How does Prodigy Comply with Connecticut (CT) ACT 16-189?

Prodigy is very serious about protecting the privacy of teachers, parents and students. We have partnered with industry privacy expert iKeepSafe to review our privacy compliance and have been certified as compliant with the Children’s Online Privacy Protection Rule (COPPA), Family Educational Rights and Privacy Act (FERPA), and California Student Privacy Certified (CSPC).

What is CT 16-189?

CT 16-189 is a Connecticut specific Public Act Concerning Student Data Privacy. CT 16-189 builds on FERPA and incorporates several provisions to protect the privacy of student information including:

  • Restricting how student information may be used by entities that contract to provide educational software and electronic storage of student records and by operators of websites, online services or mobile applications
  • Clarifying that student data collected for school purposes is not owned by any of these third-party contractors
  • Requiring local boards of education to notify parents when they execute a new contract with a software, data storage, or internet service provider
  • Stipulating data security and privacy provisions that must figure in all contracts between local school districts and software, data storage and internet service providers
  • Requiring school districts to withhold the release of student directory information if the local or regional board of education determines that a request for such information is not related to school purposes
How does Prodigy stay CT 16-189 compliant?


Within CT 16-189 Prodigy would be considered an operator because we operate a website or online service that is designed and used for educational purposes and we collect and use some student information. As an operator, Prodigy is committed to:

  • NOT performing targeted advertising using student data
  • NOT storing/collecting student data for anything other than school purposes
  • NOT selling data to third parties 

In order to ensure that Prodigy is compliant with CT 16-189, where a contract is present with both local education authorities and third parties, each contract will contain certain provisions, including the following:

  • Pupil records provided by the education agency be the property of and under the control of the educational agency
  • Pupils retain possession and control of their content
  • Legal guardians or the pupils have the ability to review and/or correct personally identifiable information
  • Where a contract exists, Prodigy will not to retain pupil records beyond the terms of the contract, unless a parent/guardian is linked to the student account
  • Where a contract exists, third parties are not to use pupil record information for purposes beyond those specified in the contract
  • Prodigy will not use personally identifiable pupil record information to engage in targeted advertising
  • Prodigy will ensure the security and confidentiality of the records
  • Prodigy will notify the local education agency in the event of an unauthorized disclosure
  • Prodigy will work together with local educational agencies to ensure compliance with the federal Family Educational Rights and Privacy Act (FERPA)

Prodigy maintains a comprehensive set of security practices that are reasonably designed in accordance with commercial best practices to protect the security, privacy, confidentiality and integrity of student personal information against risks - such as unauthorized access or use, or unintended or inappropriate disclosure - through the use of administrative, technological and physical safeguards. Prodigy’s practices include a notification to school boards of unauthorized releases of information.

What Privacy Certification has Prodigy attained?

Prodigy has earned a California Student Badge from iKeepSafe, a leading independent privacy protection organization. The California Student Badge certifies that Prodigy is compliant with:

  • Family Educational Rights and Privacy Act (FERPA)
  • The Children’s ONline Privacy and Protection Act (COPPA)
  • Protection of Pupil Rights Amendment (PPRA)
  • Student Online Personal Information Protection Act (SOPIPA)
  • AB 1584: Privacy of Pupil Records: 3rd-Party Digital Storage and Education Software
  • Collection of Student INformation from Social Media (California Education Code 49073.6

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