State Data Privacy Agreement Library
ThinkKits processes only publicly available federal education data sourced from NCES, CRDC, SAIPE, E-Rate, and EdFacts. We do not access, store, or process protected student records. As a result, ThinkKits is exempt from most state student data privacy requirements. However, we maintain DPA readiness for every state to streamline district procurement.
1. Federal Baseline
| Law | Status | Notes |
|---|---|---|
| FERPA (20 USC §1232g) | Exempt | No education records received from schools |
| COPPA (15 USC §6501) | Exempt | Platform not directed at children under 13 |
| PPRA (20 USC §1232h) | N/A | No student surveys conducted |
2. SDPC Alignment
ThinkKits supports the Student Data Privacy Consortium (SDPC) National Data Privacy Agreement framework. We can execute the SDPC National DPA as a baseline for any state. Our standard DPA includes scope limitations documenting our public-data-only model.
3. California
California
AB 1584 / SOPIPA (Student Online Personal Information Protection Act) — Education Code §49073.1; Business & Professions Code §22584
Key Requirements
- Operators must not use student data for targeted advertising
- Must delete data upon request from school/district
- Must implement and maintain reasonable security practices
- Annual security audit and breach notification
Our Compliance Posture
ThinkKits does not qualify as an "operator" under SOPIPA because we do not operate a website or service designed and marketed for K-12 purposes that collects student information. Our platform serves adult professionals and processes only publicly available federal data. However, we can execute an AB 1584-compliant contract addendum with explicit scope limitations.
4. Texas
Texas
HB 18 — Securing Children Online through Parental Empowerment (SCOPE) Act + Student Data Privacy Act — Texas Business & Commerce Code Chapter 509; Texas Education Code §32.151
Key Requirements
- Operators must not collect, use, or share student PII beyond educational purpose
- Districts must have DPA before sharing student data
- Breach notification within 60 days
- Annual compliance audit option for districts
Our Compliance Posture
ThinkKits does not receive student PII from Texas districts. Our data sources are entirely federal (NCES CCD, CRDC, SAIPE). We do not fall under the definition of "operator" in TEX Code §32.151. We can execute a TEA-compatible DPA addendum for Texas district procurement.
5. New York
New York
Education Law 2-d — Student Data Privacy and Security — NY Education Law §2-d; 8 NYCRR Part 121
Key Requirements
- Third-party contractors must have DPA before receiving student data
- Parents' Bill of Rights for Data Privacy and Security (must be published)
- NIST Cybersecurity Framework alignment required
- Annual breach notification and training requirements
- Data must stay within contractor's control; no unauthorized sub-processing
Our Compliance Posture
ThinkKits is not a "third-party contractor" under Ed Law 2-d because we do not receive student PII from educational agencies. Despite exemption, our security practices align with the NIST CSF (Identify, Protect, Detect, Respond, Recover). We can provide a supplemental Parents' Bill of Rights disclosure and execute a 2-d compliant DPA.
6. Florida
Florida
FLDOE Student Privacy Guidelines — Florida Statute §1002.22; Florida Admin Code 6A-1.0014
Key Requirements
- Education records must be maintained in a confidential manner
- Access limited to authorized individuals
- Annual notification to parents about data practices
- School-level data governance
Our Compliance Posture
ThinkKits does not access Florida education records. Our platform uses publicly available NCES and federal data. We are not subject to §1002.22 requirements. We can provide a Florida-specific DPA addendum upon request.
7. Illinois
Illinois
SOPPA (Student Online Personal Protection Act) — 105 ILCS 85/
Key Requirements
- Operators must not sell, lease, or trade student data
- Data must be deleted within 60 days of end of contract
- Annual data governance plan required
- Written consent before collecting biometric data
- Breach notification within the most expedient time possible
Our Compliance Posture
ThinkKits does not qualify as an "operator" under SOPPA because we do not operate a website, online service, or app that is (a) used primarily for K-12 purposes, (b) designed and marketed for K-12 purposes, or (c) used at the direction of a K-12 school or teacher with student data. Our platform serves adult administrators and vendors.
8. Pennsylvania
Pennsylvania
Act 88 — Student Data Privacy — 24 P.S. §4604
Key Requirements
- Operators must protect student data from unauthorized access
- No targeted advertising based on student data
- Breach notification within the most expedient time
- Annual review of DPAs by school entity
Our Compliance Posture
ThinkKits is headquartered in Pennsylvania (Colmar, PA). We do not qualify as an operator under Act 88 because we do not collect student data. We are registered as a Pennsylvania vendor and can execute an Act 88-compliant DPA addendum.
9. Ohio
Ohio
Student Data Privacy (HB 49) — Ohio Revised Code §3319.321
Key Requirements
- Written consent required before sharing directory information with third parties
- Data governance policies required for each district
- Annual notification to parents
- Restrictions on commercial use of student data
Our Compliance Posture
ThinkKits does not receive directory information or any student data from Ohio districts. Our data comes from public federal sources. We can execute an Ohio-specific DPA addendum.
10. Georgia
Georgia
Student Data Privacy, Accessibility, and Transparency Act — O.C.G.A. §20-2-324.4
Key Requirements
- Operators must maintain reasonable security standards
- No secondary use of student data
- Data deletion upon contract termination
- Transparency about data collection practices
Our Compliance Posture
ThinkKits does not collect student data from Georgia schools. Our platform uses publicly available federal data. We meet Georgia's transparency requirements through our public documentation (security overview, state compliance, methodology whitepaper).
11. Michigan
Michigan
Student Data Privacy Act — MCL §380.1136
Key Requirements
- Operators may not use student data for commercial purposes
- Data must be deleted upon contract expiration
- Breach notification within 45 days
- Public transparency about data practices
Our Compliance Posture
ThinkKits does not receive student data from Michigan schools. Our platform processes publicly available federal datasets. We can execute a Michigan-compliant DPA.
12. North Carolina
North Carolina
Student Privacy Guidelines (Identity Theft Protection Act supplement) — N.C.G.S. §115C-401.1; §75-65
Key Requirements
- Reasonable measures to protect student information
- Breach notification within 60 days
- No sale of student data
- Data governance at district level
Our Compliance Posture
ThinkKits does not collect or process student information from North Carolina schools. All data is sourced from publicly available federal datasets. We can provide a North Carolina-specific DPA addendum.
13. How to Request a DPA
Request a DPA
Email legal@thinkkits.com with your state and district name.
We'll return a pre-drafted DPA within 2 business days.
Custom addenda available for any state not listed above.
Bulk DPA execution for multi-state organizations available.
14. Contact
Compliance & Security Inquiries
legal@thinkkits.com for DPA and legal requests
security@thinkkits.com for security questions
Phone: (267) 936-0332