FERPA Statement

This statement describes how we handle information from students and student-athletes when the Conflict Literacy Index is administered through a school or athletic department subject to the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. §1232g and 34 CFR Part 99.

1. School official designation

When a school or athletic department ("Institution") uses the Service to administer assessments to its students or student-athletes, JenFryTalks LLC acts as a "school official" with a "legitimate educational interest" in student information under 34 CFR §99.31(a)(1)(i)(B). We perform a service the Institution would otherwise use its own employees to perform, and we are under the direct control of the Institution with respect to the use and maintenance of education records.

2. Use of student information

We use student information only to provide the Service to the Institution — delivering the assessment, generating individual and team results, and providing benchmarks. We do not use student information for advertising or for any purpose outside the scope of the Institution's engagement.

3. No redisclosure

We will not redisclose personally identifiable information from education records to any third party except: (a) as directed in writing by the Institution; (b) to our subprocessors bound by equivalent restrictions; or (c) as required by law.

4. Parent and eligible-student rights

Under FERPA, parents (or students 18 and over, "eligible students") have the right to inspect and review education records, request corrections, and consent to certain disclosures. These rights are administered by the Institution. On the Institution's request, we will provide the records we hold about a student.

5. Retention and deletion

We retain student information for the duration of the Institution's engagement. On the Institution's written request, or at the end of the engagement, we will delete or return student information within a reasonable time.

6. Data security

See our Security Overview for the technical and organizational measures we apply. We treat student information as sensitive data.

7. Requests and coordination

Institutions and parents can direct FERPA-related requests to info@jenfrytalks.com. We will coordinate with the Institution to respond appropriately.

8. Not a substitute for the Institution's obligations

This statement describes our practices. The Institution remains responsible for its own FERPA obligations, including providing annual notice of rights and maintaining any required consents.