Student Data and FERPA Policy

1. Purpose

Student Digital Wallet is committed to protecting student information and supporting educational organizations in meeting their responsibilities concerning student privacy.

This policy describes how Student Digital Wallet handles student information when acting as an education technology vendor and service provider.

2. Vendor Role

Student Digital Wallet provides technology services to educational organizations.

When an educational organization provides education records to Student Digital Wallet, Student Digital Wallet processes those records for authorized educational purposes.

Educational organizations may use outside providers for institutional services when applicable privacy requirements are satisfied. These requirements may include performing an institutional function, remaining under the direct control of the educational organization regarding use and maintenance of education records, limiting use and redisclosure, and meeting applicable legitimate educational interest requirements.

3. School Control

The educational organization remains responsible for determining:

• What student information is provided
• Why the information is provided
• Which users are authorized
• Which credentials may be issued
• Which documents may be uploaded
• Who may access student information
• When information should be retained or deleted

Student Digital Wallet will process student information according to authorized instructions and applicable agreements.

4. Permitted Uses

Student Digital Wallet may use student information to:

• Provide the contracted platform
• Store educational records
• Issue credentials
• Verify credentials
• Share credentials when authorized
• Maintain security
• Provide technical support
• Prevent unauthorized access
• Maintain system functionality
• Comply with legal obligations

Student Digital Wallet will not use education records for unrelated advertising or unrelated commercial purposes.

5. Redisclosure

Student Digital Wallet will not intentionally redisclose personally identifiable information from education records except as authorized by the educational organization, required to provide the contracted service, required by law, or otherwise permitted under applicable law.

6. Access Controls

Student Digital Wallet uses account roles and access controls designed to limit access to authorized users.

• Student accounts
• School administrator accounts
• Organization access
• System administrator access
• Document ownership
• Authentication
• Credential verification controls

Educational organizations should maintain reasonable internal procedures ensuring that users receive access only to records for which they have a legitimate educational interest.

7. Student Access

When an educational organization is the organization responsible for student education records, requests concerning those records should generally be submitted to the educational organization.

Student Digital Wallet will cooperate with the organization in responding to lawful requests.

8. Correction of Records

Educational organizations are responsible for correcting inaccurate student records.

When an organization requests a correction, Student Digital Wallet will use reasonable technical procedures to update the applicable record.

9. Data Minimization

Student Digital Wallet seeks to collect and maintain information reasonably necessary to provide the platform.

Educational organizations should avoid uploading information that is unnecessary for the service.

10. Security

Student Digital Wallet uses reasonable technical and organizational safeguards designed to protect student information.

• Authentication
• Role based authorization
• Organization based access
• Document ownership
• Cloud security controls
• Restricted storage access
• Security monitoring
• Administrative controls

11. Security Incidents

Student Digital Wallet maintains procedures for detecting, investigating, containing, and responding to security incidents.

When an incident involves student information and notification is required by applicable law or contract, Student Digital Wallet will notify the applicable organization within the required period.

12. Service Providers

Student Digital Wallet may use technology providers to provide hosting, authentication, storage, communications, security, monitoring, or related infrastructure.

Student Digital Wallet will require applicable service providers to handle information according to authorized purposes.

13. COPPA

Student Digital Wallet may be used by children under 13 in educational settings.

When COPPA applies, Student Digital Wallet will follow applicable requirements.

Student Digital Wallet will not use school provided children's information for unrelated commercial purposes.

14. Data Retention

Student Digital Wallet will retain student information according to the applicable organization agreement, legal requirements, and the Student Digital Wallet Data Retention and Deletion Policy.

15. Data Return and Deletion

When an educational organization's service ends, Student Digital Wallet will follow the applicable agreement concerning return, export, retention, and deletion of student information.

Student Digital Wallet will cooperate with educational organizations regarding the return or deletion of student information as required by the applicable agreement and law.

16. No Sale of Student Records

Student Digital Wallet does not sell student education records.

Student information provided under an educational organization relationship will not be used for unrelated advertising or behavioral marketing.

17. Written Agreements

Student Digital Wallet recommends that educational organizations enter into a written agreement before providing student education records to the platform.

The written agreement should establish the permitted purposes, access requirements, security responsibilities, data retention requirements, and data return or deletion procedures.

18. Contact

Student Digital Wallet

support@studentdigitalwallet.com

studentdigitalwallet.com

[Business Address]