Building a strong, connected community where young learners can feel free to explore their passions has always been a part of Outschool’s mission. Many educators who choose to teach on Outschool share our commitment to support learners and families as they navigate the world of online learning. Your support is critical to improving our overall privacy practices.
Starting in early January, 2022, Outschool’s class approval process will change to further ensure that teachers only use legally compliant external tools with their learners who are younger than 13 years old, as required under COPPA. We’re announcing this policy update now so that you have time to understand these changes and make any necessary adjustments to your class resources before the new year.
Beginning in mid-December, all new classes will follow an updated class submission process that includes selecting which approved third-party tools you will use in your lessons. In the interim, educators may update their existing class listings themselves (without resubmission). See the “How will I know what tools I can use?” section of this article for more details.
Why are we updating our class submission process?
We know this may be shocking, frustrating, or confusing for any educators who have relied on use of specific third-party teaching tools. We’re here to support you as you navigate this new policy, and we want to be as transparent as possible about how and why we’re updating our policy and processes.
First, let’s define third-party teaching tools. A third-party (or external) tool is any website or learning management system requiring that learners leave the Outschool platform to use that tool. A few common examples include: Google classroom, YouTube, and Nearpod. Some of these tools may be appropriate to use with learners under 13, but some may not be.
As we work to improve our platform for learners, families, and educators, we need to balance creating an exceptional learning environment with essential legal compliance. You may visit this website to learn more about COPPA, or see our FAQs at the bottom of this article. In short, COPPA was enacted by the FTC in the United States to help parents control the information collected online from their children under the age of 13.
What does this mean then, when you want to send your learners under the age of 13 to another website to complete an activity or view a resource? That depends on which website or learning management system tool you want to use. Some websites, like Minecraft, are COPPA-compliant and learners under 13 may use them freely, without parental oversight. Other websites, like Padlet, require parental review of privacy practices and consent prior to a learner under 13 using that website. Additionally, certain websites, like Facebook (Meta), expressly forbid learners under 13 from ever using them.
Because of these nuances, we’re improving our processes to ensure that you have continued access to a wide breadth of teaching materials you can use with your younger learners, as well as the ability to more proactively inform parents about what sites their learners may access while on Outschool.
How will I know what tools I can use?
For new classes
Beginning in mid-December, the class submission process will include a new option to select which age-appropriate and legally compliant external resources will be used in your lessons. We’ll be publishing a step-by-step guide on how to choose approved resources, add them to your class listing, and notify parents that their learners will be visiting an external website/platform during class when this feature launches in December.
For existing classes or classes approved before mid-December
Adding an approved tool to an existing class listing is considered a minor change and won’t require re-approval for your class. We do recommend that you begin updating your class descriptions now to include which approved teaching tools you’ll be using. This will help you be prepared to meet new policy guidelines when they go into effect in early January. To check whether you need to make any changes to your tools or class description, visit this list of approved and unapproved 3rd-party teaching tools.
To provide additional support, we’ll be publishing a new course in our Educator Training Center on the nuts and bolts of selecting appropriate third-party resources in December. Upcoming educator newsletters will include continued updates on this policy as we approach the new year.
What should I do now?
Even though this policy doesn’t go into effect until early January, 2022, we recommend updating your external tools and class descriptions following the guidelines above as soon as possible. You’ll find a list of approved/unapproved resources here, and we encourage you to remove any links to unapproved resources from your current classes for learners under 13.
We understand that this policy update may require you to spend extra time adjusting your curriculum, and we want to support you as you make those changes. Below you’ll find answers to some FAQs about this policy, and we’ll be updating these FAQs as we receive more questions from our educator community. As always, you can reach out to firstname.lastname@example.org with any questions along the way.
Thank you for joining us as we stand with our families to protect children’s privacy online. Your dedication to teaching, guiding, and inspiring learners around the world never goes unnoticed, and we’re here to support you in whatever way we can as you create curriculum that keeps kids safe.
What is COPPA?
COPPA is the Children’s Online Privacy Protection Act. It was passed by Congress in 1998, and requires the Federal Trade Commission to issue and enforce regulations concerning the online privacy of children under 13. The primary goal of COPPA is to place parents in control of what information is collected from their children online, through a variety of mechanisms including but not limited to telling parents what their data collection practices are and collecting verifiable parental consent prior to collecting data from children under 13. For more information about COPPA, please go here.
Why does COPPA apply to Outschool?
COPPA applies to Outschool because Outschool provides an online educational experience for learners under 13, through which Outschool collects personal information from those learners (for example, through our learners’ comments on classroom pages or talking in our recorded videos of classes). See our privacy statement for more information on our practices and what we tell parents of children under 13.
What are some ways in which Outschool complies with COPPA?
There are many ways in which we comply with COPPA, including but not limited to: providing parents with proper notice of our privacy statement and obtaining their verified consent prior to enrolling their under 13-year-olds in our classes; being transparent in our privacy statement about how we collect their learner’s data and what we do with it; separately updating parents with proper notice any time we make a material change to our privacy statement; requiring that our learners under 13 use our “learner space” rather than parent space so as to avoid improper data collection or usage; giving parents access to any data their learners share and the ability to request that we delete such data.
Why does COPPA apply to the external tools I use in class, and how so?
COPPA applies to operators of commercial websites and online services (including mobile apps and IoT devices, such as smart toys) directed to children under 13 that collect, use, or disclose personal information from children, or on whose behalf such information is collected or maintained (such as when personal information is collected by an ad network to serve targeted advertising). The Rule also applies to operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13, and to websites or online services that have actual knowledge that they are collecting personal information directly from users of another website or online service directed to children.
There are websites that are never meant to be used by children under 13 for many reasons, ranging from how they collect data to what they do with such data; these websites’ terms of services and privacy statements either clearly state that they are not meant for children under 13, or are silent altogether. For safety and legal reasons, Outschool educators should not send their learners under 13 to those websites.
Can a teacher create a “kit” for parents to buy or would that violate COPPA?
Yes, kits are still permitted. COPPA does not apply to teachers’ interactions with parents on the Outschool site nor to any personal data that parents share on Outschool. If you require a kit to run your class, you must include the price and the list of materials included in your class listing; alternatively, you may privately message parents with links to your website for kit purchase, provided that you only direct parents to your external website for that sole purpose, and not to collect their personal data for any other reason.
Does COPPA apply to the teacher resources I use to prepare for class (like Teachers Pay Teachers) or share out with my learners?
No. COPPA does not apply to the resources you use to prepare for class or share out with your learners as long as you’re not sending them to an external website or learning management system. That means that you can upload a PDF of a document, or an embedded YouTube video (which does not allow a learner to access the YouTube website), to your classroom or Group. In contrast, if you wanted to use a learning management system (such as Google docs), through which learners would need to create an account in order to access a document, that tool would need to be COPPA compliant if your learners are under 13.
Kids under 13 aren’t supposed to use YouTube, yet you allow me to upload YouTube videos into my classroom page – how is that okay under COPPA?
It’s ok under COPPA because our embedding of YouTube videos on our platform has stripped the ability of a learner to access the YouTube website from the video itself, nor allowed YouTube to collect any data about the learner.
I found a website that doesn’t appear on your “approved resources” list, but it looks like it’s okay for me to use with my under 13-year-old learners. Can I?
Note: If you decide to use an external tool after class begins, and your learners are under 13, you may only add an approved Outschool tool to the class as reflected in the product under the class submission page. Adding an approved tool after your class has been listed is considered a minor change and does not require resubmission of your class to the approvals team.
Do I have to unlist my class and resubmit it for approval if I change a non-COPPA compliant link to a COPPA compliant one?
No! If you are replacing non-COPPA compliant links with links that are approved by Outschool, this is considered a minor change and does not require resubmission of your class to the approvals team.
I have a class that has a mix of ages (11-14 year olds). What if I want to use a tool that’s okay for over 13-year-old learners, but not under 13-year-olds?
Unfortunately, if a class is mixed in age with learners over and under 13, you must only use approved tools for learners under 13.
What happens if I think a tool is okay to use with kids under 13, but it’s not?
When you submit your class listing, please add the website or learning management system that you’d like to use. If Outschool deems that the tool is inappropriate for learners under 13, we will work with you to find another adequate alternative. We do strongly encourage you to review the list of approved third-party external resources and utilize those resources from the approved list so as to not delay the listing of your class.
Do I have to go back and delete non-COPPA compliant links that were posted in my classroom? If so, how far back do I have to go?
For your ongoing classes, we do encourage you to go back in time where possible and remove impermissible links that you believe learners may still be accessing.
What happens if a learner in my class for learners under 13 posts a link to something that isn’t COPPA compliant?
You can either remove the link by deleting the learner’s post, or email email@example.com, and we’ll remove the link for you (and reach out to the learner’s parents regarding our safety policies).