Regulation — federal children's privacy
COPPA (15 USC 6501) — K-12 AI outreach and under-13 student pipelines
The Children's Online Privacy Protection Act governs collection of personal information from children under 13. Any higher-ed institution running K-12 outreach that AI-scores prospective students (early-identification programs, summer-enrichment recruiting, pipeline-development analytics) sits in COPPA's scope when those pipelines touch under-13 students.
What the statute actually says
"It is unlawful for an operator of a website or online service directed to children, or any operator that has actual knowledge that it is collecting personal information from a child, to collect personal information from a child in a manner that violates the regulations prescribed under subsection (b) of this section."
15 U.S.C. §6502(a)(1) — the operative prohibition
"The regulations … shall require the operator of any website or online service directed to children that collects personal information from children or the operator of a website or online service that has actual knowledge that it is collecting personal information from a child — (A) to provide notice on the website of what information is collected from children by the operator, how the operator uses such information, and the operator's disclosure practices … (B) to obtain verifiable parental consent …"
15 U.S.C. §6502(b)(1) — the notice + verifiable-parental-consent rule
What this means in plain English
Three things for higher-ed K-12 pipeline programs:
- Verifiable parental consent is the gate. Not a checkbox. Not an assumed consent.
- AI scoring of under-13 students is data collection. The score, the model version, the retained record — all subject to COPPA.
- FTC enforcement is real. Per-violation penalties are substantial and settlements routinely exceed $1M for large operators.
What triggers the exposure in the sample
The sample institution's outreach into under-resourced public-school markets may include K-12 pipeline programs. If any of those programs AI-score prospective students under 13 without documented verifiable parental consent + notice, COPPA exposure attaches independently of any Title VI issue.
What the $499 Snapshot shows against this rule
- Scope-check of K-12 outreach AI pipelines for under-13 data collection
- Notice + consent record inventory against COPPA requirements
- 3 fix-first items when K-12 AI scoring exists without documented consent
- Independent-verifier declaration bounded to the audited AI surface
See the scenario walkthrough →
$499 Snapshot. 3 business days.
COPPA-scope check on your K-12 outreach AI, alongside the primary admissions-AI evaluation.
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Snapshot credit applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days.