St. Andrew's Episcopal School: Legal Risks & Redlines in Privacy Policy | Erayaha

Uncovering Legal Risks in St. Andrew's Episcopal School's Privacy Policy

When we examined St. Andrew's Episcopal School's privacy policy, our analysis revealed several critical legal risks that could expose the school to regulatory fines, litigation, and reputational harm. With GDPR penalties reaching up to €20 million or 4% of annual revenue, and CCPA fines of $2,500–$7,500 per violation, even a single oversight can have significant financial consequences. Below, we highlight four key issues and present actionable redlines to strengthen enforceability and compliance.

1. Ambiguous Scope of Third-Party Data Sharing The policy states that personal information is not shared with non-affiliated third parties unless otherwise stated at the time of collection. However, it lacks specificity about what constitutes a 'third party' and under what conditions data may be shared, creating ambiguity and potential loopholes for unauthorized disclosures. This ambiguity could result in regulatory scrutiny and parent complaints, especially if student data is shared with vendors or partners without clear notice or consent.

Legal Analysis

high Risk

Removed

Added

Personal information provided to the school iswill not be shared with non-affiliatedany third parties unless otherwise stated at, including vendors, service providers, or partners, except as explicitly disclosed in this policy or with the timeexpress, informed consent of collectionthe data subject or their legal guardian, in accordance with applicable privacy laws.

Legal Explanation

The original clause is vague about what constitutes a third party and under what circumstances information may be shared. The revision provides explicit limitations and requires informed consent, reducing ambiguity and aligning with GDPR/CCPA requirements.

2. Insufficient Parental Consent Mechanisms for Student Data The policy authorizes the school to provide consent to third-party data collection on behalf of parents. However, it does not specify the process for obtaining verifiable parental consent or outline safeguards for sensitive student information. This gap increases the risk of non-compliance with COPPA (Children's Online Privacy Protection Act) and state student privacy laws, potentially resulting in fines of up to $43,280 per violation.

Legal Analysis

critical Risk

Removed

Added

Notwithstanding anything herein to the contrary, Parents authorize theThe School to providewill obtain verifiable parental consent prior to suchdisclosing or authorizing the collection of student personal information onby third parties, in compliance with COPPA and applicable state laws. Parents’ behalf will be notified of the specific data collected, its purpose, and to provide the student’s basic information when required to do soidentity of third-party recipients.

Legal Explanation

The original clause allows the school to consent on behalf of parents without a clear process or safeguards. The revision mandates verifiable parental consent and transparency, reducing legal exposure under COPPA.

3. Lack of Data Retention and Deletion Policy There is no mention of how long personal information is retained or the procedures for data deletion upon request. Without clear data retention limits and deletion rights, the school risks violating GDPR Article 17 (Right to Erasure) and CCPA requirements, exposing it to regulatory action and costly remediation.

Legal Analysis

high Risk

Removed

Added

The policy does not address data retentionPersonal information will be retained only as long as necessary to fulfill the purposes for which it was collected, after which it will be securely deleted or anonymized. Data subjects may request deletion proceduresof their information at any time, subject to legal obligations.

Legal Explanation

Absence of a data retention and deletion policy increases risk of non-compliance with GDPR and CCPA. The revision establishes clear retention limits and deletion rights, supporting regulatory compliance.

4. Limited Clarity on Security Incident Response While the policy mentions SSL encryption, it does not address the school's obligations to notify affected individuals or authorities in the event of a data breach. Failure to provide clear breach notification procedures could lead to delayed responses, regulatory fines, and reputational damage. Under GDPR, failure to notify within 72 hours can result in significant penalties.

Legal Analysis

medium Risk

Removed

Added

The school is committed to protecting the personal and confidential information of. In the usersevent of its website. When users submita data breach involving personal data, the school will notify affected individuals and/or confidential information via online forms relevant authorities within 72 hours, registrationin accordance with GDPR and applicable state laws, or online purchase, thatand will provide information is encrypted via SSL (Secured Sockets Layer) upon submissionon remedial actions taken.

Legal Explanation

The original clause lacks breach notification procedures. The revision adds clear obligations for timely notification, reducing regulatory risk and supporting transparency.

Conclusion: Proactive Legal Safeguards for Educational Institutions Our analysis demonstrates that addressing these gaps is critical for reducing financial and legal exposure. By implementing the recommended redlines, St. Andrew's Episcopal School can better protect its community, ensure regulatory compliance, and avoid costly penalties.

How confident are you in your institution's data governance and privacy safeguards?
Are your third-party vendor agreements aligned with student privacy laws?
What steps can you take today to proactively reduce legal risk?

**This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai's terms of service for liability limitations.**