Academic Therapy Publications, Inc. is committed to protecting personally identifiable information ("PII") or protected health information ("PHI") from loss, misuse, and unauthorized access, disclosure, alteration or destruction.

The following Privacy of Minors and Students Statement ("Policy") describes how Academic Therapy Publications, Inc. and ATP Assessments ("ATP", "we", "us", or "our") collects, protects, uses and shares data through our interactions with users of the ATP Online web site located at https://atponline.academictherapy.com ("ATP Online", "Service(s)"). ATP Online is made available to qualified clinicians, therapists, examiners, and other professionals ("Customer(s)", "School Customer(s)", "Educator(s)", "Practitioner(s)", "you", "your") with access to "Personal Data" including: personal information ("PI"), personally identifiable information ("PII"), or Protected Health Information ("PHI") about their clients, students, or patients ("Data Subject(s)", "Examinee(s)").

We reserve the right to revise this Policy periodically to reflect changes in our Services and in order to comply with changes in the law. Any such revisions are effective immediately upon posting. Your use of the Services subsequent to such posting constitutes your acceptance of such revisions. The date at the top of this document shall indicate the most recent date of this Policy revision.

ATP offers a wide range of products and services that are designed for use by Practitioners who work directly with minors and students of varying ages. We recognize the sensitive nature of Personal Data concerning minors and students, where the information may be contained in a school's educational records. This Personal Data is protected under either or both of the following federal statutes: the Children's Online Privacy Protection Act ("COPPA") and the Family Educational Rights and Privacy Act, including the Protection of Pupil Rights Amendment ("FERPA"). ATP Online complies with all applicable provisions of both COPPA and FERPA.

We provide this Policy to our School Customers to ensure that, in providing Personal Data to us about your Examinees and thus providing your COPPA or FERPA consent, you have full information and assurance that our practices comply with COPPA and FERPA.

COPPA
COPPA permits a school, acting in the role of "parent," to provide required consents regarding the sharing of Personal Data of students who are under the age of 13. Where a school or one of its Practitioners is a Customer of ATP Online, we rely on this form of COPPA consent for the Personal Data that is transmitted to us by the Practitioner.

ATP Online never collects information directly from children under the age of 13 for any of its products or services. Only qualified professionals may use ATP Online to create, maintain or transmit Personal Data about children under age 13. To the extent COPPA applies to information we collect, we store and process such information for educational purposes only, at the direction of the Practitioner or partnering School Customer, and on the basis of educational institution consent.

For additional questions regarding COPPA please use the link below:
Federal Trade Commission's Complying with COPPA: Frequently Asked Questions

FERPA
FERPA permits a school to provide educational records (including those that contain students' Personal Data) to certain service providers without requiring the school to obtain specific parental consent to do so. FERPA permits this where the service provider acts as a type of "school official" by performing services, for example, that would otherwise be performed by the school's own employees. We fulfill FERPA requirements for qualifying as a school official by, among other steps, giving our School Customers direct control with respect to the use and maintenance of the education records at issue (including all associated Personal Data about the Examinee), and refraining from re-disclosing or using this Personal Data except for purposes of providing our products and services to our School Customers. By providing ATP Online to Practitioners working on behalf of educational institutions, we are a "school official" under FERPA and we comply with FERPA by relying on this form of consent.

For additional questions regarding FERPA please use the link below:
U.S. Department of Education's Privacy Technical Assistance Center

Other Forms of Consent
"Eligible Students" are those students to whom the rights accorded to parents under FERPA have transferred. According to 34 CFR § 99.5(a)(1) an Eligible Student refers to a student who is 18 years of age or older OR attends an institution of postsecondary education. For Practitioners working on behalf of postsecondary educational institutions bound by FERPA, ATP may rely on consent given directly by the Eligible Student to the institution.

For select products and services, such as research studies, ATP may additionally require Practitioners to obtain signed and dated written consent from the parent or Eligible Student before the Examinee's Personal Data is disclosed to ATP.

ATP Online strives to be a valuable resource and provide support to our valued Customers to help them achieve their own compliance with all applicable laws governing their use and disclosure of Personal Data for Examinees of any age. Understanding consent requirements for disclosing Personal Data about minors and students can be a complex undertaking. You should ensure that any service providers which you work with, have a highly robust approach to data protection, understand their obligations under the law, and are well prepared to meet them. However, compliance with the law regarding the use and disclosure of Personal Data is ultimately your responsibility. You, as the Customer, have specific legal obligations and are best equipped to determine which laws are applicable to your Examinees.

According to our Terms of Use, our Customers must comply with all applicable laws including COPPA and FERPA and the required form of consent must be sought and obtained by the Practitioner prior to disclosing an Examinee's Personal Data through your use of ATP Online. If we discover that we have collected Personal Data in a manner inconsistent with the requirements of COPPA, FERPA, or any applicable laws, we will either (a) delete the Personal Data or (b) promptly seek requisite consents before taking further action concerning the Personal Data.

For more information including product-specific details about the Personal Data we collect, how we use it, reasons we share it, and how you may access and control it, please refer to our General Privacy Statement and our Terms of Use.