Strategic Testing Protocol

🎯 Objective

Secure real-world feedback for a K-12 writing app without violating student privacy laws (SOPIPA, AB 1584, SOPPA, BIPA).

Key Assets

🎓

University Partner

School of Education Professor

👨‍👩‍👧

Family Network

Teachers & Educators

🏫

School Access

Parent Connection

PHASE 1: The "Research Shield" Strategy

The Concept

Instead of a commercial "beta test," frame the pilot as a University Research Study. This leverages academic partnerships to bypass standard commercial hurdles.

⚖️ Legal Mechanism

FERPA "Studies" Exception (34 CFR § 99.31(a)(6))

This allows schools to share data with researchers for the purpose of improving instruction without individual parent consent (if IRB approved).

📋 Action Plan

1

IRB Proposal

Ask the university professor to sponsor a study titled: "Efficacy of AI-Assisted Feedback in K-12 Writing"

2

EdTech Lab Credibility

Request "hosting" or "vetting" through the university EdTech Lab to gain official letterhead credibility.

3

The Pitch

"We are conducting a university research study on AI feedback standards. Would your school participate as a pilot site?"

PHASE 2: Testing Pathways

Distinct legal categories for testing. You must be explicit about which one you are requesting.

PATH A The "Sandbox" (Internal / Alpha)

Users:

Family members (teachers), University Professor

Data:

Dummy Data Only. Anonymized past essays or "fake" essays.

Legal Status:

🟢 GREEN LIGHT - No student PII touched; no district contract needed.

Goal:

Calibrate AI tone, check standards alignment, refine UI.

PATH B The "Classroom" Pilot (External / Beta)

Users:

Partner school, TOSA (Teacher on Special Assignment)

Data:

Real student writing

Legal Status:

🟡🔴 YELLOW/RED - Requires DPA or Research MOU

Technical Requirement:

Must have "Anonymous Rostering" OR signed contract before login.

PHASE 3: Operational Roadmap

1 Outreach & "The Ask"

Target Audience: Instructional Coaches, TOSAs, or Department Heads (not just classroom teachers).

📝 Sample Script (Research Focus):

"Hi [Name], I'm working with Dr. [Name] at [University] on a study regarding AI feedback alignment with AB 1121 Literacy Standards. We are looking for one pilot classroom to test the tool. I'm not selling anything—I just need an expert educator's reality check."

Tip: Attend CUE (Computer-Using Educators) conferences to find early adopters.

2 Incentives (The "Gift" Trap)

🚫 PROHIBITED

Cash payments to public employees (violates Gov Code 1090 & district policies)

✓ ALLOWED

• "Free for Life" License
• Small gift cards (under $25)
• DonorsChoose credits
• PD certification letter

3 The Legal Wrapper

Even for free pilots, use a paper trail to protect both parties.

📄 Pilot MOU (Memorandum of Understanding)

A simple 2-page document stating:

Cost: Free
Data Ownership: School owns data; Developer owns software
Termination: School can demand data deletion at any time

🔒 The "Click-Through" Gate

UI Requirement: Teachers cannot create a class until they check:

☐ I certify that I have permission from my administration to use this pilot software with students.

PHASE 4: Technical Compliance Strategy

1 The "Anonymous Roster" (Bypassing Rostering Nightmares)

Feature: Create a system where the teacher generates generic accounts (e.g., Student_Alpha, Student_Beta) rather than using real names/emails.

Workflow:

App generates 30 anonymous codes
Teacher maps Student_Alpha to "John Doe" on physical paper (kept at school)
Students log in with codes only

✓ Result: Developer never possesses PII, significantly lowering SOPIPA/SOPPA liability.

2 Illinois Prep (SOPPA/BIPA)

📋 Data Inventory

Create a public-facing list of every data point collected (e.g., "Essay Text", "Grade Level") to satisfy Illinois transparency laws.

View Data Inventory →

🚫 Biometrics Disabled

Explicitly disable keystroke dynamics or voice analysis for IL users to avoid BIPA class-action lawsuits.

✓ TSA Status: No biometrics collected

QUICK REFERENCE: Testing Pathway Decision Tree

❓ Are you using real student data?

NO → Use Sandbox Mode (Path A). No contracts needed. ✅

YES → Continue to next question...

❓ Do you have a signed DPA or Research MOU?

YES → Proceed with Classroom Pilot (Path B). ✅

NO → Use Anonymous Rostering to avoid PII collection. ⚠️

📁 Related Documents

📄 Pilot MOU Template 📄 Research Collaboration Letter (IRB) 📄 Sandbox Mode Documentation 📄 Anonymous Rostering Guide 📄 Illinois Compliance Guide 📄 SOPPA Data Inventory