This statement explains how Anni Planner handles student education records under the Family Educational Rights and Privacy Act (FERPA, 20 U.S.C. § 1232g), the Children's Online Privacy Protection Act (COPPA, 16 CFR Part 312), and Arizona's student data privacy law (A.R.S. § 15-1046). It is written for teachers, principals, and district technology staff evaluating Anni.
What Anni is, in data terms
Anni is a classroom planner an individual teacher uses to do work the school directs: lesson planning, class lists, classroom checklists and logs, substitute plans, and teacher-controlled student game portals. The student information inside it (names, classroom records, game scores) is created and controlled by the teacher or school, never collected from children, and used by us for exactly one purpose: operating the planner. Anni is designed and marketed for school purposes and we operate it as an "operator" under A.R.S. § 15-1046.
FERPA posture
FERPA obligations sit with schools and districts; vendors meet them by acting as a "school official" with a legitimate educational interest under 34 CFR § 99.31(a)(1). Anni fits that exception's conditions and will sign a Data Privacy Agreement saying so with any school or district:
- Performs an institutional service the school would otherwise use its own employees for (classroom planning and recordkeeping).
- Under the school's direct control with respect to education records: the teacher and school decide what goes in, who it is shared with, and when it is deleted; our systems act only on those instructions.
- Use limited to the purpose of the disclosure: we use education records only to provide the service, never for any other purpose, and redisclose them to no one except the contracted service providers that host and deliver the service, each bound to the same limits.
- Destruction: records are deleted on the school's request, on the teacher's own deletion, and on account deletion, per the retention schedule in the Privacy Policy.
School-official status attaches through a signed Data Privacy Agreement or the district's own designation of Anni under its vendor process. A teacher using Anni without one should obtain their school's approval; at signup every teacher confirms they use Anni at their school's direction and under its policies, and we hold the records to the identical standard either way: the teacher's directions, and the school's policies, control. We encourage every teacher to put Anni through their district's software-approval process, and we cooperate with any district's review.
COPPA posture (students under 13)
Children interact with Anni only in the student game portals. Consistent with the Federal Trade Commission's guidance on education technology, we rely on school authorization in place of individual parental consent, which is available only because all of the following are true: the portals are used solely for educational purposes at the teacher's direction; the teacher, not the child, creates the account (a first name only); the games collect no contact information from children and contain no free-text fields inviting personal information; children's information is used only to provide the classroom service, is never used for advertising, is never sold, and is never used to train AI models; and the school or teacher controls the information, including its deletion, at all times. Our written children's data retention policy appears in section 5 of the Privacy Policy: student information is kept only while the teacher keeps it, never indefinitely. Parents can review what the classroom keeps through the teacher or school, which controls it.
Arizona student data privacy (A.R.S. § 15-1046)
As an operator we commit, in the statute's own structure, that we do not and will not: use covered information or persistent identifiers for targeted advertising (A)(1); amass a student profile except for school purposes (A)(2); sell or rent student information (A)(3); or disclose covered information outside the statute's permitted purposes (A)(4), with third-party service providers bound by contract to use limits, non-disclosure, and reasonable security as (A)(4)(f) requires. We maintain reasonable security procedures appropriate to the information (C)(1), delete a student's covered information from live systems within ten (10) business days of a public school's request, with written confirmation (C)(2), and give prominent notice before material privacy policy changes (C)(3). De-identified and aggregate information is used only as section (E) permits. We understand violations are enforceable by the Arizona Attorney General as consumer fraud (G), and we built the service so the question never comes up.
Breach notice to schools
If a security breach involves student information, we notify the affected teacher and school with what was involved, in parallel with the individual notices Arizona's breach law (A.R.S. § 18-552) requires, within its 45-day limit.
Questions and district review
We answer FERPA, COPPA, and state-law questions from any school or district, provide the signed DPA on request, and will complete a district's vendor privacy review. Contact: Jon Hegreness, privacy@anniplanner.com.