--- title: "DocAccess Student Data Privacy & the NDPA" slug: "docaccess-student-data-privacy-ndpa" updated: 2026-10-06T14:49:58Z published: 2026-10-06T14:49:58Z canonical: "www.civicplus.help/docaccess-student-data-privacy-ndpa" excludeFromExternalSearch: true --- > ## Documentation Index > Fetch the complete documentation index at: https://www.civicplus.help/llms.txt > Use this file to discover all available pages before exploring further. # DocAccess Student Data Privacy & the NDPA How DocAccess works with Kindergarten to 12 districts on the A4L National Data Privacy Agreement (NDPA), and everything your privacy office needs to approve us quickly. ## The Short Version - **Yes, we sign the NDPA.** DocAccess is a CivicPlus product, and CivicPlus supports the Student Data Privacy Consortium's National Data Privacy Agreement (NDPA) and your state alliance's version of it. - **DocAccess is not a student-data product.** It makes documents your district has already published accessible. It does not connect to your student information system, does not create student accounts, and does not need rosters, grades, or records to work. It can run inside Canvas and other learning management systems as an LTI (Learning Tools Interoperability) tool, but it requests none of the roster, grade, or submission services that touch students. Nearly every row of the Schedule of Student Data is "not collected". - **Incidental student information is still protected.** A board agenda that recognizes National Merit Scholars, or a newsletter naming honor-roll students, may pass through DocAccess because you published it. We treat that content with the same safeguards as everything else. Content you have already published on your own public website is excluded from the defined term "Student Data" by Exhibit H, item 1; the safeguards described below apply to it either way, and anything your staff upload that is not already public is Student Data in full. - **Our Provider answers are pre-filled below for an "Example Education Entity".** Copy them into your state's form, add your district's details, and send it to our contracts team. --- ## What the NDPA is, in Plain Terms The **National Data Privacy Agreement (NDPA)** is a standard contract template for how a technology vendor handles student data. It was written by the **Student Data Privacy Consortium (SDPC)**, a special interest group of the [Access 4 Learning (A4L) Community](https://privacy.a4l.org/), so that school districts and vendors stop negotiating the same privacy terms from scratch every time. State alliances of the SDPC publish their own version of the NDPA (for example, the Indiana NDPA version 2.2) that adds any state-specific terms in Exhibit G. More than 35 state alliances and 13,000 districts use it, and A4L estimates it has saved schools well over $100 million in negotiation costs. The agreement has a fixed body (the "Standard Clauses") that neither side edits, plus exhibits that the vendor fills in: - **Exhibit A** describes the products and services covered. - **Exhibit B** is the Schedule of Student Data: a checklist of every category of student information, marked Required, Optional, or not collected. - **Exhibit E** is the optional General Offer of Privacy Terms, which lets other districts in your state sign on to the same terms with a one-page subscription instead of a new agreement. - **Exhibit F** names the cybersecurity framework the vendor follows. - **Exhibit G** holds your state alliance's supplemental terms. - **Exhibit H** (Vendor-Specific version only) holds any clarifications the vendor proposes, so the Standard Clauses stay untouched. The NDPA comes in two flavors. The **Standard** version is used as-is. The **Vendor-Specific ("Modified")** version is identical except that it includes Exhibit H. Because CivicPlus proposes a handful of clarifications that reflect how DocAccess actually works (all listed below), **please use your state's Vendor-Specific version**. A4L's own guidance says the two are alternatives, not companions. --- ## Why Most of the Form Doesn't Apply to DocAccess DocAccess converts PDF documents and other documents into accessible, screen-reader-friendly HTML so your district can meet its obligations under Title II of the ADA and Section 504. The documents it works on are the ones your district has already chosen to publish on its public website: board agendas and minutes, budgets, handbooks, newsletters, policies, forms, and similar records. That design choice is the reason the Schedule of Student Data is almost entirely "not collected": - **No student accounts.** Readers of an accessible document, including students, are anonymous to us. No login, no registration, no cookies that identify a person. - **No student information system integration.** DocAccess never connects to your Student Information System (SIS), gradebook, attendance, transportation, or health systems, and we do not want that access. - **Accounts are for district staff only.** The people who sign in to DocAccess are the communications, web, and accessibility staff who manage your documents. - **Only aggregate analytics.** We record document view counts with city-level geography so you can see which documents are used. We never store a reader's exact IP address, account, or precise location at the application level. ### Two Situations Where Student Information Can Still Reach Us - **Incidental content in a published document:** Districts publish documents that name students: a board agenda recognizing National Merit Scholars, a newsletter with honor-roll lists, an athletics schedule with rosters, a graduation program. When DocAccess makes that document accessible, the student names inside it pass through our systems exactly as they appear in the public original. - **Optional direct upload and** LMS **integration:** District staff can upload a document directly instead of publishing it first, and districts using our Canvas integration can place accessible documents in courses (details in [Working Inside Your LMS](/legal-center/docs/docaccess-privacy-statement#working-inside-your-lms-canvas-and-others)). Whether anything containing student information is uploaded is entirely within your district's control, so we do not mark "None" on Exhibit B. That keeps the full protection of the NDPA available for anything your staff chooses to upload. ### What We Do in Those Cases We do not try to separate "student data" from the rest of a document. Every document, and any student information incidentally inside it, gets the same safeguards: - **Encryption** at rest (AES-256) and in transit (TLS 1.2+), hosted in U.S. AWS regions. - **Least-privilege access** with role-based controls and MFA for CivicPlus personnel, and confidentiality obligations for anyone with access. - **No secondary use.** Document content is never used to train AI models, sold, shared for marketing, or used for advertising of any kind. AI processing is request-scoped. - **You stay in control.** Disable a document and its accessible version is removed from public view immediately. Ask us to purge it, and the original and transcription are deleted within 30 days. At termination, content is deleted on request or per contract. - **Independent assurance.** A SOC 2 Type I examination with an unqualified opinion, available under NDA. Our program aligns with the NIST Cybersecurity Framework. - **Breach notification** without undue delay and in no event later than 48 hours after we become aware of a confirmed security incident affecting your data, sent to the contacts you designate to receive support tickets. The full details behind each of these are available on our [Security Practices](https://docaccess.com/security-practices) page and in our [Privacy Policy](/legal-center/docs/civicplus-privacy-policy) (see the sections on Children's Privacy and Student Data and FERPA). ### Working Inside Your LMS (Canvas and Others) Districts often want accessible documents inside the learning management system, not just on the public website, so DocAccess is also available as an LTI 1.3 tool (LTI is the 1EdTech standard that lets an LMS (Learning Management System) such as Canvas launch an outside tool). Being inside the LMS does not change what we collect. The integration is deliberately built so that it can work in a course without ever touching the students in it. **How it is used.** An instructor or staff member opens DocAccess from the Canvas editor, link picker, or assignment picker, chooses a course file or uploads a document, and DocAccess returns an accessible link into the course. Students click that link and read the accessible version in the same viewer used for public documents: no DocAccess account, no sign-in, no identifying cookie. Private course files stay behind the course's own login; opening one requires a launch from inside the course, and DocAccess does not learn who launched it. **What we deliberately do not request.** LTI 1.3 lets a tool ask the LMS for extra "service scopes" that reach into the class. DocAccess asks for none of them: - **No Names and Role Provisioning Services (NRPS)**. We never receive the course roster or who is enrolled. - **No Assignment and Grade Services (AGS)**. We never create gradebook columns, read scores, or post grades. - **No Asset Processor or submission access**. We never receive files students submit for assignments. - **Anonymous privacy level**. We register the tool at Canvas's "anonymous" privacy level, so Canvas withholds names, email addresses, and profile photos from every launch. - **A single, read-only Canvas** API **scope**. The Canvas Developer Key a district creates for DocAccess is enforced to one scope: read the file an instructor selected. It cannot list users, read enrollments, or touch grades. **What the LMS integration receives versus what it never asks for:** | Received From the LMS | Never Requested | | --- | --- | | Course ID (so the link is tied to the right course) | Course roster or enrollment list | | An opaque LMS user ID for the staff member who placed a link (no name or email) | Student names, emails, photos, or usernames | | The file the instructor selected and its ID | Grades, scores, gradebook columns, or assignment submissions | | The launching user's LMS role (instructor or student), sent by every LMS on every launch and used only to decide which screen to show | Any per-student record, identifier, or activity history | The public tool configuration at docaccess.com/api/lti/config is what your Canvas administrator installs, so the empty service-scope list can be verified directly. The same principle applies to any other LMS DocAccess connects to. --- ## The Fast Path to a Signed Agreement 1. **Get your state's NDPA version 2.2, Vendor-Specific version:** Your Student Data Privacy Consortium (SDPC) state alliance publishes it (your privacy or technology office will usually have it on hand). If your state does not have an alliance, use A4L's national [Standard National Data Privacy Agreement (NDPA) version 2.2](https://privacy.a4l.org/national-dpa/) together with the Vendor-Specific version from A4L. Please send us the form itself; the NDPA is licensed to A4L members, so we present our answers here rather than a copy of the template. 2. **Check whether your state already has a signed CivicPlus /** DocAccess **agreement:** Search the [SDPC Resource Registry](https://privacy.a4l.org/sdpc-resource-registry/) for DocAccess or CivicPlus. If an Originating LEA in your state has already executed the NDPA with a General Offer of Privacy Terms, you can subscribe to the very same terms by completing only Exhibit E (page 3, "Subscribing LEA") and sending it to [CivicPlus Legal](mailto:legal@civicplus.com). No new negotiation is needed. 3. **Fill in your district's fields; paste ours:** Complete the LEA name, address, designated representative, and notice contacts. Every Provider field and Exhibits A, B, E, F, and H are [pre-filled below](/legal-center/docs/docaccess-privacy-statement#our-prefilled-provider-answers) for an "Example Education Entity". Each block has a copy button. Leave Exhibit D blank (it is only used at termination) and leave signatures for e-sign. 4. **Send it to CivicPlus Contracts:** Email the completed form to [CivicPlus Contracts](mailto:civicpluscontracts@mail.lexion.ai) and copy your DocAccess account executive. Our contracts team and privacy officer review it against your state's version, confirm the answers, and return it for signature through e-sign. Because the answers are already agreed internally, review is typically a matter of days, not weeks. --- ## Our Pre-Filled Provider Answers Everything below maps one-to-one to a field or exhibit in the National Data Privacy Agreement (NDPA) version 2.2. > [!WARNING] > Note: > > These are CivicPlus's standard Provider answers for DocAccess, presented for a fictional "Example Education Entity" so you can see exactly how a completed form reads. Highlighted fields are the ones your district replaces. Our contracts team confirms the final wording against your state alliance's version, and the executed agreement is always the controlling document. ### Preamble & Signature Page #### Parties, Checkboxes, and Designated Representatives The first three pages of the NDPA identify the parties, set two checkboxes, and name who receives notices. Only the Local Educational Agency (LEA) fields (highlighted) change from district to district. > **Parties** > > - **LEA:** Example Education Entity, located at 123 School Street, Anytown, ST 00000 > - **Provider:** CivicPlus, LLC, located at 302 South 4th Street, Suite 500, Manhattan, KS 66502 > > **Checkboxes** > > - [x] **Special Provisions (Exhibit G).** Checked when your state alliance's version includes Supplemental State Terms. (Indiana's version 2.2 has none, so the box is left unchecked there.) > - [x] **General Offer of Privacy Terms (Exhibit E)**. Checked. CivicPlus offers the same terms to every other LEA in your state, so your neighbors can subscribe without renegotiating. > > **Designated representative for the LEA** > > - **Name / Title:** Jane Doe, Director of Technology and Data Privacy > - **Address:** 123 School Street, Anytown, ST 00000 > - **Phone / Email:** (000) 000-0000 / privacy@example-education-entity.k12.st.us > > **Designated representative for the Provider** > > - **Name / Title:** CivicPlus Privacy Team, Privacy Team > - **Address:** 302 South 4th Street, Suite 500, Manhattan, KS 66502 > - **Email:** privacy@civicplus.com > > **Notices to Provider** > > - **Name / Role:** CivicPlus, LLC, CivicPlus Contracts Team > - **Postal address:** 302 South 4th Street, Suite 500, Manhattan, KS 66502 > - **Email:** contracts@civicplus.com > > **Security notices to Provider (required per Section 5.3)** > > - **Name / Role:** CivicPlus, LLC, CivicPlus Information Security Team > - **Postal address:** 302 South 4th Street, Suite 500, Manhattan, KS 66502 > - **Email:** informationsecurity@civicplus.com > > **Notices and security notices to LEA** > > Your district's contracts contact and security operations contact. Most districts list their technology or digital-safety office for security notices and their business office or counsel for general notices. Security notices are delivered as support tickets under Security Annex Section 10, so list the contacts who receive your support tickets. > > > > Signatures are left blank; your privacy office sends the final copy for e-signature after review. ### Exhibit A #### Products and Services Exhibit A describes the Provider's services that collect, process, or transmit Student Data. > **Product / resource name:** DocAccess (a CivicPlus product) > > > > DocAccess converts documents that the LEA has published on its public website (and, where the LEA enables the feature, documents uploaded directly by LEA staff or placed in the LEA's learning management system through the DocAccess LTI integration) into accessible, screen-reader-friendly HTML in support of the LEA's obligations under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. The Services include: accessibility remediation and reformatting of documents; on-demand translation of document text at a reader's request; in-document search and question-answering over a single document; an optional live visual-assistance connection at a reader's request; aggregate, de-identified document usage analytics; and a document control center for LEA staff. > > > > The Services operate on the LEA's publicly available documents. They do not integrate with the LEA's student information system, do not create or require student accounts, and are not directed to students as users. Where the LEA enables the LTI 1.3 integration with its learning management system, the Services are registered at the platform's anonymous privacy level and request no LTI Advantage service scopes (no Names and Role Provisioning Services, no Assignment and Grade Services); students open accessible documents from the course without identifying themselves to Provider. ### Exhibit B #### Schedule of Student Data Exhibit B lists every category of student data and asks the Provider to mark each element Required (R) or Optional (O), or leave it unmarked if it is not collected. One column is used for the single resource "DocAccess". - **Not collected:** left unmarked on the form - **Optional:** collected only for the noted purpose - **Incidental only:** never collected as a data element; may appear inside a document the LEA publishes or uploads > **Data elements collected by DocAccess** > > | Category / Data Element | DocAccess | Notes | > | --- | --- | --- | > | **Application Technology Metadata:** - IP addresses of users, use of cookies - Other application technology metadata | Optional | - A session cookie is set only for LEA staff who sign in to manage documents. The Document Viewer requires no account and sets no identifying cookie. Edge infrastructure (CDN, load balancers) logs IP addresses for security and abuse prevention; the application does not store readers' exact IP addresses. - "Other" specified as: device, browser, and operating system information. | > | **Application Use Statistics:** Metadata on user interaction with application | Optional | Aggregate, de-identified document view counts with city-level geography, so the LEA can see which documents are used. | > | **Assessment:** Standardized test scores; observation data; voice recordings; other assessment data | Not collected | N/A | > | **Attendance:** Student school (daily) attendance data; student class attendance data | Not collected | N/A | > | **Communication:** Online communication captured (emails, blog entries) | Not collected | N/A | > | **Conduct:** Conduct or behavioral data | Not collected | N/A | > | **Demographics:** Date of birth; place of birth; gender; ethnicity or race; language information; other demographic information | Not collected | N/A | > | **Enrollment:** Student school enrollment; grade level; homeroom; guidance counselor; specific curriculum programs; year of graduation; other enrollment information | Not collected | N/A | > | **Parent/Guardian Contact Information, ID, and Name:** Address; email; phone; parent ID number; first and/or last name | Not collected | N/A | > | **Schedule:** Student scheduled courses; teacher names | Not collected | N/A | > | **Special Indicator:** English language learner information; low-income status; medical alerts/health data; student disability information; specialized education services (IEP or 504); living situations; other indicator information | Not collected | DocAccess serves the LEA's accessibility obligations at the document level. It never receives which individual students have a disability or an IEP/504 plan. | > | **Student Contact Information:** Address; email; phone | Not collected | N/A | > | **Student Identifiers:** Local (school district) ID number; state ID number; provider/App assigned student ID number; student app username; student app passwords | Not collected | There are no student accounts in DocAccess. The LMS integration stores only the course ID and an opaque LMS user ID for the staff member who placed a link; it runs at the anonymous privacy level and requests no roster or grade services. | > | **Student Name:** First and/or last | Incidental only | Left unmarked. A student's name may appear inside a document the LEA publishes or uploads (for example, a board agenda recognizing award winners). It is never extracted, indexed by person, or stored as a data element. | > | **Student In App Performance:** Program/application performance | Not collected | N/A | > | **Student Program Membership:** Academic or extracurricular activities a student may belong to or participate in | Incidental only | Left unmarked. May appear inside published content such as athletics rosters or honor-roll lists. | > | **Student Survey Responses:** Student responses to surveys or questionnaires | Not collected | N/A | > | **Student Work:** Student generated content (writing, pictures); other student work data | Incidental only | Left unmarked. Applies only if the LEA chooses to publish or upload a document that contains student work (for example, a literary magazine). | > | **Transcript:** Student course grades; course data; grades/performance scores; other transcript data | Not collected | N/A | > | **Transportation:** Student bus assignment; pick up and/or drop off location; bus card ID number; other transportation data | Not collected | N/A | > | **Other:** Other data collected | Not collected | No additional data elements. | > | **None:** No Student Data collected at this time | Not collected | Deliberately left unmarked. Because the LEA controls what it publishes or uploads, marking "None" would narrow the LEA's protection. Leaving it unmarked keeps the full NDPA in force for anything that does reach DocAccess. | > > > > **Storage outside the United States** > > DocAccess stores documents, accessible versions, and account data in U.S. AWS regions only. Two reader-initiated features send document text to a subprocessor transiently: on-demand translation and the live visual-assistance connection. Those subprocessors may process the text outside the United States solely to deliver the requested feature, under appropriate safeguards (see Exhibit H, item 3). The applicable countries are confirmed by the CivicPlus contracts team on request and entered here. ### Exhibits C & D #### Definitions; Special Instructions for Disposition > **Exhibit C (Definitions)** is part of the Standard Clauses and is not edited by either party. Our Exhibit H item 1 clarifies how the "Student Data" definition applies to content the LEA has already made public. > > > > **Exhibit D (Special Instructions for Disposition)** is intentionally left blank at signing. The NDPA reserves it for the LEA to use later if it wants disposition handled differently from Section 4.6. Our standard practice already meets Section 4.6: content is deleted on request or per contract within 30 days, and within 60 days of termination unless you direct otherwise. ### Exhibit E #### General Offer of Privacy Terms Exhibit E lets other LEAs in the same state adopt this exact agreement by signature alone. CivicPlus signs it so that the first district in a state clears the way for every district after it. > **Originating LEA:** Example Education Entity > > **Provider name:** CivicPlus, LLC > > **Resource name(s):** DocAccess > > **Email for Subscribing LEAs to send signed Exhibit E:** legal@civicplus.com > > **Provider signature:** Executed by an authorized CivicPlus signatory at the same time as the DPA. > > **If you are a Subscribing LEA:** complete page 3 of Exhibit E with your district's name, designated representative, and notice contacts, sign it, and send it to legal@civicplus.com together with your DocAccess service agreement. Your subscription takes effect once we acknowledge receipt. ### Exhibit F #### Adequate Cybersecurity Frameworks The Provider marks one or more recognized frameworks and may describe its security program in the optional space provided under Section 5.3. > **Framework(s)** > > - [x] NIST Cybersecurity Framework (CSF) > - [ ] NIST SP 800-53 > - [ ] NIST SP 800-171 > - [ ] ISO 27000 series (our program aligns with ISO 27001 control families; we do not hold the certification) > - [ ] CIS (Center for Internet Security) Critical Security Controls > - [ ] Cybersecurity Maturity Model Certification (CMMC) > > **Optional security programs and measures (Section 5.3)** > > Provider maintains an information security program that includes the administrative, physical, and technical safeguards set out below. The design of that program has been examined in Provider's SOC 2 Type I examination (unqualified opinion covering the Security and Confidentiality Trust Services Criteria; report available under NDA). The safeguards are: (1) encryption of Student Data in transit and at rest using industry-standard protocols; (2) role-based access controls applying the principle of least privilege; (3) network protections including firewalls and intrusion detection/prevention; (4) logging, monitoring, and a documented incident response plan; (5) regular vulnerability scanning and periodic third-party penetration testing; (6) background checks and security training for personnel with access to Student Data; (7) secure software-development practices; and (8) security assessments of Subprocessors. ### Exhibit G #### Supplemental State Terms Exhibit G belongs to your state alliance, not to the Provider. Use it exactly as it appears in your state's version and check the "Special Provisions" box in the Preamble if it contains terms. The Indiana NDPA version 2.2, for example, states "None." Where a state's supplemental terms interact with our Exhibit H clarifications, our contracts team notes it during review. ### Exhibit H #### Description of "Agreed To" Changes Every clarification CivicPlus proposes is consolidated here, as the NDPA's structure intends. None of them modify the body of the Standard Clauses, and all of them exist because DocAccess works on documents the LEA has already published. > LEA and Provider agree to the following additional or replacement terms and modifications. Pursuant to the "Priority of Agreements" provision of this DPA, in the event of a conflict these terms control over the SDPC Standard Clauses and the Supplemental State Terms in Exhibit "G". > > 1. **SCOPE OF COVERED DATA (clarifying Sections 1.3 and 2.1 and the definition of "Student Data" in Exhibit "C").** This DPA applies only to Student Data that the LEA actually provides to, or that Provider actually collects, receives, accesses, maintains, or processes on the LEA's behalf in connection with the Services. "Student Data" does not include (i) information contained in documents or other content that the LEA has made, or directs Provider to make, publicly available; or (ii) aggregated or De-Identified Data. This reflects that the Services operate on the LEA's publicly available documents. For the avoidance of doubt, the security, confidentiality, use-restriction, and disposition obligations of this DPA apply to all document content Provider processes for the LEA, whether or not that content meets the definition of "Student Data". > 2. **PROVIDER INTELLECTUAL PROPERTY (addition to Section 2.1).** Nothing in this DPA affects Provider's ownership of, or rights in, its own Services, software, systems, models, methodologies, templates, and know-how, including any accessibility-remediated, reformatted, or translated output generated by the Services, or any aggregated or De-Identified Data, all of which remain the property of Provider. The LEA's ownership of Student Data under Section 2.1 is otherwise unaffected. Nothing in this item permits Provider to use Student Data to develop, train, or improve any model or service, which is governed by item 8 below. > 3. **SUBPROCESSORS; INTERNATIONAL PROCESSING (clarifying Sections 2.3 and 5.1).** Upon the LEA's written request, Provider will make available a current list of its Subprocessors. Provider will additionally give the LEA notice of new Subprocessors and an opportunity to object, on the terms set out in Sections 6.2 and 6.3 of the CivicPlus Data Processing Addendum, which are incorporated by reference and are not narrowed by this item. Provider's translation and visual-interpretation Subprocessors may process Student Data outside the United States solely to the extent necessary to provide features requested or enabled through the Services (such as translation), subject to appropriate safeguards; the applicable countries will be identified in Exhibit "B". > 4. **DISPOSITION - BACKUP ARCHIVES (addition to Section 4.6).** In addition to the retention already permitted under Section 4.6, Provider may retain Student Data in routine, secured backup archives created in the ordinary course of business, which will be deleted in accordance with Provider's standard backup-retention cycle. Such retained Student Data will remain subject to the protections of this DPA for so long as it is retained and will not be used for any other purpose. > 5. **SECURITY AUDITS - THIRD-PARTY REPORTS (clarifying Section 5.2).** Provider will satisfy the audit-report obligation in Section 5.2 by making available, upon the LEA's written request and execution of a confidentiality agreement, a copy or summary of its most recent independent third-party audit report or certification (such as SOC 2), subject to reasonable and appropriate redaction. Provider is not required to produce its full unredacted report or to submit to on-site audits so long as such third-party reports are made available. > 6. **MATERIAL BREACH AND CURE (clarifying "Term and Termination").** A breach of a material term of this DPA entitles the non-breaching party to terminate only if the breaching party has failed to cure the breach within thirty (30) days after its receipt of written notice describing the breach in reasonable detail. Nothing in this Section limits the LEA's right to suspend its use of the Services during such period. > 7. **PRIORITY OF AGREEMENTS; LIMITATIONS OF LIABILITY (clarifying "Priority of Agreements").** Notwithstanding anything to the contrary, the limitations of liability, disclaimers, and insurance provisions set forth in the Service Agreement and any Master Services Agreement between the parties, in each case as in effect on the effective date of this DPA and as amended only by written agreement of both parties, survive and apply to this DPA and to any claims arising under or relating to it. No unilateral amendment to the Service Agreement or Master Services Agreement alters this DPA. > 8. **NO SECONDARY USE; NO MODEL TRAINING (addition to Sections 2.1 and 3.1).** Provider will not sell, rent, or share Student Data; will not use Student Data for advertising, marketing, or profiling; and will not use Student Data to develop, train, fine-tune, evaluate, or improve any artificial-intelligence or machine-learning model, whether Provider's own or a third party's. Any AI processing of document content is performed on request and scoped to the request. This item controls over any provision of the Service Agreement or Master Services Agreement permitting Provider to collect, analyze, or use Customer Data, or data derived from it, to improve or enhance the Services. > 9. **RELATIONSHIP TO THE CIVICPLUS DATA PROCESSING ADDENDUM.** With respect to Student Data and to all document content Provider processes for the LEA under the Services, Provider acts solely as a processor on the LEA's documented instructions. The provisions of the CivicPlus Data Processing Addendum addressing Resident Account Data, Independent Controller Data, Co-Controlled Data, and cross-customer account interoperability (Sections 3.3, 3.4, 12.7(b)-(d), and 14) do not apply to the Services provided to the LEA. In the event of a conflict between this DPA and the CivicPlus Data Processing Addendum or the CivicPlus Security Annex, this DPA controls, except as to the limitations of liability addressed in item 7. > 10. **DISPOSITION NOT CONDITIONED ON ACCOUNT STATUS (addition to Section 4.6).** Provider's obligations to return or dispose of Student Data under Section 4.6 apply regardless of any amounts outstanding under the Service Agreement or Master Services Agreement, and Provider will not withhold, discard, or refuse to return Student Data on the basis of non-payment or other breach by the LEA. #### Why each Exhibit H item is there, in one line - **Scope of covered data:** keeps the obligations aligned with data actually exchanged. Content your district already published isn't re-classified as confidential by the act of making it accessible. Everything you do provide stays fully protected. - **Provider IP:** your ownership of Student Data is untouched; this only confirms CivicPlus keeps its platform and the remediated output format. - **Subprocessors:** the current list is published at the [CivicPlus Legal Center](/legal-center/docs/civicplus-subprocessors). Translation and live visual assistance are the only features that can route text outside the U.S., and only when a reader asks for them. - **Backup archives:** a customary exception so routine encrypted backups don't put us in breach before the retention cycle purges them. - **Third-party reports:** SOC 2 under NDA satisfies the annual audit requirement, which is standard for a shared cloud service. - **Cure period:** 30 days to fix a material breach before termination, while you keep the right to suspend use immediately. - **Liability:** the commercial terms in your CivicPlus service agreement continue to govern liability, so the privacy and commercial terms work together. - **No secondary use:** the no-sale, no-advertising, and no-model-training commitments are contractual, not just policy, and they override the general service-improvement language in the commercial agreement. - **Relationship to the CivicPlus DPA:** our general customer DPA is written for municipal resident accounts. For your district, this agreement governs and the resident-account provisions are switched off. - **Disposition not conditioned on account status:** a billing dispute never becomes a reason to hold or discard student records. --- ## Related Documentation - [CivicPlus Privacy Policy](/legal-center/docs/civicplus-privacy-policy) - [CivicPlus Subprocessors](/legal-center/docs/civicplus-subprocessors) - [Master Services Agreement](/legal-center/docs/master-services-agreement) - [DocAccess Voluntary Product Accessibility Template® (VPAT®)](https://docaccess.com/vpat) - [CivicPlus Data Processing Addendum](/legal-center/docs/civicplus-data-processing-addendum) - [CivicPlus Security Annex](/legal-center/docs/civicplus-security-annex) --- ## Who to Contact - **Send a completed NDPA** to the [CivicPlus Contracts Team](mailto:civicpluscontracts@mail.lexion.ai). Copy your DocAccess account executive. - **Subscribe using Exhibit E** by contacting [CivicPlus Legal](mailto:legal@civicplus.com). - **Privacy questions** can be directed to the [CivicPlus Privacy team](mailto:privacy@civicplus.com). - **For Security notices**, contact the [CivicPlus Information Security team](mailto:informationsecurity@civicplus.com). - **SOC 2 Report:** Available under NDA. [Contact Support](https://www.civicplus.help/docaccess/docs/contact-support) to request. Portable Document Format. Hypertext Markup Language. The language used to define the content of the site in a structurally meaningful manner. Americans with Disabilities Act. The Americans with Disabilities Act is a civil rights law that prohibits discrimination based on disability. It guarantees equal opportunity for individuals with disabilities in public accommodations, employment, transportation, state and local government services, and telecommunications. Internet Protocol.A set of rules for communication over the internet or a local network, such as sending mail, streaming videos, or connecting to a website. Learning Management System. Transport Layer Security. A widely adopted security protocol designed to help privacy and data security for communications over the internet. A primary use of TLS is to encrypt communications between web applications and servers, such as web browsers loading a website. Amazon Web Services. A cloud omputing platform that offers a wide range of on-demand services. Multi-Factor Authentication Artificial Intelligence Systems and Organization Controls Non-Disclosure Agreement. National Institute of Standards and Technology Family Educational Rights and Privacy Act. Application Programming Interface. A set of rules that allows programmers to develop software for a particular operating system without having to be completely familiar with that operating system. Identification or Identifier. Limited Liability Company. Content Distribution Network Not Applicable Application. A program that performs a particular task or set of tasks. : International Organization for Standardization.