COPPA Updates 2025: What K–12 Schools Must Know
Why COPPA Matters More Than Ever
When Congress passed the Children’s Online Privacy Protection Act (COPPA) in 1998, few could imagine how integrated digital learning would become. Today, nearly every classroom relies on online tools, learning platforms, digital textbooks, and AI-driven apps that collect and process vast amounts of student data.
Recognizing that the original rule no longer reflected today’s technologies, the Federal Trade Commission (FTC) issued comprehensive updates to COPPA in 2025. These revisions modernize how children’s personal information must be collected, used, and protected online.
View the FTC’s official announcement of the 2025 COPPA Rule changes
1. What’s New in the 2025 COPPA Updates
Expanded definition of “personal information”
The updated rule broadens what qualifies as “personal information” to include biometric identifiers (fingerprints, retinal scans, and genetic data), device IDs, persistent cookies, precise geolocation data, and inferred behavioral profiles. Any data that can identify or track a child, even indirectly, is now protected.
Clarifying “school consent”
Schools may consent on behalf of parents only when student data is used strictly for educational purposes. The updated rule makes clear that this consent does not extend to the use of student data for AI training or analytics beyond classroom support. The FTC also advises districts to review each service’s privacy practices, notify parents of approved tools, and maintain a documented list of authorized apps and websites to support transparency.
Data minimization and retention limits
Operators may keep children’s personal data only as long as necessary to fulfill the specific educational or operational purpose for which it was collected. The rule now requires a written data-retention policy included in the operator’s online privacy notice, describing how long information is stored and when it is deleted.
AI transparency and training disclosure
Operators that use children’s data in connection with artificial intelligence must clearly disclose which categories of data are used and whether data is shared with third-party processors. Separate verifiable parental consent is required for any AI use that is not integral to the educational service.
Stronger enforcement and penalties
The FTC increased potential civil penalties and strengthened oversight for repeat violators. It can now require ongoing compliance audits and documentation of operator safeguards to ensure continuous adherence to the rule.
2. How the New Rules Impact K–12 Districts
Parental vs. school consent
Districts can still authorize edtech tools on behalf of parents when the use is solely educational and non-commercial. Any vendor data use for advertising, profiling, or product development outside of that purpose requires direct parental consent.
Vendor vetting and documentation
The FTC encourages schools to review the privacy and data-handling practices of each online service before authorizing its use. Districts should maintain a list of approved websites and apps, share that list with parents, and document each vendor’s data-retention details.
Privacy notices to families
Schools should provide parents with clear information about the online services being used, how student data is collected and shared, and what choices families have regarding consent or review of that data.
Integration with district policies
District technology policies should reflect COPPA’s requirements - especially the limits on consent, retention, and commercial use - to avoid inconsistencies in how online tools are approved and monitored.
3. What Vendors Must Do to Stay Compliant
Update privacy notices and retention policies
Under the new rule, operators must clearly explain what categories of information they collect, how that data is used, and whether it is disclosed to third parties. Privacy notices must now include a written data-retention policy specifying how long children’s data is kept and when it will be deleted.
Implement verifiable consent workflows
Operators must ensure they have mechanisms to obtain verifiable parental consent before collecting data from children under 13, unless the collection falls under valid “school consent” for educational use.
Restrict secondary uses of data
Information collected for educational functionality may not be used for advertising, marketing, or AI model training that is not directly related to providing the educational service.
Maintain reasonable security safeguards
The FTC’s final rule strengthens data-security expectations. Operators must implement and regularly assess measures to protect the confidentiality, integrity, and security of children’s data.
Enhanced accountability
While not mandated, the FTC encourages transparency reporting and routine internal reviews to confirm compliance with data-retention limits, notice accuracy, and consent procedures.
4. AI and the Future of Children’s Data Privacy
Artificial intelligence introduces new privacy considerations for children’s data. The FTC clarified that AI-related processing, such as using children’s data to train or refine algorithms, requires separate verifiable parental consent unless that use is essential to delivering the educational service.
Operators must also disclose whether data shared with third-party AI vendors could influence recommendations or adaptive content visible to students. This ensures parents and schools understand when automated systems shape a child’s digital experience.
5. Practical Steps for District Compliance
- Maintain an approved vendor list
Keep an up-to-date list of all online tools and apps approved for use, including links to each service’s privacy policy and data-retention statement. - Review vendor policies regularly
Re-evaluate approved tools to confirm compliance with COPPA’s updated requirements. - Train staff on student privacy
Ensure teachers and technology staff understand when school consent applies and how to handle parental inquiries about student data. - Communicate clearly with families
Provide parents with notice of all websites and services used by the school. - Promote accountability
Document district review processes and maintain records showing that vendors are used only for educational purposes.
6. Building a Culture of Compliance and Trust
COPPA’s modernization is more than a legal update, it represents a renewed emphasis on transparency, limited data use, and accountability in children’s digital learning environments.
Districts that establish clear internal policies, vet vendors carefully, and maintain transparency with families not only comply with federal law but also strengthen trust between schools, parents, and students.
7. Looking Ahead
The FTC has described these 2025 COPPA revisions as the foundation for ongoing modernization. Future updates may expand requirements for algorithmic transparency, security certifications, and enhanced parental access to children’s information.
For K–12 leaders, preparing today - by documenting vendors, training staff, and ensuring every approved tool aligns with COPPA’s limits - sets the stage for smoother compliance as the law continues to evolve.
Conclusion
The 2025 COPPA updates mark the most significant revision to children’s online privacy protections in over two decades. By reinforcing data minimization, notice, consent, and transparency, the FTC has clarified how schools and edtech vendors must handle children’s information in a rapidly changing digital world.
Districts that proactively manage vendor oversight, maintain transparency with families, and ensure tools comply with educational-use limits will lead the way in safeguarding student data privacy.
