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School Official ExceptionClassroomOS operates under the legitimate educational interest exception to FERPA (34 CFR § 99.31(a)(1)). We access student education records solely to provide instructional support services to educators and districts.
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No Disclosure to Third PartiesStudent education records are never disclosed to third parties without explicit written district authorization. Advertising and data monetization are strictly prohibited.
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Minimum Necessary DataWe collect only the data fields required to provide instructional recommendations. Student PII (names, IDs) is used only to track growth within a class context, never for cross-class or cross-district profiling.
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Parent and Educator Rights PreservedDistricts retain full ownership of their data. Upon contract termination, all district data is exportable and deletable within 30 days upon written request.
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Data Processing AgreementClassroomOS provides a FERPA-compliant Data Processing Agreement (DPA) to all districts. Contact us to receive your district's DPA before deployment.
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Educator
Uploads CSV or enters class data
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JWT Auth
Supabase verifies identity every request
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Worker
Cloudflare edge processes signal computation
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Supabase DB
US-East. RLS enforced. Encrypted at rest.
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OpenAI GPT-4o
Receives signal summaries only. Zero PII sent.
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Educator
Receives recommendation. Data stays in district.
Critical note on AI: When ClassroomOS sends data to OpenAI for recommendation generation, it sends only signal summaries (e.g. "growth_gap, high severity, 62% below grade level") — never student names, IDs, or identifiable information. OpenAI processes this under our zero data retention agreement.
| Data Type | Purpose | Stored? | Sent to AI? | Shared? |
| Educator email + name | Authentication, account management | YES | NO | NO |
| Class/section metadata | Section organization, recommendations | YES | NO | NO |
| Assessment scores (aggregate) | Signal computation, growth tracking | YES | NO | NO |
| Student names / IDs | Growth tracking within class only | YES | NEVER | NO |
| Signal summaries | Instructional recommendation engine | YES | YES — anonymized | NO |
| Strategy evidence logs | Progress monitoring, coaching feedback | YES | NO | NO |
| IEP / 504 flags | Differentiated strategy selection | YES | NEVER | NO |
| Demographic indicators | Equity signal computation (aggregate) | YES | NEVER | NO |
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Student Data Never Trains AI ModelsClassroomOS operates under OpenAI's zero data retention policy. Data submitted via the API is not used to train OpenAI models. Student data from your district never improves any AI system outside your contract.
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Evidence-Based GroundingAll AI recommendations are anchored to a vetted evidence base from IES What Works Clearinghouse, NWEA, TNTP, Hattie's Visible Learning, and Rosenshine's Principles of Instruction. AI cannot generate recommendations unsupported by this research base.
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Educator Judgment Is FinalClassroomOS recommendations are planning considerations — never directives. The platform explicitly states this in every recommendation context. Educator professional judgment governs all instructional decisions.
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No Automated Student DecisionsClassroomOS never makes automated decisions about individual students. All outputs are addressed to educators for their consideration, not to students or families directly.
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Bias MonitoringThe evidence base explicitly includes culturally sustaining pedagogy (Hammond, 2015) and equity frameworks (Eccles expectancy-value theory, Yeager social-psychological interventions) to surface strategies that center students' identities and assets.
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JWT Authentication on Every RequestEvery API call is verified against Supabase Auth using a short-lived JWT. Tokens expire and require refresh. No request is served without a verified identity.
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Row-Level Security (RLS)Supabase RLS policies ensure that even if an API key were compromised, users can only read and write their own records. Cross-tenant data access is architecturally impossible at the database level.
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Encryption at Rest and In TransitAll data is encrypted at rest using AES-256 and in transit via TLS 1.3. Supabase infrastructure is hosted on AWS US-East with SOC 2 Type II certification.
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Cloudflare Edge SecurityAll API requests pass through Cloudflare's global edge network, providing DDoS protection, WAF rules, and rate limiting before reaching application logic.
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AI Rate LimitingAI synthesis endpoints are rate-limited to 20 calls per user per hour via Cloudflare KV. This prevents abuse and protects district data from bulk extraction attempts.
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Audit LoggingAll significant data access and modification events are written to an immutable audit log with user ID, timestamp, action type, and resource identifier. Available for district security review.
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Session TimeoutSessions automatically expire after 30 minutes of inactivity with a 2-minute warning. This is enforced client-side on every page.
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Right to ExportDistricts can export all their data at any time via the Admin dashboard. Data is provided in standard CSV/JSON formats within 5 business days of written request.
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Right to DeletionUpon contract termination, all district data is permanently deleted within 30 days. Confirmation of deletion is provided in writing.
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Right to AccessEducators can view all data ClassroomOS holds about their classes through the platform interface at any time. No hidden data stores.
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Right to CorrectionInaccurate data can be corrected or deleted by the educator at any time. Assessment data can be voided with a single action from the ingest history panel.
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Breach NotificationIn the event of a security incident affecting district data, ClassroomOS will notify the district within 72 hours of discovery, consistent with applicable state and federal notification requirements.
| Vendor | Purpose | Data Shared | Location |
| Supabase | Database, authentication, storage | All user and class data (encrypted at rest) | AWS US-East-1 |
| Cloudflare | Edge network, CDN, API gateway, DDoS protection | Request metadata only (no payload storage) | Global CDN / US edge |
| OpenAI | AI recommendation generation (GPT-4o) | Anonymized signal summaries only — zero PII, zero data retention | US (zero retention policy) |
No other sub-processors have access to district or student data. ClassroomOS does not use advertising networks, analytics platforms with data sharing, or social media SDKs.
Last updated: March 2026 · ClassroomOS v11.0.0 · Impact Solutions Group LLC
Questions?
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