Data Processing Agreement
AgenticED, Inc.
Based on the Student Data Privacy Consortium's National Data Privacy Agreement (Standard)
We Sign the Agreement Your District Already Uses
AgenticED did not write its own student data privacy agreement. We sign the National Data Privacy Agreement (NDPA), the standard instrument developed by the Student Data Privacy Consortium and Access 4 Learning and used by school districts across more than thirty state alliances.
We chose this on purpose. A vendor-drafted agreement means your counsel reads a document they have never seen and negotiates terms with no precedent. When a vendor signs the NDPA, your counsel reads a document they already know, and most of the negotiation is done before it starts.
We sign the Standard version of the NDPA, with your State Alliance's state exhibit. We are not asking districts to accept carve-outs from the standard clauses.
Exhibit E Lets the Next District Adopt the Same Terms
Exhibit E of the NDPA is the General Offer of Privacy Terms. When a provider signs it, any other district in the same State Alliance can adopt the identical privacy terms by countersigning, instead of running its own review.
We sign Exhibit E with the first NDPA we execute in each State Alliance and post it to the Student Data Privacy Consortium Registry. After that, any district in that alliance can subscribe to the same terms with a signature.
What the Agreement Covers
| Topic | Terms |
|---|---|
| Data ownership | The district owns the student data. We hold it as a school official under the district's direct control and may use it only for the authorized purpose. |
| Permitted purpose | Only what the district authorized. No advertising, no profiling, no secondary use, and no sale. |
| Security | The controls in our Security Overview, under the framework named in Exhibit F. |
| Breach notification | Notice to the district within seventy-two hours of confirming a breach, with the cooperation the agreement requires. |
| Service providers | Every third party that processes data is disclosed, bound to equivalent obligations, and subject to the agreement's change notice. Our current list is in the Privacy Policy. |
| Data return and destruction | On termination or on request, data is returned or destroyed as the district directs, using Exhibit D. |
| Parent rights | Our obligation to support the district in answering parent requests to see, correct, and delete records. |
| State requirements | Exhibit G, supplied by your State Alliance and incorporated as written. |
Our Exhibits
Exhibit A: Products and Services Covered
Exhibit A sets the scope of the agreement, and it is what the Student Data Privacy Consortium Registry records. The products we offer under the NDPA:
| Product | What it does |
|---|---|
| The AgenticED Platform | Agent registration, certification, and the gateway that governs which agents may reach district data |
| Next Move | Opportunity matching and the Opportunity Matrix |
| JustData | District data access with pseudonymized and longitudinal analysis |
| The Ledger | The record of agent activity, consent, and disclosure |
| Ground Truth | A verified district data foundation |
| Board Response | Superintendent and board reporting |
| Workspace | Staff work and growth tools |
| FAFSA Agent | Federal student aid application support |
| Benefits Agent | Benefits eligibility screening and application support |
| Parent Advocate | Family portal, opportunity discovery, and communication |
The Exhibit A in each signed agreement lists the products that district has licensed.
Exhibit B: Data Elements
The NDPA asks a provider to list every element its products can collect, marked required or optional. A district then limits what is shared through its own configuration and its Registry settings.
The categories, each marked required or optional for each product in the signed exhibit:
- Identity and enrollment
- District, state, and student information system identifiers
- Attendance
- Grades and coursework
- Assessment results
- Transcripts and credits
- Graduation plan progress
- Discipline records, including the student's recorded ethnicity for disproportionality reporting
- Race and ethnicity
- English-learner status and home language
- Meal program eligibility
- Special education and Section 504 plan contents, including disability category
- Foster care, housing instability, migrant, and military-connected status
- Immigrant or refugee status (a yes-or-no indicator used only for scholarship and program matching)
- Parent and guardian contact details
- Household composition and income range
- Custody arrangements, court orders, and contact restrictions
- Benefits applications and eligibility estimates
- Federal student aid applications
- Uploaded documents
- Conversation content
Not collected by any product: Social Security number, health or medical records, voice recordings or voice transcripts, exact income, salary, or adjusted gross income, biometric identifiers, precise geolocation, and employee compensation.
Exhibit D: Data Disposition
Exhibit D is the form a district uses during the life of the contract to direct the return or destruction of specific data. It is not completed at signing.
A directed erasure removes the records from more than sixty tables in a single operation that either completes or changes nothing. It produces a receipt naming what was deleted, the record counts, and each kind of record deliberately kept, with the reason for each. The records kept are audit and consent evidence, because destroying the proof that a disclosure was authorized would defeat the purpose of requiring authorization. A district may direct us to destroy that evidence as well.
Exhibit E: General Offer of Privacy Terms
Signed with the first NDPA in each State Alliance and posted to the Student Data Privacy Consortium Registry as its own document.
Exhibit F: Cybersecurity Framework
The NDPA requires a provider to name at least one security framework.
AgenticED aligns its security program to the NIST Cybersecurity Framework. It is also the framework our vendor certification program applies to third-party agents.
Exhibit G: State Requirements
Supplied by your State Alliance and incorporated without change. We sign the state exhibit for each alliance in which we contract.
Exhibit H: Modifications
None. We sign the Standard version.
Getting the Agreement
If a district in your State Alliance has already signed an NDPA with us, your district can adopt the same terms by countersigning our Exhibit E.
If your district is the first in its alliance, write to privacy@agenticed.com. We will sign a Standard NDPA with your district and sign Exhibit E so that every district after you can subscribe.
If your district uses its own agreement instead of the NDPA, we will review it and sign it where we can. We will tell you plainly where it differs from the NDPA and why that matters.
AgenticED, Inc.
Attn: Chief Compliance Officer
240 West 136th Street
New York, NY 10030
privacy@agenticed.com