FERPA Policy

At ALE International and our affiliated entities (collectively, “ALE,” “we,” “us,” or “our”), we are committed to protecting the security and privacy of our customers’ educational data. Central to our efforts is our compliance with the Family Educational Rights and Privacy Act of 1974 (“FERPA”) relating to our U.S. customers in the K-12 and postsecondary education sectors (“School Subscribers”). This policy addresses how we comply with the requirements of FERPA.

How does ALE protect its School Subscribers’ data?

ALE’s commitment to protecting the security and privacy of our School Subscribers’ data includes submitting our privacy practices to assessment by a qualified independent third-party auditor and performing regular vulnerability scans and penetration tests to evaluate our security posture and identify new threats.

What is FERPA?

FERPA is a U.S. federal law that protects the privacy of student educational records. FERPA gives parents certain rights with respect to their children’s education records. These rights transfer to the student when he or she reaches the age of 18 or attends school beyond the high school level (an “Eligible Student”).

To what institutions does FERPA apply?

FERPA applies to all academic institutions that receive funds under applicable U.S. Department of Education programs.

What rights does FERPA grant to parents (or Eligible Students)?

FERPA grants parents (or Eligible Students) the following rights:

• The right to inspect and review education records within 45 days of the day a school receives a request for access.
• The right to request the amendment of an education record if the parent (or student who is 18 or older) believes the record to be inaccurate.
• The right to consent to disclosures of personally identifiable information contained in the student’s education records, except to the extent that FERPA authorizes disclosure without consent.
• The right to file a complaint with the U.S. Department of Education concerning alleged failures by the school to comply with the requirements of FERPA.

The Student Privacy Policy Office administers FERPA. Its address is U.S. Department of Education, 400 Maryland Avenue, S.W. Washington, D.C. 20202-4605.

What are “education records”?

Education records directly relate to a student and are maintained by an educational institution or by a party on behalf of the agency or institution. Video recordings/streams, chat logs, transcripts, and other information collected or maintained by a School Subscriber while using ALE’s services may be considered education records under certain circumstances.

What is “personally identifiable information” under FERPA?

The term personally identifiable information can have different meanings under different laws. For the purposes of FERPA, personally identifiable information (“PII”) means any information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty. PII includes, but is not limited to, the student’s name, parents’ name(s) (including mother’s maiden name or the name of other family members of the student), address, personal identifiers (such as Social Security Number or student number), biometric information, date of birth, and place of birth.

How does ALE receive PII from education records?

For the purposes of FERPA, ALE is considered a “school official” and may receive PII through its contractual agreements with School Subscribers because ALE is performing a service that furthers a “legitimate educational interest” (i.e., the provision of educational services in a remote setting). As set forth in our Children’s Educational Privacy Statement, ALE maintains student PII on behalf of, and at the direction of, the School Subscriber and does not use the student PII for other purposes except as permitted by applicable law, including FERPA and applicable agreements with schools and districts.

How does ALE help schools comply with FERPA’s data-protection requirements?

ALE uses technical and organizational measures designed to help protect PII from unauthorized access, use, or disclosure. These measures include:

• Providing guidance on how to implement and utilize account settings designed to protect participant privacy. Certain features are enabled by default for K-12 account users, including use of meeting passwords, the Report a User feature, restrictions on screen sharing privileges, which are set by default to “Host Only,” and the virtual Waiting Room feature.
• Encrypting all customer content in transit between any devices running an ALE client and at rest when in permanent storage in the ALE Cloud.
• Limiting ALE’s collection, use, and disclosure of student PII to limited circumstances. Specifically, ALE only collects and uses student PII that it needs to provide and improve our services or as otherwise directed by the School Subscriber. ALE does not sell student PII or use student PII for interest-based advertising.
• Disclosing student PII to others only to the extent needed for third-party providers to help ALE provide its services, for legal reasons, or in other limited circumstances in compliance with FERPA.
• Retaining student PII only for as long as necessary to comply with legal obligations after account termination. Customer content stored on the ALE Cloud is retained for the life of the account; however, School Subscribers are free to delete this content at any time. After an account is terminated, customer content is automatically deleted in accordance with ALE’s policies and agreements with School Subscribers.

How can parents (or Eligible Students) exercise their FERPA rights?

If a parent or Eligible Student would like to access, review, refuse further collection, or request deletion of student PII, they must contact their School Subscriber to make such requests. ALE cannot respond directly to such requests, and any decisions regarding such requests are in the sole discretion of the School Subscriber. ALE will cooperate with requests by a School Subscriber for assistance in accessing or deleting student PII; however, in most cases, the School Subscriber can honor requests from parents or Eligible Students directly without additional involvement by ALE.

How can we be contacted?

Contact ALE using the below contact information if you have questions regarding this policy, or ALE’s use of student information.

FERPA Officer
ALE USA Inc.
salvatore.zoida@al-enterprise.com
+1 (747) 388-7468

You can also contact us by writing to the following address:

ALE USA Inc.
Attention: Legal, FERPA Officer
26801 W. Agoura Road
Calabasas, CA 91301

Additional Resources

FERPA Privacy Statement
Children’s Educational Privacy Statement

Revised: April 18, 2022