Privacy & Data Compliance

Clarity 360 is designed from the ground up to be fully compliant with the Family Educational Rights and Privacy Act (FERPA). We serve as a data processor on behalf of school districts — the district remains the data controller and retains all rights over educational records.

What We Collect

Clarity 360 collects only the minimum data necessary to deliver survey results to your district. Here is a complete list of what is and is not stored:

How Anonymity Works

Every participant — student, teacher, staff member, or parent — is assigned a randomly generated session ID (a UUID) at the start of their interview. This ID has no connection to any named person, email address, student ID, or device. There is no mechanism in our system to re-identify a respondent from their session ID.

Survey tokens (SCL-XXXXXX) identify which role group a response belongs to — for example, “students at Lincoln Elementary” — but are never attached to individual respondent data. A token cannot be used to identify who responded or what any individual said.

Small group anonymity limitation: In deployments where a role group has very few respondents (typically fewer than 5), individual responses may be identifiable by context even without direct identifiers. Districts should consider this when deploying surveys to small teams or departments and may choose to suppress reporting for groups below a minimum threshold.

Voice and Audio

Clarity 360 uses voice interaction to guide participants through surveys. Audio travels over an encrypted connection established directly between the participant’s browser and OpenAI, where it is transcribed in real time. It does not pass through Clarity 360’s servers. Only the resulting text is sent to us, and only that text is stored. Clarity 360 never records, stores, or receives audio.

The microphone is closed until the participant opens it. Each answer is recorded only while they hold the microphone open, and it closes again as soon as they finish.

Clarity 360 and Clarity Workplace include a built-in safety response. If language in a participant’s response suggests they may be struggling, the platform immediately:

1. Provides the participant with crisis support resources in real time, including the 988 Suicide & Crisis Lifeline.
2. Generates an anonymous alert to Engaging Education Solutions noting that a concern was detected within a participant group.

No identifying information is included in this alert. The alert contains only: an anonymous session ID, the participant group token, and the school or organization ID. No names, emails, recordings, or response content are ever shared.

The Children’s Online Privacy Protection Act (COPPA) applies to online services that collect personal information from children under 13. Because Clarity 360 does not collect any personal information from any participant — including students — COPPA’s data collection requirements do not apply. No names, email addresses, device identifiers, or any other personal information are collected from students at any age.

School Climate surveys are currently deployed only to high school students (grades 9–12). All survey deployments are administered by district personnel through their school’s authorized Clarity 360 account.

All data is stored in Google Cloud Firestore, hosted in the United States. Data is encrypted at rest and in transit using industry-standard TLS encryption. Access to raw response data is restricted to authorized Engaging Education Solutions personnel and is never sold, shared, or used for any purpose other than delivering survey results to your district.

Data Retention

Survey response data is retained for the duration of your district’s active subscription and for 90 days following subscription termination, after which it is permanently deleted. Districts may request early deletion of their data at any time by contacting knoell@engagingpd.com.

Clarity 360 uses OpenAI’s Realtime API exclusively for real-time voice transcription during survey sessions. Our use of OpenAI is governed by the following commitments:

• →OpenAI processes participant audio solely for real-time transcription — no other processing occurs.
• →Session data is not logged or stored in Clarity 360's OpenAI organization. Under OpenAI's API terms, inputs and outputs may be retained by OpenAI for up to 30 days solely to detect abuse of their platform, and are deleted after that period.
• →Clarity 360 has requested Zero Data Retention from OpenAI, which removes that 30-day window entirely. This page will be updated when it is in force.
• →No participant data — including transcribed responses — is used to train any AI model, by Clarity 360 or any third party. OpenAI's API terms exclude API data from model training by default.
• →Data is never sold, licensed, or shared with any party for any purpose other than delivering your district's survey results.

For OpenAI’s enterprise data handling commitments, see openai.com/enterprise-privacy.

As the data controller, your district retains the following rights:

• →The right to request a complete export of all response data associated with your district at any time
• →The right to request permanent deletion of all data associated with your district at any time
• →The right to restrict data processing at any time by deactivating your district's account
• →The right to receive notification in the event of a data breach affecting your district's data within 72 hours of discovery

To exercise any of these rights, contact Dr. Christopher M. Knoell at knoell@engagingpd.com.

Clarity 360 uses the following third-party services in the delivery of our platform:

No student data is shared with any third-party service.

For questions about this privacy policy, FERPA compliance, or data practices, contact:

Version 2.0 · April 2026