Privacy Policy

1. Information the Service handles

Staff enter or import the following categories of student data to track IEP compliance:

• Student identifiers — name, grade, date of birth, and (if provided by the district's SEIS export) a statewide student ID.
• Special-education information — disability/eligibility category, program type, annual IEP and triennial reevaluation dates, meeting dates and logistics, and case notes.
• Meeting participants — service providers invited and parent/guardian/education-rights-holder contact details entered by staff.
• Documents generated in-app, such as Prior Written Notice drafts.
• Account information — the staff member's email address and assigned role/site (used for sign-in and access control).

Caseload files exported from SEIS are parsed in the staff member's browser. The original file is not uploaded; only the parsed records are saved to the destinations described below.

2. Where the data is stored

• Supabase (PostgreSQL), United States region. Student records sync to a private database so a case manager's caseload is available across their devices and to authorized district staff.
• The staff member's browser (local storage), on their own device. The Service keeps a local copy so it works offline and loads quickly. Staff can erase this at any time via Site Setup → My Info → Clear All Data.

3. Who can access student data

Access is enforced at the database with row-level security, so it cannot be bypassed by the app:

Sure Step personnel do not access a district's student records except where a district explicitly requests support and authorizes it in writing.

4. How the data is used

Student data is used solely to provide the compliance-tracking Service to the district: tracking deadlines, scheduling meetings, generating required notices, and producing compliance reports for district staff. We do not sell student data, use it for advertising, or build advertising profiles, and we do not use it to train artificial-intelligence models. The Service contains no third-party advertising or analytics trackers.

4a. AI-assisted Prior Written Notice drafting

The Service offers an optional feature that uses artificial intelligence (Anthropic's Claude) to help a case manager draft a Prior Written Notice from the district's own template and a few answers the staff member provides. This feature is designed to minimize what is shared:

• De-identification before transmission. Student, parent/guardian, and staff names are replaced with placeholders (for example, [STUDENT], [PARENT/GUARDIAN], [CASE MANAGER]) on the staff member's device before any text is sent to the AI service. The real names are re-inserted locally in the returned draft.
• Mandatory review. The staff member is shown exactly what will be sent and is asked to remove any other identifying details (such as peer names) before generating.
• Honest limitation. De-identification is rule-based on the names known to the app; it is not a guarantee that every identifier is removed, which is why the review step is required. Free-text that a staff member types is their responsibility to scrub.
• The AI provider does not use data submitted through its API to train its models, and we do not use student data to train any model.

This feature is off unless a district uploads a PWN template and a staff member chooses to use it. Anthropic is listed as a subprocessor below.

5. Subprocessors

We use the following service providers. Each is engaged under its own terms; those that store or transmit student data do so under a data-protection commitment.

Adding any new subprocessor that touches student data is disclosed here before it is used.

6. Security

• All connections use HTTPS/TLS encryption in transit; data at rest is encrypted by our database provider.
• Row-level security isolates each caseload at the database layer — the guarantee that one case manager cannot see another's students does not depend on application code being bug-free.
• Sign-in is required for all access; the public application key cannot read data without an authenticated, authorized session.

No system is perfectly secure, and we do not claim otherwise. We work to protect data using reasonable, industry-standard measures appropriate to the sensitivity of student records.

7. Data retention and deletion

• Records persist until deleted by district staff or at the end of the district's agreement, per the district's instructions and its record-retention obligations.
• The device-local copy is removed with Clear All Data or by clearing the browser's storage.
• On termination of a district's agreement, we provide the district its data and delete records according to the agreed schedule in the district's data-protection agreement.

8. Rights of parents and eligible students

Because the district controls its education records, requests to review, correct, or delete a student's records are handled by the district under FERPA and California law. Sure Step supports the district in fulfilling such requests.

9. Data-protection agreements

Sure Step enters into data-protection/privacy agreements with districts (for example, an NDPA-style DPA) that govern the handling of student data consistent with FERPA, California Education Code §49073.1 (AB 1584), and SOPIPA (California B&P Code §22584). Districts should have such an agreement in place before loading real student data.

10. Children's privacy

The Service is used by district staff, not by students, and collects student information only from the district as part of providing the Service. It is intended for a school context under the district's authority.

11. Changes to this policy

If we make a material change to how student data is handled, we will update this page and notify districts as required by applicable law before the change takes effect.

12. Contact

Questions about this policy or a district's data can be directed to:
Nicholas Crabtree, Sure Step Education — nick@surestepeducation.com