Student Data Privacy And School Dsitrict Data Handling
1. Scope and Role
STUDENT DATA PRIVACY AND SCHOOL DISTRICT DATA HANDLING
1. Scope and Role
When Thynk, Inc. provides services to a school district, local education agency, or educational institution, Thynk acts as a School Official with a legitimate educational interest as defined under the Family Educational Rights and Privacy Act (FERPA).
In this context:
- The school district owns all Student Data.
- Thynk processes Student Data solely on behalf of and under the direction of the school district.
- Thynk does not own Student Data.
Student Data is used only to provide and improve the contracted educational services and for no other commercial purpose.
2. Definition of Student Data
Student Data includes personally identifiable information and education records provided by or through a school district, including but not limited to:
- Student name
- Student identifiers
- Demographic information
- Enrollment information
- Performance data within the Thynk platform
- Assessment and usage data
- Student generated content
Student Data does not include properly de-identified or anonymized data that cannot reasonably identify an individual student.
3. Permitted Uses of Student Data
Thynk uses Student Data only for the following purposes:
- Delivering and maintaining the educational services contracted by the school district
- Supporting authorized school personnel
- Maintaining system security and integrity
- Improving educational functionality through de-identified analytics
Thynk does not:
- Sell Student Data
- Rent Student Data
- Use Student Data for targeted advertising
- Build commercial profiles of students
- Use Student Data for unrelated marketing purposes
4. De-Identified Data
Thynk may use de-identified data for:
- Product improvement
- Research and development
- Demonstrating service effectiveness
- Adaptive learning functionality
Thynk does not attempt to re-identify de-identified data.
De-identified data is maintained in a manner consistent with applicable federal and state laws.
5. Data Security
Thynk maintains administrative, physical, and technical safeguards designed to protect Student Data from unauthorized access, disclosure, alteration, or destruction.
These safeguards include:
- Encryption in transit using TLS
- Encryption at rest within AWS infrastructure
- Role-based access controls
- Multi-factor authentication for privileged access
- Continuous vulnerability monitoring
- Secure development practices
- Restricted employee access on a least privilege basis
Thynk maintains a written incident response plan consistent with industry standards.
6. Data Storage Location
Student Data is stored within secure cloud infrastructure environments operated by Amazon Web Services.
Upon request, Thynk will provide school districts with information regarding the geographic storage location of Student Data.
7. Subprocessors
Thynk may engage trusted subprocessors to assist in providing services, such as cloud hosting or analytics providers.
All subprocessors are contractually obligated to:
- Protect Student Data
- Use Student Data only for authorized purposes
- Implement appropriate security safeguards
- Comply with applicable privacy laws
A current list of subprocessors is available upon request.
8. Parent and Student Rights
Parents and eligible students may request access to or correction of education records through their school district.
If Thynk receives a request directly from a parent or student regarding Student Data, Thynk will refer the request to the relevant school district.
Thynk will cooperate with school districts in responding to lawful access, correction, or deletion requests.
9. Data Retention and Deletion
Thynk retains Student Data only for as long as necessary to fulfill contractual obligations to the school district or as required by law.
Upon termination of a school district contract:
- Student Data will be returned or securely deleted within the time period specified in the applicable Data Privacy Agreement.
- De-identified data may be retained consistent with contractual and legal requirements.
10. Data Breach Notification
In the event of an unauthorized release, disclosure, or acquisition of Student Data that compromises its security, confidentiality, or integrity, Thynk will:
- Notify the affected school district without unreasonable delay and consistent with contractual requirements
- Provide relevant details regarding the nature of the incident
- Cooperate in remediation and investigation efforts
Thynk complies with all applicable federal and state data breach notification laws.
11. Direct Student Contact
Thynk employees do not have direct contact with students in the normal delivery of services.
If direct student contact becomes necessary under a specific contract, Thynk will ensure that any applicable background screening requirements required by law or contract are satisfied prior to such contact.
12. No Monitoring of Student Devices
Thynk does not access or monitor:
- Location tracking features of school-issued devices
- Audio or visual recording features of school-issued devices
- Keystroke logging or general web browsing activity outside the Thynk platform
13. Contact Information
Questions regarding Student Data privacy may be directed to:
Privacy Contact
Thynk, Inc.
9100 Conroy Windermere Road, Suite 200
Windermere, Florida 34786
Email: linda@thynk.com
STUDENT DATA PRIVACY AND SCHOOL DISTRICT DATA HANDLING
1. Scope and Role
When Thynk, Inc. provides services to a school district, local education agency, or educational institution, Thynk acts as a School Official with a legitimate educational interest as defined under the Family Educational Rights and Privacy Act (FERPA).
In this context:
- The school district owns all Student Data.
- Thynk processes Student Data solely on behalf of and under the direction of the school district.
- Thynk does not own Student Data.
Student Data is used only to provide and improve the contracted educational services and for no other commercial purpose.
2. Definition of Student Data
Student Data includes personally identifiable information and education records provided by or through a school district, including but not limited to:
- Student name
- Student identifiers
- Demographic information
- Enrollment information
- Performance data within the Thynk platform
- Assessment and usage data
- Student generated content
Student Data does not include properly de-identified or anonymized data that cannot reasonably identify an individual student.
3. Permitted Uses of Student Data
Thynk uses Student Data only for the following purposes:
- Delivering and maintaining the educational services contracted by the school district
- Supporting authorized school personnel
- Maintaining system security and integrity
- Improving educational functionality through de-identified analytics
Thynk does not:
- Sell Student Data
- Rent Student Data
- Use Student Data for targeted advertising
- Build commercial profiles of students
- Use Student Data for unrelated marketing purposes
4. De-Identified Data
Thynk may use de-identified data for:
- Product improvement
- Research and development
- Demonstrating service effectiveness
- Adaptive learning functionality
Thynk does not attempt to re-identify de-identified data.
De-identified data is maintained in a manner consistent with applicable federal and state laws.
5. Data Security
Thynk maintains administrative, physical, and technical safeguards designed to protect Student Data from unauthorized access, disclosure, alteration, or destruction.
These safeguards include:
- Encryption in transit using TLS
- Encryption at rest within AWS infrastructure
- Role-based access controls
- Multi-factor authentication for privileged access
- Continuous vulnerability monitoring
- Secure development practices
- Restricted employee access on a least privilege basis
Thynk maintains a written incident response plan consistent with industry standards.
6. Data Storage Location
Student Data is stored within secure cloud infrastructure environments operated by Amazon Web Services.
Upon request, Thynk will provide school districts with information regarding the geographic storage location of Student Data.
7. Subprocessors
Thynk may engage trusted subprocessors to assist in providing services, such as cloud hosting or analytics providers.
All subprocessors are contractually obligated to:
- Protect Student Data
- Use Student Data only for authorized purposes
- Implement appropriate security safeguards
- Comply with applicable privacy laws
A current list of subprocessors is available upon request.
8. Parent and Student Rights
Parents and eligible students may request access to or correction of education records through their school district.
If Thynk receives a request directly from a parent or student regarding Student Data, Thynk will refer the request to the relevant school district.
Thynk will cooperate with school districts in responding to lawful access, correction, or deletion requests.
9. Data Retention and Deletion
Thynk retains Student Data only for as long as necessary to fulfill contractual obligations to the school district or as required by law.
Upon termination of a school district contract:
- Student Data will be returned or securely deleted within the time period specified in the applicable Data Privacy Agreement.
- De-identified data may be retained consistent with contractual and legal requirements.
10. Data Breach Notification
In the event of an unauthorized release, disclosure, or acquisition of Student Data that compromises its security, confidentiality, or integrity, Thynk will:
- Notify the affected school district without unreasonable delay and consistent with contractual requirements
- Provide relevant details regarding the nature of the incident
- Cooperate in remediation and investigation efforts
Thynk complies with all applicable federal and state data breach notification laws.
11. Direct Student Contact
Thynk employees do not have direct contact with students in the normal delivery of services.
If direct student contact becomes necessary under a specific contract, Thynk will ensure that any applicable background screening requirements required by law or contract are satisfied prior to such contact.
12. No Monitoring of Student Devices
Thynk does not access or monitor:
- Location tracking features of school-issued devices
- Audio or visual recording features of school-issued devices
- Keystroke logging or general web browsing activity outside the Thynk platform
13. Contact Information
Questions regarding Student Data privacy may be directed to:
Privacy Contact
Thynk, Inc.
9100 Conroy Windermere Road, Suite 200
Windermere, Florida 34786
Email: linda@thynk.com
When Thynk, Inc. provides services to a school district, local education agency, or educational institution, Thynk acts as a School Official with a legitimate educational interest as defined under the Family Educational Rights and Privacy Act.
In this context:
• The school district owns all Student Data. • Thynk processes Student Data solely on behalf of and under the direction of the school district. • Thynk does not own Student Data.
Student Data is used only to provide and improve the contracted educational services and for no other commercial purpose.
2. Definition of Student Data
Student Data includes personally identifiable information and education records provided by or through a school district, including but not limited to:
• Student name • Student identifiers • Demographic information • Enrollment information • Performance data within the Thynk platform • Assessment and usage data • Student generated content
Student Data does not include properly de identified or anonymized data that cannot reasonably identify an individual student.
3. Permitted Uses of Student Data
Thynk uses Student Data only for the following purposes:
• Delivering and maintaining the educational services contracted by the school district • Supporting authorized school personnel • Maintaining system security and integrity • Improving educational functionality through de identified analytics
Thynk does not:
• Sell Student Data • Rent Student Data • Use Student Data for targeted advertising • Build commercial profiles of students • Use Student Data for unrelated marketing purposes
4. De Identified Data
Thynk may use de identified data for:
• Product improvement • Research and development • Demonstrating service effectiveness • Adaptive learning functionality
Thynk does not attempt to re identify de identified data.
De identified data is maintained in a manner consistent with applicable federal and state laws.
5. Data Security
Thynk maintains administrative, physical, and technical safeguards designed to protect Student Data from unauthorized access, disclosure, alteration, or destruction.
These safeguards include:
• Encryption in transit using TLS • Encryption at rest within AWS infrastructure • Role based access controls • Multi factor authentication for privileged access • Continuous vulnerability monitoring • Secure development practices • Restricted employee access on a least privilege basis
Thynk maintains a written incident response plan consistent with industry standards.
6. Data Storage Location
Student Data is stored within secure cloud infrastructure environments operated by Amazon Web Services.
Upon request, Thynk will provide school districts with information regarding the geographic storage location of Student Data.
7. Subprocessors
Thynk may engage trusted subprocessors to assist in providing services, such as cloud hosting or analytics providers.
All subprocessors are contractually obligated to:
• Protect Student Data • Use Student Data only for authorized purposes • Implement appropriate security safeguards • Comply with applicable privacy laws
A current list of subprocessors is available upon request.
8. Parent and Student Rights
Parents and eligible students may request access to or correction of education records through their school district.
If Thynk receives a request directly from a parent or student regarding Student Data, Thynk will refer the request to the relevant school district.
Thynk will cooperate with school districts in responding to lawful access, correction, or deletion requests.
9. Data Retention and Deletion
Thynk retains Student Data only for as long as necessary to fulfill contractual obligations to the school district or as required by law.
Upon termination of a school district contract:
• Student Data will be returned or securely deleted within the time period specified in the applicable Data Privacy Agreement. • De identified data may be retained consistent with contractual and legal requirements.
10. Data Breach Notification
In the event of an unauthorized release, disclosure, or acquisition of Student Data that compromises its security, confidentiality, or integrity, Thynk will:
• Notify the affected school district without unreasonable delay and consistent with contractual requirements • Provide relevant details regarding the nature of the incident • Cooperate in remediation and investigation efforts
Thynk complies with all applicable federal and state data breach notification laws.
11. Direct Student Contact
Thynk employees do not have direct contact with students in the normal delivery of services.
If direct student contact becomes necessary under a specific contract, Thynk will ensure that any applicable background screening requirements required by law or contract are satisfied prior to such contact.
12. No Monitoring of Student Devices
Thynk does not access or monitor:
• Location tracking features of school issued devices • Audio or visual recording features of school issued devices • Keystroke logging or general web browsing activity outside the Thynk platform
13. Contact Information
Questions regarding Student Data privacy may be directed to:
Privacy Contact Thynk, Inc. 9100 Conroy Windermere Road, Suite 200 Windermere, Florida 34786 Email: linda@thynk.com