Student Corner Student Data Privacy Promise

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Background

Student Corner believes in complete transparency around company policies that govern the collection, disclosure, and use of a student’s personally identifiable information (PII) and has adopted a formal privacy and data security policy, outlined below in five guiding principles.

Principle 1 - Student Corner will protect data and only use it to deliver the services in our agreement for our customers and users.

Student Corner agrees that any and all data exchanged shall be used expressly and solely for the delivery of services to our customers. Data shall not be distributed, repurposed, or shared across other applications, environments, or Company business units. As required by Federal and State law, Student Corner further agrees that no data of any kind shall be revealed, transmitted, exchanged, or otherwise passed to other vendors or interested parties without the express written consent of the Contracting Agency (Agency). Student Corner will disclose Confidential Information to its employees, authorized subcontractors, agents, consultants and auditors on a “need to know” basis only, provided that all such subcontractors, agents, consultants and auditors have executed written confidentiality obligations to Student Corner and all Student Corner clients. The confidentiality obligations shall survive termination of any agreement with Student Corner for a period of twenty (20) years or for so long as the information remains confidential, whichever is longer.

Principle 2 - Student Corner will maintain a secure technical environment for the protection of data

Student Corner agrees to protect and maintain the security of data with security protection measures that include maintaining secure environments that are patched and up to date with all appropriate security updates in accordance with industry standards. In order to ensure that only appropriate individuals and entities have access to personally identifiable student data, Student Corner has implemented various forms of authentication including, but not limited to secure password authentication and SSL encryption to establish the identity of the requester of the information with a level of certainty that is commensurate with the sensitivity of the data. No individual or entity is allowed unauthenticated access to confidential personally identifiable student records or data at any time for any reason.

Principle 3 - Student Corner will comply with all applicable Federal and State Laws concerning data privacy and protection

Student Corner agrees to comply with any and all State and Federal Laws, including but not limited to FERPA and COPPA, that require the notification of individuals in the event of unauthorized release of personally identifiable information or other event requiring notification. In the event of a breach of any of Student Corner’s security obligations or other event requiring notification under applicable law, Student Corner agrees to notify impacted organizations immediately and assume responsibility for informing all such individuals in accordance with applicable law and to indemnify, and to hold harmless and defend the Contracting Agency and its employees from and against any claims, damages, or other harm related to the breach and/or the Notification Event as applicable.

Principle 4 - Student Corner will implement and maintain policies to minimize the risk and impact of data breaches

Student Corner has established and implemented a clear data breach response plan outlining organizational policies and procedures for addressing a breach, which is an essential step in protecting the privacy of student data. Prompt response is essential for minimizing the risk of any further data loss and therefore, plays an important role in mitigating any potential negative consequences of the breach, including potential harm to affected individuals. A data breach is any instance in which there is an unauthorized release or access of personally identifiable information or other information not suitable for public release.

Principle 5 - If requested, Student Corner will return data to customers and users if and when we terminate our agreement, and will remove user data from our systems if requested

Student Corner agrees that upon termination of its agreement with the Contracting Agency, it shall return all data in a useable electronic format, and erase, destroy, and/ or render unreadable all data from the Contracting Agency in its entirety in a manner that prevents its physical reconstruction through the use of commonly available file restoration utilities. Student Corner further agrees to certify in writing that these actions have been completed within 60 days of the termination of the applicable agreement or within 7 days of the request of an authorized agent of the Contracting Agency, whichever shall come first.

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