student is an eligible student) with the opportunity to inspect and review or "be informed of" the content of the video. If the educational agency or institution can reasonably redact or segregate out the portions of the video directly related to other students, without destroying the meaning of the record, then the educational agency or institution would be required to do so prior to providing the parent or eligible student with access. On the other hand, if redaction or segregation of the video cannot reasonably be accomplished, or if doing so would destroy the meaning of the record, then the parents of each student to whom the video directly relates (or the students themselves if they are eligible students) would have a right under FERPA to inspect and review or "be informed of" the entire record even though it also directly relates to other students.

For a fuller legal analysis and explanation of this issue, please see the 2017 Letter to Wachter.

4. If a video is an education record for multiple students, can the parent of one of the students (or the eligible student) receive a copy of the video?

While we do not advise on an educational agency's or institution's obligations under any state open records laws that may apply, we note that FERPA does not generally require an educational agency or institution to provide copies of education records to parents and eligible students[2]. That said, it would not violate FERPA for an educational agency or institution to non-consensually disclose to an eligible student or to his or her parents copies of education records that the eligible student or his or her parents otherwise would have the right to inspect and review under FERPA.

For a fuller legal analysis and explanation of this issue, please see the 2017 Letter to Wachter.

5. If redaction or segregation of an education record of multiple students can be reasonably accomplished without destroying the meaning of the education record, can educational agencies and institutions charge parents or eligible students for the costs of the redaction or segregation?

No. FERPA provides parents and eligible students with the right to inspect and review the student's education records, and nothing in the FERPA statute or regulations permits educational agencies and institutions to charge parents or eligible students for fees or costs associated with exercising that right.

If a school elects to provide a parent or eligible student with a copy of the education records, then the FERPA regulations (34 CFR § 99.11(a)) generally permit (with the exception noted below) the school to charge for the costs required to make the copy. FERPA regulations (34 CFR § 99.11(b)) also provide that the school may not charge a parent or eligible student for the costs to search for or retrieve the education records. We view the costs, if any, to the school of redacting, or segregating, education records of multiple students as being like the costs of search and retrieval that may not be charged to parents or eligible students, rather than like the costs for copies that generally may be charged to parents and eligible students. As noted above, if an educational agency or institution can reasonably redact or segregate out portions of an education record that is directly related to other students, without destroying the meaning of the record, then the educational agency or institution must do so and therefore cannot charge parents or eligible students for the costs associated with exercising their right to inspect and review such education records.

In contrast, parents and eligible students generally may be charged for the costs of making copies of education records precisely because FERPA generally does not require the school to provide them with such copies. Thus, where the redaction or segregation of education records of multiple students can be reasonably accomplished without destroying the meaning of the education records, nothing in FERPA permits educational agencies or institutions to charge parents or eligible students for the costs of making the required redactions or segregation. Please note that the FERPA regulations (34 CFR § 99.11(a)) similarly provide that if a fee for copies effectively prevents a parent or an eligible student from exercising the right to inspect and review his or her education records, an educational agency or institution would be required to provide copies without payment. Such cases would be limited to a parent or an eligible student providing evidence of the inability to pay for the copies due to financial hardship.

6. Does FERPA permit legal representatives of parents or eligible students to inspect and review videos with the parent or eligible student?

Yes. FERPA permits legal representatives of a parent or an eligible student to inspect and review videos with the parent or eligible student. While FERPA does not require educational agencies and institutions to allow parents or eligible students to bring their attorney or other legal representative with them when they exercise their right to inspect and review the student's education records, nothing in FERPA prevents educational agencies and institutions from allowing parents or eligible students to bring their attorney or other legal representative with them when they exercise their right to inspect and review the student's education records under FERPA.

7. Does FERPA permit educational agencies and institutions turn over videos to the police upon request or following an incident that may warrant police involvement?

If the law enforcement unit of an educational agency or institution creates and maintains videos for a law enforcement purpose, then the videos would not be education records and FERPA would not prohibit the law enforcement unit of an educational agency or institution from disclosing the videos to the police. If the videos are education records, however, educational agencies and institutions may not turn over videos to the police upon request without having first either obtained the written consent of the parent or eligible student or determined that the conditions of an exception to the general requirement of consent have been met, such as if the disclosure is made in connection with a health or safety emergency (20 U.S.C. 1232g(b)(1)(I) and 34 CFR §§ 99.31(a)(10) and 99.36) or the law enforcement officer has presented the educational agency or institution with a judicial order or a lawfully issued subpoena (20 U.S.C. 1232g(b)(1)(J) and (b)(2) and 34 CFR § 99.31(a)(9)).

In addition to the potential for loss of funds under ESEA for failure to comply with § 9528 of the ESEA, an LEA that denies a military recruiter access to the requested information on students after July 1, 2002, will be subject to specific interventions under 10 U.S.C. § 503.

In this regard, the law requires that a senior military officer (e.g., Colonel or Navy Captain) visit the LEA within 120 days. If the access problem is not resolved with the LEA, the Department of Defense must notify the state's Governor within 60 days. Problems still unresolved after one year are reported to Congress, if the Secretary of Defense determines that the LEA denies recruiting access to at least two of the armed forces (Army, Navy, Marine Corps, etc.). The expectation is that public officials will work with the LEA to resolve the problem.

Additionally, the Department of Defense has developed a national high school data base to document recruiter access. Presently, 95 percent of the nation's 22,000 secondary schools provide a degree of access to military recruiters that is consistent with current law.

A parent or eligible student may file a written complaint with the Family Policy Compliance Office regarding an alleged violation under of FERPA. The complaint must be timely (submitted to the office within 180 days of the date that the complainant knew or reasonably knew of the violation) and state clearly and succinctly specific allegations of fact giving reasonable cause to believe that the school has violated FERPA.

A teacher should first check with their school/district administration to see if that application or service is approved for use in the classroom. Any applications or services that collect personally identifiable information (PII) from students' education records under the school officials exception to prior consent in FERPA must:

Provides a service or function that the school would otherwise use its own staff

Be under the direct control of the school with regard to the use and maintenance of the PII from education records

Collection and use of the PII must be consistent with the school or district's annual notification of rights under FERPA

Not re-disclose or use the education data for unauthorized purposes.

Remember that the use of some applications or services may introduce security or privacy vulnerabilities into the school or districts IT systems. Teachers should always consult their IT representatives to discuss the use of these types of software tools prior to use to ensure compliance with FERPA requirements and promote a safe, secure computing environment.

If a student is attending a postsecondary institution - at any age - the rights under FERPA have transferred to the student. However, in a situation where a student is enrolled in both a high school and a postsecondary institution, the two schools may exchange information on that student. If the student is under 18, the parents still retain the rights under FERPA at the high school and may inspect and review any records sent by the postsecondary institution to the high school. Additionally, the postsecondary institution may disclose personally identifiable information from the student's education records to the parents, without the consent of the eligible student, if the student is a dependent for tax purposes under the IRS rules. Dual Enrollment Dually Enrolled

When a video is an education record of multiple students, in general, FERPA requires the educational agency or institution to allow, upon request, an individual parent of a student (or the student if the student is an eligible student) to whom the video directly relates to inspect and review the video. FERPA generally does not require the educational agency or institution to release copies of the video to the parent or eligible student.

In providing access to the video, the educational agency or institution must provide the parent of the student (or the student if the student is an eligible student) with the opportunity to inspect and review the video. If the educational agency or institution can reasonably redact or segregate out the portions of the video directly related to other students, without destroying the meaning of the record, then the educational agency or institution would be required to do so prior to providing the parent or eligible student with access. On the other hand, if redaction or segregation of the video cannot reasonably be accomplished, or if doing so would destroy the meaning of the record, then the parents of each student to whom the video directly relates (or the students themselves if they are eligible students) would have a right under FERPA to access the entire record even though it also directly relates to other students.

For a fuller legal analysis and explanation of this issue, please see the 2017 Letter to Wachter.

While we do not advise on an educational agency's or institution's obligations under any state open records laws that may apply, we note that FERPA does not generally require an educational agency or institution to provide copies of education records to parents and eligible students[1]. That said, it would not violate FERPA for an educational agency or institution to non-consensually disclose to an eligible student or to his or her parents copies of education records that the eligible student or his or her parents otherwise would have the right to inspect and review under FERPA.

For a fuller legal analysis and explanation of this issue, please see the 2017 Letter to Wachter.

can educational agencies and institutions charge parents or eligible students for the costs of the redaction or segregation?
No. FERPA provides parents and eligible students with the right to inspect and review the student's education records, and nothing in the FERPA statute or regulations permits educational agencies and institutions to charge parents or eligible students for fees or costs associated with exercising that right.

If a school elects to provide a parent or eligible student with a copy of the education records, then the FERPA regulations (34 CFR § 99.11(a)) generally permit (with the exception noted below) the school to charge for the costs required to make the copy. FERPA regulations (34 CFR § 99.11(b)) also provide that the school may not charge a parent or eligible student for the costs to search for or retrieve the education records. We view the costs, if any, to the school of redacting, or segregating, education records of multiple students as being like the costs of search and retrieval that may not be charged to parents or eligible students, rather than like the costs for copies that generally may be charged to parents and eligible students. As noted above, if an educational agency or institution can reasonably redact or segregate out portions of an education record that is directly related to other students, without destroying the meaning of the record, then the educational agency or institution must do so and therefore cannot charge parents or eligible students for the costs associated with exercising their right to inspect and review such education records.

In contrast, parents and eligible students generally may be charged for the costs of making copies of education records precisely because FERPA generally does not require the school to provide them with such copies. Thus, where the redaction or segregation of education records of multiple students can be reasonably accomplished without destroying the meaning of the education records, nothing in FERPA permits educational agencies or institutions to charge parents or eligible students for the costs of making the required redactions or segregation. Please note that the FERPA regulations (34 CFR § 99.11(a)) similarly provide that if a fee for copies effectively prevents a parent or an eligible student from exercising the right to inspect and review his or her education records, an educational agency or institution would be required to provide copies without payment. Such cases would be limited to a parent or an eligible student providing evidence of the inability to pay for the copies due to financial hardship.

Generally, yes. FERPA allows schools that have adopted directory information policies to disclose properly designated directory information without consent on students whose parents (or eligible students) have not opted out of the disclosure of directory information. See § 99.37(a). However, if a school adopts a directory information policy specifying that disclosure of directory information will be limited to specific parties, for specific purposes, or both, then the school is required to limit its directory information disclosures to those specified in its public notice. See § 99.37(d).

Education records that have been appropriately designated as "directory information" by the educational agency or institution may be disclosed without prior consent. See 34 CFR §§ 99.31(a)(11) and 99.37. FERPA defines directory information as information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. 34 CFR § 99.3.

FERPA provides that a school may disclose directory information if it has given public notice of the types of information which it has designated as "directory information," the parent or eligible student's right to restrict the disclosure of such information, and the period of time within which a parent or eligible student has to notify the school in writing that he or she does not want any or all of those types of information designated as "directory information." 34 CFR § 99.37(a). A school is not required to inform former students or the parents of former students regarding directory information or to honor their request that directory information not be disclosed without consent. 34 CFR § 99.37(b). However, if a parent or eligible student, within the specified time period during the student's last opportunity as a student in attendance, requested that directory information not be disclosed, the school must honor that request until otherwise notified.

Yes. Before the LEA discloses personally identifiable information (PII) from education records to a community-based organization designated as an authorized representative, the LEA is required to use "reasonable methods" to ensure to the greatest extent practicable that the community-based organization is FERPA-compliant. This specifically means ensuring that the community-based organization:

1. Uses PII from education records only to carry out an audit or evaluation of federal- or state-supported education programs, or for the enforcement of or compliance with, federal legal requirements related to these programs. The LEA should make sure that the proposed audit or evaluation is legitimate, and require in the written agreement that the community-based organization use the PII from education records only for that audit, evaluation, or enforcement or compliance activity.

2. Protects the PII from education records from further disclosures or other uses, except as authorized by the LEA in accordance with FERPA. The agreement must specify that the community-based organization may not further disclose the PII from education records, unless authorized.

3. Destroys the PII from education records when no longer needed for the audit, evaluation, or enforcement or compliance activity. The agreement must specify that the community-based organization is required to destroy the PII from education records when it is no longer needed and specify the time period in which the PII must be destroyed. See 34 CFR § 99.35(a)(2).

While FERPA does not require that you notify us, we recommend that you contact SPPO if a community-based organization violates FERPA and provide us with information concerning the violation and any actions that you have taken. SPPO has the authority to impose what is informally known as "the five-year rule ban" against the community-based organization if SPPO determines that it has violated certain provisions under FERPA. The five-year rule means that SPPO can instruct the originating LEA or school to not provide the community-based organization with further access to PII from students' education records for a minimum period of five years. SPPO may impose a longer period of time in which the community-based organization may not have access to PII. The five-year rule ban applies regardless of whether the community-based organization is a recipient of Department funds. For more information on penalties for FERPA violations, see 34 CFR § 99.67.

Under FERPA, "law enforcement unit" means any individual, office, department, division, or other component of a school, such as a unit of commissioned police officers or noncommissioned security guards, that is officially authorized or designated by that school or school district to (1) enforce any local, state, or federal law, or refer to appropriate authorities a matter for enforcement of any local, state, or federal law against any individual or organization other than the agency or institution itself; or (2) maintain the physical security and safety of the agency or institution. See 34 CFR § 99.8(a)(1).

Schools vary in who they authorize or designate to be their law enforcement unit, usually depending upon their size and resources. Some larger school districts have their own fully equipped police units, while others have smaller security offices. Other schools designate a vice principal or other school official to act as the law enforcement unit officer. And other schools may utilize local police officers and SROs as their law enforcement officials.

The Protection of Pupil Rights Amendment (PPRA) requires that local education agencies (LEAs), in consultation with parents, develop the following local policies concerning student privacy, parents access to information, and administration of certain physical examinations to minors:

The right of a parent of a student to inspect, upon the request of the parent, a survey created by a third party before the survey is administered or distributed by a school to a student, and any applicable procedures for granting a request by a parent for reasonable access to the survey within a reasonable period of time after the requires is received;

Arrangements to protect student privacy that are provided by the LEA in the event of the administration or distribution of a survey to a student containing one or more of the eight protected areas of information;

The right of a parent or student to inspect, upon the request of the parent, any instructional material used as part of the educational curriculum for the student, and any applicable procedures for granting a request by a parent for reasonable access to instructional material within a reasonable period of time after the request is received;

The administration of physical examinations or screenings that the school or LEA may administer to a student;

The collection, disclosure, or use of personal information collected from students for the purpose of marketing or for selling that information, or otherwise providing that information to others for that purpose, including arrangements to protect student privacy that are provided by the LEA in the event of such collection, disclosure, or use;

The right of a parent of a student to inspect, upon request, any instrument used in the collection of personal information (a student or parent's first and last name, a home or other physical address, a telephone number, or a Social Security identification number) before the instrument is administered or distributed to a student, and any applicable procedures for granting a request by a parent for reasonable access to such instrument within a reasonable period of time after the request is received.

A model PPRA general notification for use by LEAs may also be obtained on SPPO's website at: Model Notification of Rights Under PPRA

Records which are kept in the sole possession of the maker of the records, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the records.

Records of the law enforcement unit of an educational agency or institution. Law enforcement unit records are records that are: (1) created by a law enforcement unit; (2) created for a law enforcement purpose; and (3) maintained by the law enforcement unit.

Records relating to an individual who is employed by an educational agency or institution that are made and maintained in the normal course of business, relate exclusively to the individual in that individual's capacity as an employee and are not available for use for any other purpose. However, records relating to an individual in attendance at the agency or institution who is employed because of his or her status as a student are education records.

Records on a student who is 18 years of age or older, or attending a postsecondary institution, that are: (1) made or maintained by a physician or other recognized professional acting in that capacity; (2) made, maintained, or used only in connection with treatment of the student; and (3) disclosed only to individuals providing the treatment.

Records that are created or received by an educational agency or institution after an individual is no longer a student in attendance and that are not directly related to the individual's attendance as a student.

Records that are grades on peer-graded papers, before they are collected and recorded by a teacher.

There are three types of notification an LEA must provide parents and students. The first one is a general notification of their rights under PPRA.

The second notice is a notification of specific events. The following activities require notification:

Activities involving the collection, disclosure, or use of personal information collected from students for marketing purposes or for selling that information, or otherwise providing it to others for that purpose;

The administration of any survey containing one or more of the eight protected areas listed above: and

Any nonemergency, invasive physical examination or screening that is: (1) required as a condition of attendance; (2) administered by the school and scheduled by the school in advance; and (3) not necessary to protect the immediate health and safety of the student, or of other students.

The third notice is a notification of the policies LEAs are required to develop, in consultation with parents, under PPRA. The LEA shall provide the notice at least annually, at the beginning of the school year, and within a reasonable period of time after any substantive change in the policies.

A community-based organization may be considered a "school official" only if it:

Once a school determines that a community-based organization meets the above criteria, the organization may have access to PII from education records, without consent, under the school official exception, in order to perform the required institutional services and functions for the school. (S ee § 99.31(a)(1)(i)(B))

As with any other "education record," a photo or video of a student is an education record, subject to specific exclusions, when the photo or video is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution. (20 U.S.C. 1232g(a)(4)(A); 34 CFR § 99.3 "Education Record")[1]
Directly Related to a Student:
FERPA regulations do not define what it means for a record to be "directly related" to a student. In the context of photos and videos, determining if a visual representation of a student is directly related to a student (rather than just incidentally related to him or her) is often context-specific, and educational agencies and institutions should examine certain types of photos and videos on a case by case basis to determine if they directly relate to any of the students depicted therein. Among the factors that may help determine if a photo or video should be considered "directly related" to a student are the following:

The educational agency or institution uses the photo or video for disciplinary action (or other official purposes) involving the student (including the victim of any such disciplinary incident);

The photo or video contains a depiction of an activity:

that resulted in an educational agency or institution's use of the photo or video for disciplinary action (or other official purposes) involving a student (or, if disciplinary action is pending or has not yet been taken, that would reasonably result in use of the photo or video for disciplinary action involving a student);

that shows a student in violation of local, state, or federal law;

that shows a student getting injured, attacked, victimized, ill, or having a health emergency;

The person or entity taking the photo or video intends to make a specific student the focus of the photo or video (e.g., ID photos, or a recording of a student presentation); or

The audio or visual content of the photo or video otherwise contains personally identifiable information contained in a student's education record.

A photo or video should not be considered directly related to a student in the absence of these factors and if the student's image is incidental or captured only as part of the background, or if a student is shown participating in school activities that are open to the public and without a specific focus on any individual.

Examples of situations that may cause a video to be an education record:

A school surveillance video showing two students fighting in a hallway, used as part of a disciplinary action, is directly related to the students fighting.

A classroom video that shows a student having a seizure is directly related to that student because the depicted health emergency becomes the focus of the video.

If a school maintains a close-up photo of two or three students playing basketball with a general view of student spectators in the background, the photo is directly related to the basketball players because they are the focus of the photo, but it is not directly related to the students pictured in the background. Schools often designate photos or videos of students participating in public events (e.g., sporting events, concerts, theater performances, etc.) as directory information and/or obtain consent from the parents or eligible students to publicly disclose photos or videos from these events.

A video recording of a faculty meeting during which a specific student's grades are being discussed is directly related to that student because the discussion contains PII from the student's education record.

Maintained by an educational agency or institution:
To be considered an education record under FERPA, an educational agency or institution, or a party acting for the agency or institution, also must maintain the record. Thus, a photo taken by a parent at a school football game would not be considered an education record, even if it is directly related to a particular student, because it is not being maintained by the school or on the school's behalf. If, however, the parent's photo shows two students fighting at the game, and the parent provides a copy of the photo to the school, which then maintains the photo in the students' disciplinary records, then the copy of the photo being maintained by the school is an education record.
Exclusion for Law Enforcement Unit Records
The FERPA statute and regulations (20 U.S.C. 1232g(a)(4)(B)(ii) and 34 CFR §§ 99.3 and 99.8) exclude from the definition of education records those records created and maintained by a law enforcement unit of an educational agency or institution for a law enforcement purpose. Thus, if a law enforcement unit of an educational agency or institution creates and maintains the school's surveillance videos for a law enforcement purpose, then any such videos would not be considered to be education records. If the law enforcement unit provides a copy of the video to another component within the educational agency or institution (for example, to maintain the record in connection with a disciplinary action), then the copy of the video may become an education record of the student(s) involved if the video is not subject to any other exclusion from the definition of "education records" and the video is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution.

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"Law enforcement unit records" (i.e., records created by a law enforcement unit at the educational agency or institution, created for a law enforcement purpose, and maintained by the law enforcement unit) are not "education records" subject to the privacy protections of FERPA.

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Examples with videos

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As in many other sectors, the Internet of Things (IoT) has been a boon for education. From so-called "flipped classrooms" and online courses to integrated mobile technology and more efficient teaching methods, IoT-enabled connectivity continues to supplant pencils, paper and chalkboards as instructional approaches and learning opportunities expand.

Just as important, the IoT can improve things that complement a solid education - stuff like security via the use of smart cameras, climate control via the use of smart HVAC systems. Smart lighting systems are big, too, providing better and more energy efficient illumination.

Here are 10 examples of IoT in education and how each is making a huge impact.

IoT for Interactive Learning

Location: Seattle, Washington

Promethean makes interactive displays that combine multi-touch, dry-erase and natural writing technology, plus cloud-based lesson delivery software and personalized training for educators. The company's ActivPanel 9 is equipped with key features like an intuitive remote for navigation, the ability to record lessons and multiple sign-in options for security.

Location: New York, New York

Kaltura' s video management and creation tools enable students and teachers in and out of the classroom to create, edit and deliver live or on-demand high-quality video to any device. The company's end goal is to increase interaction and creativity to improve the overall learning experience.

Location: San Francisco, California

SweetRush designs, builds and tests education solutions for mobile and e-learning. Customized instructor-led training offers real-time feedback, and tools like competitive games and audio/video animation help increase participation and retention.

The company created a simulated call-center experience for a large financial services firm that wanted its call staff to learn and practice new skills without the need for classroom training and role playing.

More on the Internet of Things 38 Internet-of-Things (IoT) Companies You Should Know

Location: Boca Raton, Florida

Blackboard, part of Anthology, provides what the company describes as "a connected learning experience and support network" for a variety of fields, including K-12 and higher education. Blackboard's digital learning environment personalizes the educational experience, while virtual classroom technology increases collaboration and branded websites keep parents, students and others updated with the latest grades, attendance, events and news.

IoT for Reading and Document Scanning

Location: Kansas City, Missouri

Scanmarker produces digital highlighters that allow users to quickly scan editable text from books, papers and other documents directly into a phone, tablet or computer. That text is then translatable into more than 40 languages. There's also a function that allows you to listen while you scan.

Location: Sunnyvale, California

IPEVO develops teaching tools including document cameras that can be used to present documents for both in-person and virtual settings. The company says it limits its products to the necessary technology features to keep costs low and make tools that are intuitive and easy for teachers to use.

IoT for STEM Learning

Location: Philadelphia, Pennsylvania

A provider of programming and robotics education, LocoRobo uses robots to teach coding languages like Python, C, Javascript and MATLAB. The LocoIoT course instructs students on how to build, design and connect IoT systems from the ground up.

The company released a tiny AI robot called MyLoopy to teach children code-writing skills. Equipped with sensors that respond to touch, light, sound and other things, it learns both from its environment and human interactions.

Location: Mountain View, California

At Tynker, a BYJU's company, children start off learning to code via visual code blocks that represent actual programming concepts before progressing to popular languages like JavaScript and Python. Coding education can be applied to drones, apps, games, robots and more.

Tynker partnered with the toymaker Mattel to teach kids coding using various iterations of the popular action figure Barbie.

More on Education Technology 13 Edtech Examples You Should Know

IoT for Safe Connectivity

Location: Weymouth, England

Magicard makes a variety of student smart cards that can be presented to an authenticating reader and linked via IoT to an access control system. Types of cards include ones for physical access to facilities, photo ID (with hologram or UV printing), time and attendance, logical access (to monitor use of electronic data like coursework, e-learning resources, printers and internet), loyalty and membership, payment (for vending machines, printing, photocopying) and health data (blood type, emergency contacts).

Location: McLean, Virginia

Kajeet makes Wi-Fi education solutions for school buses, mobile hotspots, single devices and homes. For example, Wi-Fi enabled school buses provide students with safe internet connectivity to finish and turn in homework, and Kajeet says its SmartBus Wi-Fi system is easy to install and comes with lifetime maintenance resources.

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IoT in Education: 10 Connected Classroom Examples

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IoT in education has been changing the classroom experience for both teachers and students. Here are 10 examples of IoT applications for learning.

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Student engagement and ownership of learning

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Northwest VEX Robotics Final 1 Second View

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Benefits: Intervention, analyze student performance.

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Customization, crowd sourcing information, easier grading

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By Elana Lyn Gross, Contributor

Nothing seemed suspect when Jill Watson, a teaching assistant at the Georgia Institute of Technology (Georgia Tech), emailed students about assignments and answered questions during Professor Ashok Goel's online knowledge-based artificial intelligence course. In fact, it wasn't until the end of the semester that the students realized they hadn't been emailing a human at all - they'd been corresponding with a chatbot.

Goel had built an artificially intelligent teaching assistant that could answer routine questions so that he and the human teaching assistants could focus on responding to more complex issues, Business Insider reports.

And he isn't the only person using artificial intelligence to improve education. The teams at companies including Thinkster Math, Brainly, Content Technologies Inc., and Gradescope are creating artificial intelligence tools to aid students and educators. Educators are using AI tools to assess students' skills and weaknesses, create customized learning materials, and make time-consuming tasks like grading more efficient and effective. Artificial intelligence is benefiting students by facilitating peer-to-peer learning and enabling them to create customized textbooks and study guides. Here's a closer look at how some companies are developing artificial intelligence programs to improve education.

1. Assessing and Addressing Students' Skills and Weaknesses

Thinkster Math uses artificial intelligence and machine learning to track the steps students take while solving math problems. Students solve problems on the app, and it produces detailed progress reports specifying their understanding of the different skills tested, such as order of operations or long division. Thinkster Math matches students with online math tutors who personalize their learning programs based on the students' strengths and weaknesses, but it is also used in the classroom.

Educators use Thinkster Math to determine how students learn and comprehend math concepts so they don't fall behind. The app enables them to quickly diagnose each student's weaknesses without having to review a large stack of tests and assignments, leaving them more time to create individualized assignments that target specific skill sets.

2. Empowering Students with Crowdsourced Learning

Brainly isn't used in the classroom. Rather, the online messaging board facilitates peer-to-peer learning by making it easy for students to ask questions, connect with "friends," and have their questions answered by other students.

Brainly moderators verify questions and answers on the platform to make sure they're high-quality. The company also developed machine learning algorithms that automatically filter out spam and low-quality content, such as incorrect answers, so that moderators have more time to focus on helping students navigate the site, the Next Web reports.

Additionally, Brainly partnered with Professor Chirag Shah and Rutgers University to use machine learning to match students based on their skill sets. A student who has successfully answered advanced American history questions, for example, could be matched with a student who has questions about American history coursework. "We start off by determining a new user's learning level by offering them easier questions to answer. Then we connect them with other, more established Brainly users who can mentor them, and then we gradually move them forward ... We're looking to spark interest and endow confidence for students who may lack interest or support," Professor Shah said on Brainly's blog.

3. Creating Customized Learning Materials

Content Technologies Inc. (CTI), an artificial intelligence research and development company, develops AI that creates customized educational content. Using deep learning to absorb and analyze existing course materials, textbooks, and syllabi, the technology creates custom learning materials, including textbooks, chapter summaries, and multiple choice tests, PCMag reports.

CTI has two additional tools: Cram101 and JustTheFacts101. Cram101 uses AI to break down existing textbooks into nuggets of information and generates study guides with chapter summaries, practice tests, and even flashcards. Similarly, JustTheFacts101 highlights pertinent information from the textbook and builds chapter summaries. These tools save time on some of the more menial study tasks - like making a mountainous stack of flashcards - so students have more time to focus on comprehending concepts.

4. Decreasing Time Spent Grading

Gradescope makes grading tests and assignments a lot speedier for secondary school and higher education instructors. Students upload assignments to the Gradescope platform, and its AI capability sorts and groups answers to check multiple assignments at once. According to Gradescope, its use of AI decreases time spent grading by 70 percent or more.

Additionally, the software provides instructors with a detailed analysis on what their students got right and wrong so they can provide individualized tutoring to each student or re-teach entire concepts.

In conversations about artificial intelligence, concerns often arise about its impact on human employees. One commonality between each of these educational tools, however, is that they are used to provide value to teachers and tutors, rather than taking their place. "The way I think about it, there are seven billion people on this earth, and about half of them don't have access to good education," Professor Goel said in a conversation with Quartz. "If we can take artificial intelligence and provide those people with minimal question answering, who knows what a difference it could make in someone's life?"

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4 Ways Artificial Intelligence is Revolutionizing Education

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By Elana Lyn Gross, Contributor Nothing seemed suspect when Jill Watson, a teaching assistant at the Georgia Institute of Technology (Georgia Tech), emailed students about assignments and answered questions during Professor Ashok Goel's online knowledge-based artificial intelligence course.

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Simple introduction with examples

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Dr. Puentedura developed the SAMR Model.

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How to Apply the SAMR Model with Ruben Puentedura

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Same assignments shown through each level of SAMR

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Examples of Applying the SAMR Model can Help Teachers Understand and Embrace it

The SAMR Model for integrating technology into teaching, developed by Dr. Ruben Puentedura, has gained a good deal of exposure in recent years. "SAMR" is an acronym that stands for Substitution, Augmentation, Modification, and Redefinition. The SAMR model provides a technique for moving through degrees of technology adoption to find more meaningful uses of technology in teaching and move away from simply using edtech for tech's sake.

We recently discussed the SAMR model during an Academic Technology Work Group meeting at The College of Westchester. We examined the video, SAMR in 120 Seconds. One thing that really struck me is how much the example helped, so I made it a point to gather and/or create some more examples.

Following are 8 examples of the SAMR process, each taking an example of a typical classroom exercise that does not use technology and walking it through each phase of SAMR. For half of these, I searched and borrowed from examples that teachers had written about online (original sources are provided - in some cases I tweaked the example a bit). I also created examples of my own. In working through this, it became apparent to me that while Substitution and Augmentation can be relatively straightforward conceptually, there is even more room for interpretation when it comes to Modification and Redefinition.

The goal of this exercise was to help me (and readers) better understand the SAMR model, and to really see how lessons and assessments can be transformed while considering the benefits of evolving them through these stages. I find it particularly interesting to see the vast difference between the original lesson and the redefined lesson - there is often a much wider range of skills required in the latter stages, and lessons can become much more engaging and collaborative when modified or redefined.

Lesson: Writing a Short Paper
Taken from: http://www.educatorstechnology.com/2013/08/samr-model-explained-through-examples.html. A modification of an idea found at https://edofict.wikispaces.com/SAMR+Examples. Taken from: https://edofict.wikispaces.com/SAMR+Examples and modified. Idea taken from: https://sites.google.com/a/msad60.org/technology-is-learning/samr-model and slightly modified. In this example, we take a simple form of assessment and evolve it into a collaborative group project.
Original Assignment: A hand written paper.

Lesson: Geography & Travel

Original Assignment: An overview of a location consisting of hand written content supplemented with compiled cut-and-pasted magazine clippings.

Lesson: Understanding Shakespeare

Original Assignment: Read a Shakespeare play in traditional printed format.

An Assessment Exercise
Original Assignment: Show understanding of fractions on a worksheet by coloring in blocks.
Original Assignment: Take a quiz, answers handwritten in a printed form.

Following are some example lessons, evolved through the SAMR model, that I have tried my hand at creating.It's easy to get caught up in worrying about how effectively an approach constitutes "modification" or "redefinition", but that's not the point of the exercise. To my way of thinking, it's more about understanding the difference between a just replacing or augmenting a "paper" lesson with a "digital" one and actually evolving it in a beneficial way and exploring new possibilities.

Lesson: Art/Painting
Creative Commons license image source.
Original Assignment: Drawing a picture using traditional brush, paint, paper. Of course, there is a a big difference between doing this by hand in the traditional manner and doing it digitally. Digitally is by no means better, it is just different and opens up some interesting possibilities.

Substitution: Use a digital drawing/painting program (like MS Paint) to draw/paint a picture.

Augmentation: Use a tool that allows the creation of your masterpiece to be layed back (like Educreations, for example).

Modification: Pull a background image to use as a canvas. You could even scan something hand drawn and use that.

Redefinition: Create Artwork Collaboratively using a Collaborative Online Whiteboard (like Twiddla or one of these other tools).

Lesson: Email Etiquette

Original lesson: Review printed copies of Email Etiquette concepts and guidelines.

Lesson: Learning Fractions

Substitution: Use an Excel Worksheet to let students color in the blocks.

Augmentation: Use Google Sheets to let students color in the blocks, where the teacher can offer feedback directly on Google Sheets.

Modification: Use Google Sheets and direct students to online examples and supplementary learning materials for areas that they might struggle with.

Redefinition: Use a Fractions App instead (here are a handful of examples for iOS devices).

Lesson: Phys Ed - Learning To Hit a Baseball Well

Original Assignment: Learning how to hit a baseball by watching and listening to a Coach or Phys Ed instructor show you and then trying it yourself.

Hopefully these example of lessons modified through the SAMR cycle help to encourage you to think about how you leverage technology to make some of your lessons more interactive, collaborative, and engaging with some of the many great technology tools available today! Here is a set of tools that may be helpful when working to evolve your lessons: 10 of the Most Engaging Uses of Instructional Technology (with Dozens of Resources and Tools).

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8 Examples of Transforming Lessons Through the SAMR Cycle - Emerging Education Technologies

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Examples of Applying the SAMR Model can Help Teachers Understand and Embrace it The SAMR Model for integrating technology into teaching, developed by Dr. Ruben Puentedura, has gained a good deal of exposure in recent years. "SAMR" is an acronym that stands for Substitution, Augmentation, Modification, and Redefinition.

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Teacher and Student Descriptors for Technology Integration Matrix

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Teacher and Student Descriptors for Technology Integration Matrix

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With examples and descriptions of what students and teachers are doing at each stage

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Comparison and discussion of TIM

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What is the Technology Integration Matrix?

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How TIM can help teachers choose tech thoughtfully and effectively

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Districts around the country are adding technology to their classrooms. But in a world where new hardware and software seems to appear daily, which tools are the best for which grade level? And what's the best way to use these tools to truly improve teaching and learning? To give schools some guidance, the Florida Center of Instructional Technology (FCIT) has created the Technology Integration Matrix (TIM) to illustrate how teachers can use technology to enhance learning for K-12 students.

Designed to be used as the foundation for technology coaching, the TIM incorporates five interdependent characteristics of meaningful learning environments: active, constructive, goal-directed, authentic, and collaborative. The TIM associates five levels of technology integration (entry, adoption, adaptation, infusion, and transformation) with each of those five characteristics. Together, the five levels of technology integration and the five characteristics of meaningful learning environments create a matrix of 25 cells. (See the figure below)

Although anything containing the word "cells" may sound rigid, Mark Quintana, who uses the TIM with clients as part of his work as a senior education consultant for Promethean, said that's not the case. The matrix also provides evaluation tools and resources for teachers, and the process of using it varies from school to school. Quintana, whose team has used the matrix with Broward County Public Schools (FL), Fulton County Public Schools (GA), and the Ministry of Education in the Bahamas, said, "We customize the TIM process for different school systems dependent on their desire, among others, for the coaching relationship to be between administrator and teacher, instructional coach and teacher, and/or peer teacher to peer teacher."

Quintana said that the matrix is not about teaching teachers how to use specific technology products, but rather "about how to use any and all available technology most effectively and efficiently." At its heart, Quintana adds, "The TIM is about increasing student engagement in the classroom to where the student is at the center of lesson-plan implementation, and the student has choices in both the resources/tools used and the content with which they are interacting."
The TIM in Action
Autrey Mill Middle School in Alpharetta, Georgia, has used the TIM to help teachers optimize their use of Promethean interactive displays and collaborative learning software, as well as other technology in their classrooms. Principal J.E. "Trey" Martin said that Autrey Mill started using the matrix because "we wanted to support our teachers in a non-threatening way. The TIM provides several samples and videos to help teachers grow. I funded the training of several tech coaches at our school to lead others."

One of those coaches is Andrea N. Rioux, an instructional technology specialist, who pointed out, "As a school, we have a plethora of technology available to teachers and students. We wanted the technology used in more meaningful ways. The TIM gives us a common language to discuss and implement effective technology integration in the classroom."

To put the matrix to its best use, Martin said, teachers started with a self-assessment and then created an attainable technology goal that they would aim for-with the support of teacher coaches.

Marisa Wesker, a seventh-grade social studies teacher, is also a peer coach. She said that the TIM has helped her clarify the underlying purpose of all the technology that Autrey Mill provides her. "Just because I teach with technology," she said, "does not mean it is effective. The TIM helped me re-evaluate how I was using technology during instruction. Now, I use technology to increase collaboration and to build knowledge."

At its most effective the TIM is not a simple set of steps to follow. It is a catalyst for the kind of re-evaluation that empowers teacher like Wesker, who are always looking to improve their practice. According to Rioux, "The TIM is the main tool we are using this year to help teachers grow their own pedagogy." After teachers have an observation from a peer coach, Rioux said, they meet to discuss the observation, consider how to improve the technology integration, and determine concrete steps that teachers should take to achieve the technology goals they set at the beginning of the process.

Rioux also uses observation data from the matrix to determine where teachers might need help with specific aspects of classroom tech so that she can focus on those areas in the Technology Discovery workshops she offers on Fridays.

Rioux heartily recommends using the TIM as the basis for a peer-coaching model. At Autrey Mill, she said, "The coaches are excited to mentor and support teachers. Teachers are thriving and using more and more technology through our non-threating and non-evaluating system."

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Teaching Teachers to Master their Own Tech

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Districts around the country are adding technology to their classrooms. But in a world where new hardware and software seems to appear daily, which tools are the best for which grade level? And what's the best way to use these tools to truly improve teaching and learning?

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Overviews clearly explained

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Ensuring technology use is purposeful and tied to content and pedagogy

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Reviews each of the three types of knowledge and their overlaps

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Lisa Dietrich

Lisa Dietrich ( lisa.dietrich@uoit.net)
University of Ontario Institute of Technology

TPACK refers to the knowledge and competencies at work within the complex profession of teaching, examined through the lens of the Technological, Pedagogical and Content Knowledge infrastructure. Closely aligned with the interdependent relationships between these competencies exists the implications of those conditions created once technology is figured into the equation. Mishra and Koehler posit that the competencies inherent in the three core knowledge areas, must work in tandem with pedagogical content knowledge, technological content knowledge and technological pedagogical content knowledge for the essence of TPACK to be fully realized. Essentially, fluency within and between these core domains is required for successful adoption of technology within the curriculum.

Keywords: curriculum, pedagogy, teaching, technology, TPACK.

The concept of Pedagogical Content Knowledge (PCK) was first introduced by Lee Shulman in 1986, and later revisited by Punya Mishra and Matthew Koehler in 2006. Over the past 20 years, the progression of technology and the flexibility it offers educators to enhance and promote learning, prompted Mishra and Koehler to incorporate a technological domain, to speak to those emerging affordances. Education has gone through a transformation with technology at the helm, reconfiguring the pedagogical landscape and opening doors for more robust teaching and learning opportunities for both educators and students. In many classrooms, the presence of technological tools is interwoven into the fabric of many teaching pedagogies such as those involving mobile applications. The restructured TPACK model encapsulates Shulman's three original domains and their interrelationships within the educational context. Mishra and Koehler's reimagined framework goes further to detail the complex interplay between Technological, Pedagogical and Content Knowledge once a teacher has elected to integrate technology within the curriculum, unveiling the intrinsic role that technology now assumes within the classroom environment.

Punya Mishra and Matthew Koehler, developers of the TPACK framework, contend that uniting technology within the classroom has further complicated the teaching profession. They propose that understanding how these bodies of knowledge, both theoretically and in practice interact, will provide teachers with the types of flexible knowledge needed to successfully integrate technology use into their teaching practice (Koehler & Mishra, 2009).

Utilizing Shulman's Pedagogical Content Knowledge (PCK) framework to form the basis for their model, Mishra and Koehler identified three core components at the heart of good teaching practices: Content, Pedagogy, Technology and the interrelationship among and between them. The domains are represented as PCK (Program Content Knowledge), TCK (Technological Content Knowledge), and TPK (Technological Pedagogical Knowledge or TPACK) as illustrated in Figure 1:

Lee Shulman

Lee Shulman, professor emeritus at Stanford Graduate School of Education, has focused on two key themes through much of his research as an educational psychologist:

1. Cognition in professional practice, particularly under conditions of uncertainty and

2. The domain-specificity of expertise (Shulman, n.d.)

Shulman first coined the term Pedagogical Content Knowledge (PCK) through his research involving new teachers and the process of assimilating content knowledge. The research posed many questions, among them, the following:

Where do teacher explanations come from?

How do teachers decide what to teach, how to represent it, how to question students about it?

How do teachers take a piece of text and transform their understanding of it into instruction that their students can comprehend? (Shulman, 1986, p. 8).

Shulman's research was positioned to address such pedagogical perplexities surrounding the ways in which teachers, novice or seasoned, draw on expertise in the subject matter in the process of teaching (Shulman, 1986). Essentially, understanding how one determines what and how to teach for optimum, authentic learning to occur is valuable information for educators since it speaks to how learning for teaching occurs and this insight, can clarify the strengths and weaknesses of strategies currently being utilized.

Soon after embarking on his journey to uncover the intricacies of teacher understanding and transmission of content knowledge, Shulman realized that a more detailed theoretical framework from which to isolate his findings was required, in efforts to move forward in his research and thus, the PCK model was born (Shulman, 1986).

Shulman commenced this process by defining three categories of Content Knowledge, namely: Subject Matter Content Knowledge, Pedagogical Content Knowledge and Curricular Knowledge.

1. Subject Matter Content Knowledge

Subject Matter Content Knowledge or simply, Content Knowledge, (CK), is the amount and organization of knowledge in the mind of the teacher

To think properly about content knowledge requires going beyond knowledge of the facts or concepts of a domain to understanding the structures, such as those outlined in Bloom's Taxonomy of Cognitive Learning Objectives (Adams, 2015)

The teacher needs to go beyond basic knowledge of a subject to the why, with proof and, under what circumstances our belief in its justification can be weakened or refuted (Shulman, 1986)

We also expect the teacher to understand why a given topic is particularly central to a discipline in contrast to others that do not assume center stage (Shulman, 1986., p. 9)

2. Pedagogical Content Knowledge

Pedagogical Content Knowledge or PCK, refers to the subject matter knowledge for teaching or, the representation of those ideas, the most powerful analogies, examples, explanations, and demonstrations of that knowledge that present as clear, comprehensible illustrations

An understanding of what makes the learning of specific topics easy or difficult alongside the preconceived notions of what students from various backgrounds and ages bring with them to the learning environment, is intrinsic to PCK (Shulman, 1986)

3. Curricular Knowledge

Curricular Knowledge or CK, constitutes the full range of programs behind the subject being taught, coupled with the instructional materials such as texts, software, programs and visual materials at the disposal of the teacher

CK refers to the justification of those selected instructional materials and speaks to the necessity for teachers to demonstrate the ability to relate the content of a given course or lesson to topics or issues being discussed across other subject areas (Shulman, 1986)

Punya Mishra, Associate Dean of Scholarship & Innovation at Mary Lou Fulton Teacher's College, Arizona State University and Mathew Koehler, Professor, Department of Counseling, Educational Psychology and Special Education at Michigan State University, reimagined the model from the perspective of 21st century skill building, closely integrating the presence of technology into Shulman's framework.

Through intensive examination of Shulman's work, colleagues Mishra and Koehler became invested in the study of the interrelationships between the Content, Pedagogical and Curricular domains developed by Shulman. Specifically, their research of these domains exposed an omission in lieu of the growth of technology within education since Shulman's seminal work had been completed, prompting them to modify the existing PCK model to include that of educational technology. (Koehler & Mishra, 2009).

Through the inclusion of the technical content knowledge required to engage students through the utilization of an expanded array of technological tools, the Technological Content Knowledge Domain (TCK) aptly captures the intrinsic nature of technology's potential presence in today's educational environment. Mobile devices and tablets, the collaborative landscape of web 2.0 that provide for innovative pedagogies that extend beyond the concrete walls of the classroom to the virtual, are captured and interwoven into the TPACK model.
Return to Figure 1.
Content Knowledge

Content knowledge (CK) is the teachers' knowledge about the subject matter to be learned or taught. This knowledge includes knowledge of concepts, theories, ideas, organizational frameworks, knowledge of evidence and proof, as well as established practices and approaches toward developing such knowledge (Mishra & Koehler, 2009).

Key points

In the case of art appreciation, such information would include knowledge of art history, famous paintings, sculptures, artists and their historical contexts, as well as knowledge of aesthetic and psychological theories for evaluating art

The cost of not having a comprehensive base of content knowledge could include students receiving incorrect information and developing misconceptions about the content

Pedagogical Knowledge

Mishra and Koehler, 2009, speak to Pedagogical knowledge (PK) as teachers' deep knowledge about the processes and practices or methods of teaching and learning. They encompass, among other things, overall educational purposes, values, and aims. Pedagogical knowledge requires an understanding of cognitive, social, and developmental theories of learning and how they apply to students in the classroom.

Key points

General classroom management and lesson-planning are overarching themes in this domain

Providing encouraging feedback via assessment creates a positive space for learning

Technological Knowledge

Technology Knowledge (TK) is always in a state of flux. Mishra and Koehler (2009), embrace Fluency of Information Technology or FITness, to describe the TK component; the framework was originally proposed by the Committee of Information Technology Literacy of the National Research Council NRC (1999). FITness guidelines extend beyond traditional notions of computer literacy to require that persons understand information technology broadly enough to apply it productively at work, and in their everyday lives, understanding the need for flexibility as technology advances.

Key Points

A deep understanding of information technology for information processing, communication and problem-solving is required

This level of understanding is necessary to afford individuals the ability to utilize technology to accomplish a variety of different tasks and to develop different ways of accomplishing those tasks

Return to Figure 1.
Pedagogical Content Knowledge

Mishra & Koehler, 2009 state that Pedagogical Content Knowledge (PCK) covers the core business of teaching, learning, curriculum, assessment and reporting. An awareness of common misconceptions and ways of looking at them, the importance of forging connections among different content-based ideas, students' prior knowledge, alternative teaching strategies, and the flexibility that comes from exploring alternative ways of looking at the same idea or problem are all essential for effective teaching.

Key Points

The essence of PCK is found in how teachers interpret and choose to represent the subject being taught by ways of methodologies and technologies selected

The conditions that promote learning and the links among curriculum, assessment, and pedagogy embody the PCK domain

PCK speaks to the necessity for teachers to examine the learning environment from multiple angles and assess various methods of teaching for effective selection of delivery methods

Re-evaluating curriculum with a view to students' prior knowledge is recommended

Exploring different teaching strategies is central to this domain, in efforts for teachers to connect different content-based ideas

Technological Content Knowledge

Technological Content Knowledge (TCK) is an understanding of how technology and content influence and constrain one another (Mishra & Koehler, 2009).

Key Points

Teachers need to understand what specific technologies are best suited for addressing subject-matter learning in their domains and how the content dictates or perhaps even changes the technology-or vice versa

Viewing the heart as a pump (Trinity Animation, 2018) is a way in which technology has provided new perspectives for understanding phenomenon

Technological Pedagogical Knowledge

Technological Pedagogical Knowledge (TPK) is an understanding of how teaching and learning can change when selected technologies are used in specific ways. This includes knowing the pedagogical affordances and limitations of a range of technological tools as they relate to disciplinarily and developmentally appropriate pedagogical designs and strategies (Mishra & Koehler, 2009).

Key Points

To build TPK, a comprehensive understanding of technological tools and how they can be pedagogically integrated for enhancement of learning is imperative

Since most software programs are not designed for educational purposes, teachers need to develop skills to look beyond most common uses for the technologies, reconfiguring them for customized pedagogical purposes

Technology, Pedagogy and Content Knowledge

Technology, Pedagogy and Content Knowledge (TPACK) goes beyond all three core components of content, pedagogy, and technology and forms the basis for effective teaching with technology (Mishra & Koehler, 2009).

The following conditions exist within Technology, Pedagogy and Content Knowledge:

The representation of concepts using technologies

Pedagogical techniques that use technologies in constructive ways to teach content

Knowledge of what makes concepts difficult or easy to learn

An understanding of how technology can help redress some of the problems that students face

Knowledge of how technologies can be used to build on existing knowledge

Teachers need to develop fluency and cognitive flexibility not just in each of the core competencies (Technology, Pedagogy and Content), but also in the interplay that exists between these domains and contextual parameters, so that they can construct effective solutions (Mishra & Koehler, 2009).

The TPACK model incites teachers, researchers, and teacher educators to move beyond oversimplified approaches that treat technology as an afterthought, redirecting their attention to the ways in which the connections among technology, content, and pedagogy, unravel within the classroom setting (Mishra & Koehler, 2009).

Addressing the Challenges of Technology

Each new day brings rapid, technological progress and while we are living in a time that is rife with the technological implications for education, it can also be overwhelming to teachers. New teachers or, teachers who have an established teaching style and are comfortable with traditional approaches to classroom learning, are often those who experience the greatest challenges. Some of the predominant barriers that teachers face with respect to the integration of technology into the classroom are captured in the infographic below:

TPACK classifies the types of knowledge into manageable pieces and expresses the relationship between each distinguishing component, allowing teachers to address some of the above concerns such as lack of confidence. TPACK can serve as a guiding template for efforts surrounding technology integration. Teachers are prompted to revisit existing teaching strategies and contemplate ways they can attain the deeper understanding required to satisfy the expectations contained in the dynamic nature of the intersecting domains. The TPACK method embodies a holistic approach to successful teaching.

Mishra, Koehler & Kereluik (2009) assert that technology itself is not as important as how to integrate it with classroom instruction (Incikabi & Tokmak, 2013, p. 293). Preparing teachers through the integration of TPACK into training for technology integration, will provide more perspective regarding the multi-faceted nature of technology, content and pedagogy.

Using TPACK to Assist Mathematics Teachers Effectively Integrate Technology for Instruction

The following example positions the TPACK model as the basis for framing instructional practices within an educational environment.

The National Council of Teachers of Mathematics (2000), has placed emphasis upon TPACK, stating that "Technology is essential in teaching and learning mathematics; it influences the mathematics that is taught and enhances students' learning" (Incikabi & Tokmak, 2013, p. 294).

An undergraduate course was specifically designed for mathematics teacher candidates to enhance their understanding of TPACK. The course was comprised of three main steps.

Step A: Selection and evaluation of educational software about the topic took place, utilizing the ASSURE Model developed by Heinich, Molenda, Russell & Smaldino, 2002, consisting of the following stages:

Analyze the learner
S tate objectives
S elect media
U tilize media
Require learner participation
E valuate and revise

Students were required to discuss the reasoning behind their selection and subsequent evaluation of the media

Students were also instructed to prepare a lesson plan for teaching of a mathematical subject by utilization of the selected educational software (TPK) (Incikabi & Tokmak, 2013, p. 294)

Step B: Students were required to prepare a PowerPoint presentation on the topic

Step C: Students taught a class following the lesson plan with the integration of all technologies selected for inclusion during instruction.

Incorporated all elements of TPACK throughout the process with the culmination of all domains represented in the final state of the training (Incikabi & Tokmak, 2013).

After each activity, all groups shared their insights and comments via blogs. The activities required integration of technology throughout the entire teaching process, taking into consideration technology interaction with content and pedagogy. The TPACK model was utilized for preparation of the lesson plan activity.

The analysis of the pre-service teachers' TPACK perceptions before and after the course revealed statistically significant gains with good effect sizes. Regression analysis also revealed that technological knowledge, pedagogical and content knowledge were all significant predictors of pre-service teachers' TPACK, with pedagogical knowledge having the largest impact.

The outcome of the course illustrated that teachers' understanding of Technological Pedagogical Content Knowledge is critical in accomplishing successful technology integration in teaching. Teachers ultimately gained deeper and more complex understanding of technological pedagogical content knowledge and therefore, a more profound understanding of how to integrate technology into their teaching practice (Incikabi & Tokmak, 2013).

The TPACK model offers a detailed framework for technology integration for educational purposes. The framework, coupled with training and embedded classroom assistance can lead to changes in instructional strategies and subsequent positive changes in student learning (Newman, Coyle & McKenna, 2015).

The knowledge gleaned by the implementation of TPACK into teacher development with regards to technology integration promotes the productive use of technology to increase the effectiveness and quality of instruction throughout the whole process of teaching specific content from planning, to evaluation (Yurdakul, Odabasi, Sahin & Coklar, 2015).

When used as a frame of reference for technological integration into established or newly developed curriculum, TPACK affords educators a comprehensive understanding of how content, technology and pedagogical knowledge intersect to create the unification of all three components, speaking to the significance of each domain and, the implications the relationships between each hold for the efficacious, seamless unification of technology and teaching.

References

Adams, N. (2015). Bloom's taxonomy of cognitive learning objectives. Journal of the Medical Library Society 103(3) 152-153.

Incikabi, L., Tokmak, H. (2013). Integrating Technology into Mathematics Teaching: A TPACK (Technological, Pedagogical, Content Knowledge)-Based Course Design for College Students . In J. Keengwe (Ed.). Research perspectives and best practices in educational technology integration (270-287). Hershey, PA: IGI Global.

Joseph, J. (2012). The Barriers of Using Education Technology for Optimizing the Educational Experience of Learners. Procedia - Social and Behavioral Sciences 64. 427 - 436.

Keengwe (Ed.). Research perspectives and best practices in educational technology integration . Hershey, PA: IGI Global.

Koehler, T. (2018). The TPACK Framework. [Web page]. Available from tpack.org

Koehler, M., Mishra, P., (2009). What is Technological Pedagogical Content Knowledge (TPACK)? CITE Journal 9(1).

Kurt, S. (2018). Assure: instructional design model. Retrieved from https://educationaltechnology.net/assure-instructional-design-model/

McGraw Hill Education Canada (2017). What is TPACK Theory and How Can it be Used in the Classroom. [Web log post]. Available from https://www.mheducation.ca/blog/what-is-tpack-theory-and-how-can-it-be-used-in-the-classroom/

Mishra, P., Koehler, M. (2006). Technological pedagogical content knowledge: a framework for teacher knowledge. Teachers College Record 108(6). 1017-1054.

Mishra, P., Koehler, M., Kereluik, K. (2009). The song remains the same: looking back to the future of educational technology. TechTrends, 53(5), 48-53.

Newman, D., Coyle, V., Mckenna, L. (2013). Changing the Face of ELA Classrooms: A Case Study of TPACK Professional Development. In J. Keengwe (Ed.). Research perspectives and best practices in educational technology integration (270-287). Hershey, PA: IGI Global.

Shulman, L. (n.d.). Biography. Available from http://www.leeshulman.net/biography/

Shulman, L. (1986). Those who understand: knowledge growth in teaching. Educational Researcher 15(2). 4-14.

Technology Innovation in School Education. (2016). Available from https://fourthambit.com/fa/blogs/102428

The National Academies Press. (1999). Being fluent with information technology. Retrieved from https://www.nap.edu/read/6482/chapter/1

Trinity Animation. (2018). Viewing the heart as a pump. [YouTube video]. Available from https://www.youtube.com/watch?v=9ue1ALMk6aE

Yurdakul, I., Odabasi, H., Sahin, Y., Coklar, A. (2013). A TPACK Course for Developing Pre-Service Teachers' Technology Integration Competencies: From Design and Application to Evaluation. In J. Keengwe (Ed.). Research perspectives and best practices in educational technology integration (242-269). Hershey, PA: IGI Global.

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Technology and the Curriculum: Summer 2018

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Lisa Dietrich Lisa Dietrich ( lisa.dietrich@uoit.net) University of Ontario Institute of Technology TPACK refers to the knowledge and competencies at work within the complex profession of teaching, examined through the lens of the Technological, Pedagogical and Content Knowledge infrastructure.

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Breaks down a before/after of a lesson using TPACK

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Access videos, whitepapers, eBooks, webinars, blogs, infographics, case studies, demos and more in our resource hub to support your success.

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SAMR can feel more linear, although useful. TPACK overlaps.

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TPACK vs SAMR: Key Differences Between 2 Tech Frameworks

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What is or isn't blended learning

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Description of various models

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For a full overview on blended learning basics and models, visit the Blended Learning Universe, an online hub curated by the Christensen Institute.

The definition of blended learning is a formal education program in which a student learns:

1. at least in part through online learning, with some element of student control over time, place, path, and/or pace;

2. at least in part in a supervised brick-and-mortar location away from home;

3. and the modalities along each student's learning path within a course or subject are connected to provide an integrated learning experience.

The majority of blended-learning programs resemble one of four models: Rotation, Flex, A La Carte, and Enriched Virtual. The Rotation model includes four sub-models: Station Rotation, Lab Rotation, Flipped Classroom, and Individual Rotation.

1. Rotation model - a course or subject in which students rotate on a ﬁxed schedule or at the teacher's discretion between learning modalities, at least one of which is online learning. Other modalities might include activities such as small-group or full-class instruction, group projects, individual tutoring, and pencil-and-paper assignments. The students learn mostly on the brick-and-mortar campus, except for any homework assignments.

a. Station Rotation - a course or subject in which students experience the Rotation model within a contained classroom or group of classrooms. The Station Rotation model differs from the Individual Rotation model because students rotate through all of the stations, not only those on their custom schedules.

b. Lab Rotation - a course or subject in which students rotate to a computer lab for the online-learning station.

c. Flipped Classroom - a course or subject in which students participate in online learning off-site in place of traditional homework and then attend the brick-and-mortar school for face-to-face, teacher-guided practice or projects. The primary delivery of content and instruction is online, which differentiates a Flipped Classroom from students who are merely doing homework practice online at night.

d. Individual Rotation - a course or subject in which each student has anindividualized playlist and does not necessarily rotate to each available station or modality. An algorithm or teacher(s) sets individual student schedules.

2. Flex model - a course or subject in which online learning is the backbone of student learning, even if it directs students to offline activities at times. Students move on an individually customized, ﬂuid schedule among learning modalities. The teacher of record is on-site, and students learn mostly on the brick-and-mortar campus, except for any homework assignments. The teacher of record or other adults provide face-to-face support on a flexible and adaptive as-needed basis through activities such as small-group instruction, group projects, and individual tutoring. Some implementations have substantial face-to-face support, whereas others have minimal support. For example, some Flex models may have face-to-face certified teachers who supplement the online learning on a daily basis, whereas others may provide little face-to-face enrichment. Still others may have different staffing combinations. These variations are useful modifiers to describe a particular Flex model.

3. A La Carte model - a course that a student takes entirely online to accompany other experiences that the student is having at a brick-and-mortar school or learning center. The teacher of record for the A La Carte course is the online teacher. Students may take the A La Carte course either on the brick-and-mortar campus or oﬀ-site. This differs from full-time online learning because it is not a whole-school experience. Students take some courses A La Carte and others face-to-face at a brick-and-mortar campus.

4. Enriched Virtual model - a course or subject in which students have required face-to-face learning sessions with their teacher of record and then are free to complete their remaining coursework remote from the face-to-face teacher. Online learning is the backbone of student learning when the students are located remotely. The same person generally serves as both the online and face-to-face teacher. Many Enriched Virtual programs began as full-time online schools and then developed blended programs to provide students with brick-and-mortar school experiences. The Enriched Virtual model differs from the Flipped Classroom because in Enriched Virtual programs, students seldom meet face-to-face with their teachers every weekday. It differs from a fully online course because face-to-face learning sessions are more than optional office hours or social events; they are required.

Source: Michael B. Horn and Heather Staker, Blended: Using Disruptive Innovation to Improve Schools (San Francisco: Jossey-Bass, 2014).

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Blended Learning Definitions - Christensen Institute

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For a full overview on blended learning basics and models, visit the Blended Learning Universe, an online hub curated by the Christensen Institute. The definition of blended learning is a formal education program in which a student learns: at least in part through online learning, with some element of student control over time, place, path, and/or [...]

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Practical tips for incorporating blended learning

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List of ideas for effective, rigorous distance/digital education

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Photo: Chino Valley Unified School District/Facebook

As the new school year begins, districts are facing demands from parents and elected officials while also hearing calls for "more rigor" through distance learning.

In making this important shift to higher standards and to meet expectations, teachers, schools and districts should understand that "more rigor" must mean higher quality distance learning, not just more complexity or quantity.

Gov. Gavin Newsom has insisted that distance learning be "rigorous" and include "daily, live interactions" between students and teachers, "challenging assignments" equivalent to those made in in-person classes and lessons adapted for English language learners and students with disability.

Parents and education leaders rightly are demanding improved connectivity and more digital devices, more minutes of remote instruction, grade transparency and greater attention to students' social and emotional needs.

However - thinking these are hallmarks of "rigor" - some parents also likely will demand ineffective strategies, such as long lists of spelling words, more complex math problems or extra credit assignments, without realizing the severe consequences these demands can have on their child's motivation to learn.

Given these conflicting demands of rigor without adequate support or preparation for teachers, we run the risk of simultaneously trivializing and complicating access to content and negatively affecting student engagement.

An editorial published in Science notes teaching difficult concepts before a child is ready to understand them is counterproductive and often leads to "overly strict attention to rules, procedures and rote memorization," ultimately taking all the joy out of learning.

To support teachers and students with distance learning, here are practical approaches to preserving academic and creative rigor:

Provide teachers with ongoing professional development, coaching and time to expand their expertise in using online platforms, creating lessons, collaborating with their colleagues and delving deeply into the tools and content they will use to help students succeed in a distance learning environment.

Use project-based learning to create lessons where students actively explore real-world problems and challenges to help deepen content knowledge. Examples include students exploring racism and social justice in language arts through the use of articles, poems, songs, documentaries and books such as "The Hate U Give" and "Just Mercy" to address relevant issues. Teachers can also assign history lessons that compare and contrast the coronavirus pandemic and the Black Death in the 14th century.

Re-structure learning by combining synchronous activities, regular live interactions where students meet online with their classmates and teachers, with asynchronous activities, where students think deeply and engage with the subject matter alone or with other students independently of the teacher.

Employ a learning strategy of parts, purposes and complexity, Harvard University Graduate School of Education's approach that helps "make students' thinking visible through creating lists, maps and drawings of the parts, purposes and complexities of various objects and systems." This strategy provides students the ability to look beyond obvious features of an object to stimulate curiosity, identify questions for further inquiry and engage them directly in the content. If students are trying to understand a system, such as a "democracy," having them create a list or draw a picture of what they believe the parts of a democracy might be can help identity what they understand a democracy to be. Participating in a discussion about a democracy can build background knowledge and help students engage in the content.

Use technology to minimize the use of worksheets, textbooks and other paper-and-pencil activities. Practical digital tools include Flipgrid, which allows students and teachers to record short, online videos; WeVideo, an online video editor that can be linked and directly uploaded into Google Drive; Storyline, which features videos of celebrities reading popular children's books; and Mystery Science, which offers science lessons for students to work on at home.

As we demand "more rigor" in a distance learning environment, we must understand the pressures teachers will be under and help them avoid traps that include more homework, more content and more boring handouts.

While we understand the sense of urgency, and the pressures and importance of addressing the learning needs of all students, learning in a new environment takes time.

We must get this right. Students, educators and families are counting on us.

***
Tom Armelino is the executive director of the California Collaborative for Educational Excellence (CCEE). This statewide agency supports county offices of education and other local education agencies to improve student outcomes. To get more reports like this one, click here to sign up for EdSource's no-cost daily email on latest developments in education.

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COMMENTARY: 'Rigor' through distance learning calls for quality, not quantity

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Photo: Chino Valley Unified School District/Facebook As the new school year begins, districts are facing demands from parents and elected officials while also hearing calls for "more rigor" through distance learning. In making this important shift to higher standards and to meet expectations, teachers, schools and districts should understand that "more rigor" must mean higher quality distance learning, not just more complexity or quantity.

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Step-by-step ideas for building rigor and relevance for digital classrooms

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Building Digital Communities of Rigor and Relevance

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Administrators should trust students and their teachers to use real-world tools to unleash creativity and a passion for learning.

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Detailed description of steps in ASSURE Model

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According to Herlo (2013), "Instructional Design (ID) is concerned with factors that influence how well a person will be able to acquire, recall, and use new knowledge and skills" (p. 72). There are many ID Models - ADDIE, Dick & Carey, Merrill's First Principles, Gagne's Nine Events, Kirkpatrick's Four Levels, etc. - that instructional designers and faculty members can choose from to use as "frameworks to organize and structure the process of creating instructional activities" (Herlo, 2013, p. 72) so that learners can successfully complete a course or training and demonstrate knowledge and skills.

Many ID Models primarily pertain to face-to-face classroom instruction; however, instructors are using educational technology and media to teach their classes. When considering eLearning and fully online programs, it is important to follow a model that allows for the incorporation and utilization of media and technology in the curriculum. The best model for this is the ASSURE Model.

The ASSURE Model is an acronym and comprises of six components. Elements of the ADDIE Model and Gagne's Nine Events (Instructional Design Central, 2018) are evident when reviewing the ASSURE Model:

The ASSURE model can greatly aid instructional designers and faculty in the planning and delivery of online courses since it provides the best outline for classes involving technology and media. Sezer, B., Karaoglan Yilmaz, F. G., & Yilmaz, R. (2013) claim that the use of this instructional design model "can make instruction more effective, efficient, and relevant" (p. 136).

The utilization of technology and media in educational environments has changed from its introduction to the traditional classroom, and is continuously changing as education has shifted to include online learning. The ASSURE model can aid instructors and instructional designers to incorporate critical elements in lesson planning and implementation for optimum learning outcomes. To learn more about how to use the ASSURE model to design and deliver your online classes at UA Little Rock, REGISTER and join us for our next Learning Short session, Be ReASSUREd! presented by Cori Schmidtbauers, October 4th, 2019 at 11:30 am. Stop by the STaR Training Lab (Dickinson Hall Room 101) or join us online via STaR Trainings (Bb Collaborate).

For additional training and faculty development opportunities check out the STaR Training & Events Calendar.

References:
Herlo, D. (2013). Pass through examples of instructional design - I. Journal Plus Education / Educatia Plus, 9(1), 72-76.

Instructional Design Central. (2018). Instructional Design Models. Retrieved from: https://www.instructionaldesigncentral.com/instructionaldesignmodels

Sezer, B., Karaoglan Yilmaz, F. G., & Yilmaz, R. (2013). Integrating technology into classroom: The learner-centered instructional design. International Journal on New Trends in Education & Their Implications (IJONTE), 4(4), 134-144.

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Learning Shorts: Be ReASSUREd! Instructional Design for a New Age - Scholarly Technology and Resources

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According to Herlo (2013), "Instructional Design (ID) is concerned with factors that influence how well a person will be able to acquire, recall, and use new knowledge and skills" (p. 72). There are many ID Models - ADDIE, Dick & Carey, Merrill's First Principles, Gagne's Nine Events, Kirkpatrick's Four Levels, etc.

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Full instructional plan

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Discusses all steps thoroughly

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The ASSURE Model of Learning sample lesson

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Similar to my own checklist

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Although the digital divide may be closing as more districts transition to 1-1, there is a new concern over the digital use divide - "the disparity between students who use technology to create, design, build, explore, and collaborate and those who simply use technology to consume media passively." ( NETP16) Although accessing information (consumption) through technology is certainly important in some respects, it should seldom be students' primary use. They should also be curating, collaborating, and most of all, creating with the technology.

Question to Consider

In which of the following ways will students be using this technology

Consumption: Access information through some form of digital media to deepen knowledge.

Curation: Sort through content and present it in an organized and logical way.

Collaboration: Communicate and collaborate with others (students, teachers, community) for deeper learning.

Creation: Create original products to learn new concepts and provide a representation of their learning.

3. Investigate Infrastructure Requirements

Before diving into any new edtech product, it is vital to evaluate the product's technology & infrastructure requirements. This will avoid an instance where considerable time and effort is put into a pilot only to realize that implementation is impossible due a mismatch in existing infrastructure and what the tool needs to effectively function.

Questions to Consider

What steps need to happen for initial setup? Ex. Software installation on devices, class roster upload, student password creation.

What type of devices will the software work on? (Ex. iPads, Chromebooks, Laptops, All?)

Will the company provide direct support to customers?

What set-up and maintenance is required by teachers? By IT?

Can students access to this technology outside of school?

4. Take Student Data And Privacy Seriously

As we strive to personalized learning for students, we will also be using tools that collect information and data about students at unprecedented scales. We therefore have to be increasingly aware of the student data and privacy implications of our edtech decisions.

Questions to Consider
For more info, here is a great student privacy guide for educators.
5. Be Mindful of Resources, Both Time & Funding

It is no secret that schools have limited resources. And by resources, I include both funding and time. We must be strategic about where we allocate our monetary resources as well as how much time it will take educators to comfortably implement any new tool. We also need to be ready to shift resources when necessary, away from tools that provide little academic return on investment towards those that better align to the school's vision of teaching and learning.

Questions to Consider

What is the upfront and recurring monetary cost of the tool (if any)?

Is the product intuitive enough for teachers to implement right away? Or, will substantial time and resources be needed for professional development?

Is it financially feasible to scale this edtech tool across the school or district?

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5 Guiding Principles to Help Evaluate EdTech - TomDriscollEDU

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Innovative edtech products are being developed at an increasingly rapid pace, making it more challenging than ever for educators to decide which to use in their classroom. As a former high school teacher who was eager to try anything that could improve student learning, I was at times over

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Very thorough, but not user-friendly

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Free tool to help reflect

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Digital technologies for better learning and teaching: Self-reflection tool for schools (SELFIE)