Question · COPPA
How do we prove an under-13 AI tutor didn't retain student data after the 2025 COPPA Rule?
COPPA requires notice and verifiable parental consent before collecting, using or disclosing personal information from children under 13.
01 / The answer
The short answer
You prove it with records of your own data practices. The amended Rule requires a written data retention policy stating why you collect children's data, the business need to keep it and when you delete it, and that policy must appear in your online notice. Keep deletion logs showing data was removed on schedule, your written information security program, and the contracts and deletion confirmations for any AI provider or other third party that received the data. The Rule allows keeping children's data only as long as reasonably necessary, never indefinitely.
02 / The rule
What COPPA requires
COPPA requires notice and verifiable parental consent before collecting, using or disclosing personal information from children under 13. The 2025 amendments, enforced from April 22, 2026, add separate parental consent for disclosures to third parties, including disclosures to train AI, plus written retention and security programs.
- 01Post clear notice and get verifiable parental consent before collecting, using or disclosing a child's personal information.
- 02Get separate verifiable parental consent before disclosing a child's personal information to third parties, unless the disclosure is integral to the service.
- 03Keep and publish a written data retention policy; keep children's data only as long as reasonably necessary, never indefinitely.
- 04Establish, implement and maintain a written information security program suited to the sensitivity of children's data.
03 / Records
Records to keep
- 01Verifiable parental consent records, with separate third-party disclosure consent
- 02Written retention policy published in the online notice
- 03Written information security program and periodic risk assessments
- 04Inventory of third parties receiving children's data and their purposes
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
SOURCES
Go back to the source
Federal Register via GovInfo
Federal Register public inspection
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Related: COPPA: the full guide · Does the 2025 COPPA amendment apply to our ed-tech tutor product? · Is there a COPPA school-authorization exception for ed-tech in 2026?