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FERPA COMPLIANCE & PRIVACY POLICY 1 Purpose and Scope This document describes Edulog's standards of practice relating to disclosures to Edulog of personally identifiable information ("PII") by educational agencies and institutions ("EAs"). This document applies to all Edulog employees and technology resources including all externally hosted systems and data repositories. Edulog, in its role as

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product privacy Skip to content Solutions Athena Routing eSQL Routing GPS Tracking Parent Portal Ride Registration Tablets and MDTs Student Ridership Advisory Services Service Level Management Web Solutions About Leadership News and Press Blog Events Virtual Learning Academy Trade Shows Conferences Zoom Meetings Contact Help for Parents – Edulog Parent Portal Apps Sales Support Careers Edulog Security Compliance EdulogU ParentsParents Product Privacy FERPA COMPLIANCE & PRIVACY POLICY 1 Purpose and Scope This document describes Edulog’s standards of practice relating to disclosures to Edulog of personally identifiable information (“PII”) by educational agencies and institutions (“EAs”). This document applies to all Edulog employees and technology resources including all externally hosted systems and data repositories. Edulog, in its role as a vendor to educational agencies and institutions (EAs), receives disclosures from the EAs of personally identifiable information (PII) contained in student records. Only information that is needed for Edulog to perform services outsourced to it by the EA is disclosed to Edulog. These disclosures are authorized under the Family Educational Rights and Privacy Act (FERPA), a federal statute that regulates the privacy of student records by EAs that receive financial assistance from the U.S. Department of Education. Edulog, as a contractor to the EA, receives the disclosures on the same basis as school officials employed by the EA, consistent with FERPA regulations, 34 CFR §99.31(a)(1)(i)(B). Consistent with those regulations, Edulog has a legitimate educational interest in the information to which it is given access because the information is needed to perform the outsourced service, and Edulog is under the direct control of the EA in using and maintaining the disclosed education records, consistent with the terms of its contract. 2 Appropriate Use Edulog is subject to the same conditions on use and redisclosure of education records that govern all school officials, as provided in 34 CFR §99.33. In particular, Edulog must ensure that only individuals that it employs or that are employed by its contractor, with legitimate educational interests – consistent with the purposes for which Edulog obtained the information -- obtain access to PII from education records it maintains on behalf of the district or institution. Further, in accordance with 34 CFR §99.33(a) and (b), Edulog may not redisclose PII without consent of a parent or an eligible student (meaning a student who is 18 years old or above or is enrolled in postsecondary education) unless the agency or institution has authorized the redisclosure under a FERPA exception and the agency or institution records the subsequent disclosure. An example of such a disclosure is when Edulog is requested by a school district to assist the district in the transfer of the student records from our system to another system. Edulog shall use education records only for the purposes of fulfilling its duties contracted by the educational institution. Edulog will not sell or otherwise use or redisclose education records for behavioral or targeted advertising or marketing to parents or students. In order to continuously improve the products and services it provides to EAs and educational research, Edulog may use anonymized or de-identified, non-PII data, and any reports or other data generated by the Edulog Products or Edulog Services regarding traffic flow, feature use, system loads, product installation, and/or similar information, as well as seek input from the EAs and their employees regarding use of the Edulog Products and Edulog Services. 3 Data Security and Privacy Measures Edulog employs extensive technological and operational measures to ensure data security and privacy, including advanced security systems technology, physical access controls, and annual privacy training for employees and partners, and criminal background checks of all employees. All employees of Edulog are required to sign an Acknowledgement and Agreement of Policies that commits the employees to comply with Edulog's data privacy and security policies and receive required annual security and privacy training, including commitments and training regarding the prohibition on disclosure of student data. 4 Data Management The collection, input, use, retention, disposal, and disclosure of education records in our software applications are controlled solely by the EAs which

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