The 2025 COPPA Rule amendments take effect June 23, 2025, with full compliance required by April 22, 2026. Educational technology companies face a unique challenge: how do you measure product engagement while protecting student privacy under FERPA, COPPA, and state laws like California's SOPIPA? This guide explores the regulatory landscape and technical requirements for EdTech analytics.
๐ COPPA 2025 Rule Amendments
On April 22, 2025, the FTC published final amendments to the Children's Online Privacy Protection Rule. These changes significantly expand what qualifies as "personal information" and create new requirements for EdTech companies serving children under 13.
Key Timeline
- June 23, 2025: Amendments take effect (60 days after publication)
- April 22, 2026: Full compliance deadline
Expanded Definition of Personal Information
The 2025 amendments expand "personal information" to include:
Biometric Identifiers
Fingerprints, retina patterns, iris patterns, genetic data (DNA), voiceprints, gait patterns, facial templates, and faceprints used for automated or semi-automated recognition. The FTC explicitly rejected requests for security or age verification exceptions.
Government-Issued Identifiers
Social Security numbers, state identification card numbers, birth certificate numbers, and passport numbers are now explicitly covered.
Online Contact Information
Mobile telephone numbers are now included, recognizing that messaging platforms use internet connections for direct communication.
New Consent and Retention Requirements
- โข Separate opt-in consent required for disclosing children's personal information to third parties for targeted advertising
- โข Written data retention policies must specify purposes for collection, business need for retention, and deletion timelines
- โข Enhanced direct notices must disclose how operators intend to use children's personal information, not just what categories are collected
What the FTC Declined to Adopt
The FTC notably declined to finalize proposed EdTech-specific amendments, including new definitions of "School" and "School-authorized education purpose." The Commission cited potential conflicts with DOE's FERPA regulations. This leaves EdTech companies without formal clarity on school authorization for parental consentโthe exception remains in FTC guidance but isn't codified in the rule.
๐ FERPA Requirements for EdTech
The Family Educational Rights and Privacy Act (20 U.S.C. ยง 1232g) protects student education records at institutions receiving federal education fundingโvirtually all public schools and most private schools.
What Are "Education Records"?
Records containing information directly related to a student and maintained by an educational agency, institution, or person acting for such agency. When analytics events like "lesson_completed" are linked to persistent student identifiers, they may create education records under FERPA.
The "School Official" Exception
FERPA permits disclosure to "school officials" with "legitimate educational interest" without parental consent. Analytics vendors may qualify if they meet specific conditions:
Requirements to Qualify:
- โ Under the school's direct control regarding use and maintenance of education records
- โ Performing services the school would otherwise perform itself
- โ Contractual terms ensuring appropriate use restrictions and data security
Why Most Analytics Vendors Don't Qualify:
- โ Aggregate data across multiple schools beyond any single school's control
- โ Use student information for their own product improvement
- โ Share data with advertising networks or other services
๐ป California SOPIPA
California's Student Online Personal Information Protection Act (effective January 1, 2016) imposes obligations directly on EdTech operatorsโnot just schools. It applies to services with actual knowledge they're used primarily for K-12 purposes and designed/marketed for K-12.
SOPIPA Prohibits:
- โ Targeted advertising based on information acquired through K-12 services
- โ Amassing student profiles for non-K-12 purposes
- โ Selling student information or disclosing it for non-K-12 purposes
Unlike FERPA (which has no private right of action), SOPIPA is enforced through California's Unfair Competition Law, allowing the Attorney General and district attorneys to bring actions. This creates real enforcement potential.
โ ๏ธ Analytics Privacy Challenges for EdTech
Traditional analytics platforms collect data that qualifies as personal information under COPPA and personally identifiable information under FERPA:
Device Identifiers
IDFA, GAID, or fingerprints that persist across sessions. Personal information under 2025 COPPA.
IP Addresses
Often stored for geolocation. Collection requires parental consent under COPPA for child-directed services.
Persistent User IDs
Track students across sessions. Create education records under FERPA when combined with educational activity.
Custom Event Properties
Free-form fields where developers might accidentally include student names, grades, or assessment scores.
The Biometric Data Challenge
EdTech apps using voice interaction, facial recognition for engagement tracking, or biometric authentication now face enhanced requirements under COPPA. The FTC explicitly rejected exceptions for security purposes or age verificationโoperators must obtain verifiable parental consent before collecting biometric information from children.
๐ก๏ธ Data Minimization Approach
Respectlytics helps developers avoid collecting personal data in the first placeโour Return of Avoidance (ROA) approach. For EdTech, this means architectural choices that prevent student data collection rather than relying on policies alone.
RAM-Only Session Identifiers
Anonymized identifiers stored only in device memory, rotating every two hours or on app restart. Hashed server-side with daily rotating salt. Cross-session student tracking is technically impossible.
Strict 5-Field Storage
Only these fields are stored:
- โข
event_name(e.g., "lesson_completed") - โข
session_id(RAM-only, hashed) - โข
timestamp - โข
platform - โข
country(approximate only)
Blocked Custom Properties
The API returns a 400 error if developers attempt to send additional fields. This prevents accidental transmission of student names, grades, assessment scores, or any personally identifiable educational information.
๐ง Implementation Guide
Design Privacy-Safe Event Names
// โ
Use descriptive event names
"math_lesson_started"
"reading_quiz_completed"
"science_video_viewed"
// โ Avoid generic names requiring properties
"activity" + property: {student_id: "12345"// Blocked
"score" + property: {points: 85// BlockedSDK Integration
import RespectlyticsSwift
Respectlytics.configure(apiKey: "your-api-key")
Respectlytics.track("math_lesson_completed")What Session-Based Analytics Measures:
- โ Learning feature adoption rates
- โ Session completion patterns
- โ Drop-off points in lessons and assessments
- โ Platform distribution (iOS, Android, Web)
- โ Country-level geographic trends
Trade-offs (Cannot Track):
- โ Individual student progress across sessions
- โ Per-student retention or learning outcomes
- โ Cross-device usage by the same student
โ๏ธ Regulatory Considerations
Important: We Are Not Lawyers
Respectlytics provides a technical solution focused on data minimization. We do not provide legal advice or claim our product satisfies any specific regulatory requirement.
Consult your legal team to determine:
- โข Whether your service is child-directed under COPPA or has actual knowledge it's used by children
- โข Whether your analytics create education records under FERPA
- โข How to structure school contracts and data processing agreements
- โข Whether California SOPIPA applies to your service
- โข How the 2025 COPPA amendments affect your specific data practices
Legal Disclaimer
This article provides educational information about educational privacy regulations and analytics architecture. It does not constitute legal advice. COPPA, FERPA, and state student privacy laws vary in application depending on your specific service, user base, and data practices. The 2025 COPPA Rule amendments create new requirements with an April 2026 compliance deadline. Consult your legal team to determine the requirements that apply to your situation.
Additional Resources
- Respectlytics SDK Documentation - Integration guides for Swift, Flutter, React Native, and Kotlin
- Mobile Analytics Without Personal Data - Technical architecture deep dive