Student Data Privacy Policy

Effective Date: August 2026

Closing Gaps LLC provides academic support, enrichment, mentoring, and other educational services to schools and educational organizations. In providing these services, Closing Gaps LLC may receive limited student information from Schools or a school district or may use authorized educational technology to support instruction.

Closing Gaps LLC is committed to protecting student information and using it only for legitimate educational purposes.

1. Student Information We May Receive

The student information Closing Gaps LLC receives or collects depends upon the specific services being provided. We limit student information to what is reasonably necessary to provide those services.

Information may include:

• Student name or authorized identifier
• School
• Grade level
• Program enrollment and participation information
• Attendance information
• Student responses, assignments, or other student-generated educational work
• Academic progress or performance information when applicable
• Non-personally identifiable program survey responses
• Educational platform username, password, or other account information when required to provide educational services.  Closing Gaps LLC does not collect or maintain students' CPS or Google account passwords.

Closing Gaps LLC does not routinely collect sensitive demographic information such as race, ethnicity, gender, or date of birth unless specifically required and authorized for a contracted educational purpose.

2. How Student Information Is Used

Student information may be used to provide contracted educational services, including student enrollment and rostering, grade-appropriate instruction, individualized academic practice, progress monitoring, program participation tracking, assessment, program evaluation, and reporting to authorized school or district personnel.

Student information is not used for purposes unrelated to the educational services Closing Gaps LLC has been engaged to provide.

3. Educational Technology

Closing Gaps LLC may use licensed educational technology platforms to supplement academic instruction, individualized practice, assessment, and student progress monitoring.

When an educational technology platform requires student information, Closing Gaps LLC limits the information provided to what is necessary for the educational service.

Specific technology providers and the student information shared with those providers may be disclosed to the contracting school or school district through applicable agreements, student-data exhibits, or other required documentation.

Closing Gaps LLC follows applicable school or district requirements regarding approved technology, student accounts, authentication, rostering, Single Sign-On, and data sharing.

4. Independent Contractors and Instructors

Closing Gaps LLC may engage qualified independent contractors and instructors to deliver educational and enrichment programming.

Independent contractors providing instruction on behalf of Closing Gaps LLC do not routinely receive identifiable student rosters or student names. Access to personally identifiable student information is limited to authorized Closing Gaps personnel and other authorized parties when access is necessary to perform legitimate educational or administrative responsibilities.

5. Student Information We Do Not Sell or Use for Advertising

Closing Gaps LLC does not:

• Sell or rent student information.
• Use student information for targeted advertising.
• Create student profiles for noneducational purposes.
• Use student information for commercial purposes unrelated to the educational services being provided.
• Disclose personally identifiable student information to unauthorized parties.

6. Third-Party Educational Service Providers

Closing Gaps LLC may use authorized third-party educational technology providers to deliver instructional services, create and manage student accounts, provide academic practice or assessments, and monitor student progress. Student information is shared only as necessary to provide the authorized educational service and in accordance with the applicable school or district agreement.

Only student information reasonably necessary to provide the applicable educational service will be shared. Closing Gaps LLC will identify third-party providers and subprocessors as required by its agreements with schools and school districts.

7. Security

Closing Gaps LLC uses reasonable administrative, technical, and organizational safeguards designed to protect student information from unauthorized access, disclosure, alteration, loss, or misuse.

Access to identifiable student information is limited to individuals who require access for an authorized educational or administrative purpose.

8. Data Retention and Deletion

Closing Gaps LLC retains student information only for as long as necessary to provide contracted services or as required by applicable law or agreement.

At the conclusion of the applicable service or agreement, student information will be returned, transferred, deleted, or otherwise handled in accordance with the requirements of the contracting school or school district and applicable law.

9. Parent and Student Rights

Closing Gaps LLC respects the rights of parents, guardians, and eligible students regarding student information.

Requests to access, review, correct, or delete education records may be coordinated through the applicable school or school district. Closing Gaps LLC will cooperate with authorized requests from its educational partners as required by applicable law and contract.

10. Student Privacy Compliance

Closing Gaps LLC handles student information consistent with applicable student privacy requirements, including, as applicable, the Family Educational Rights and Privacy Act (FERPA), Children’s Online Privacy Protection Act (COPPA), Protection of Pupil Rights Amendment (PPRA), and Illinois Student Online Personal Protection Act (SOPPA).

When providing services to Chicago Public Schools, Closing Gaps LLC also follows applicable CPS contractual and student-data privacy requirements.

11. Data Security Incidents

If Closing Gaps LLC becomes aware of unauthorized access to or disclosure of protected student information, Closing Gaps LLC will take appropriate measures to address the incident and notify the applicable school or school district as required by law and contractual requirements.

12. Changes to This Policy

Closing Gaps LLC may update this Student Data Privacy Policy to reflect changes in its services, technology practices, legal requirements, or contractual obligations.

The current version will be made publicly available through the Closing Gaps LLC website.

13. Contact

Questions regarding this Student Data Privacy Policy or Closing Gaps LLC’s handling of student information may be directed to:

Closing Gaps LLC
Email: admin@closinggapsllc.org
Website: www.closinggapsllc.org(opens in new tab)