⚖️ California Education Code Compliance
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CALIFORNIA EDUCATION CODE COMPLIANCE

Advanced EdTech Regulatory Requirements

The Scribe Academy

Last Updated: December 2024

1. SOCIAL CONTENT REVIEW (Education Code § 60040-60050)

✓ IMPLEMENTED AI Diversity Requirements in Prompts

Requirement Summary

AI-generated content must accurately portray California's cultural and racial diversity and avoid adverse reflections on any group.

Prohibited Content:

  • Commercial Brands: No brand names in prompts (e.g., "Write about buying Nikes")
  • Religious Indoctrination: No prompts encouraging or discouraging any religion
  • Adverse Reflections: No content reflecting adversely on persons based on race, color, creed, national origin, ancestry, sex, disability, or occupation
  • Gender Stereotypes: No implicit gender assumptions (e.g., "doctor and his nurse")

Implementation in AI Prompts:

All AI system prompts include diversity requirements:

DIVERSITY REQUIREMENTS (California Ed Code § 60040-60050):

- Use gender-neutral language and diverse name examples

- Represent California's cultural and racial diversity

- Avoid commercial brand names

- No religious content or stereotypes

- No adverse reflections on any group

2. ANTI-CENSORSHIP (AB 1078 & Right to Read Act)

✓ IMPLEMENTED Protected Identity Content Distinction

The Conflict

Content moderation must distinguish between harmful/explicit content and protected identity topics. Blocking keywords like "gay" or "racism" violates California civil rights laws.

Implementation:

  • No keyword blocking of identity terms (LGBTQ+, race, religion, disability)
  • Context-aware moderation: AI evaluates intent, not just keywords
  • Protected topics allowed: Essays about identity, civil rights, social justice
  • Only block: Explicit sexual content, violence, threats, harassment

AI Moderation Guidelines:

✓ ALLOWED

  • • Essays about LGBTQ+ identity
  • • Discussion of systemic racism
  • • Religious/cultural experiences
  • • Disability advocacy
  • • Immigration stories

✗ BLOCKED

  • • Explicit sexual content
  • • Graphic violence
  • • Threats or harassment
  • • Self-harm instructions
  • • Hate speech targeting groups

3. SCIENCE OF READING (AB 1121 & Literacy Standards)

✓ COMPLIANT Evidence-Based Literacy Alignment

Requirement

Writing feedback must align with the California ELA/ELD Framework and avoid "Three Cueing" (guessing words based on pictures/context).

Our Approach:

  • Focus on writing skills: Organization, evidence, clarity, grammar
  • No "guessing" encouragement: We don't teach reading strategies
  • Vocabulary support: Dictionary feature explains word meanings and morphology
  • Rubric-based feedback: Structured evaluation criteria

Feedback Focus Areas:

Organization

Structure & flow

Evidence

Supporting details

Clarity

Clear expression

Grammar

Conventions

Vocabulary

Word choice

Voice

Engagement

4. DATA BREACH TIMELINES (SB 446 / AB 1584 Update)

✓ DOCUMENTED Incident Response Plan Updated

New Hard Deadlines (Effective Jan 1, 2026)

30

DAYS

Notify school/user after breach discovery

15

DAYS

Notify CA Attorney General (if 500+ CA residents affected)

Incident Response Plan:

  1. Day 0: Breach discovered - Immediately contain and assess
  2. Days 1-7: Forensic investigation, determine scope
  3. Days 8-14: Prepare notification materials
  4. Day 15: Notify CA Attorney General (if 500+ affected)
  5. Days 15-30: Notify all affected schools/users
  6. Ongoing: Remediation and monitoring

5. DATA DESTRUCTION STANDARDS (NIST 800-88)

✓ IMPLEMENTED Irrecoverable Destruction Capability

Requirement

Student records (Class 3 Disposable Records under Title 5) require irrecoverable destruction, not just "unlinking."

Our Implementation:

  • Full User Wipe: Permanently deletes all Firestore documents (profile, state, reports, activity logs)
  • Firebase Auth Deletion: Optional deletion of authentication record
  • No soft delete: Data is permanently removed, not just marked as deleted
  • Crypto-shredding ready: Firebase uses encryption at rest; key rotation available

NIST 800-88 Alignment:

Method Description Status
Clear Logical deletion (document removal) ✓
Purge Physical/cryptographic destruction ✓ (via Firebase)
Destroy Physical media destruction N/A (cloud)

6. WILLIAMS ACT (Sufficiency of Materials)

✓ COMPLIANT Equal Access Licensing Model

Requirement

If adopted as a primary classroom tool, every student must have equal access. No "some students buy premium" model.

Our Licensing Model:

  • Site/District Licenses: All students in a class/school get equal access
  • No feature gating: All educational features available to all licensed students
  • Teacher-controlled: Teachers manage student access uniformly
  • No in-app purchases for students: Brain Points are earned, not bought

License Types:

Type Description Williams Compliant
Classroom License All students in a class ✓
School License All students in a school ✓
District License All students in a district ✓
Individual/Family Home use (not classroom adoption) N/A

COMPLIANCE SUMMARY

Requirement Code/Law Status
Social Content Review (Diversity) Ed Code § 60040-60050 ✓
Anti-Censorship (Protected Content) AB 1078 ✓
Science of Reading Alignment AB 1121 ✓
Data Breach Timelines SB 446 / AB 1584 ✓
Data Destruction Standards NIST 800-88 / Title 5 ✓
Williams Act (Equal Access) Ed Code § 60119 ✓

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Document Version: 1.0 | Last Updated: December 2024