Privacy Policy

Career Solutions, Inc. (CSP) shall protect and maintain the security of customers’ student Personally Identifiable
Information (PII) as defined by the Family Educational Rights and Policy Act (FERPA) with commercially reasonable
security measures commensurate with the sensitivity of such student PII.

CSP has implemented policies and procedures for its Systems that maintain student PII to allow access only to those
individuals or software programs that have been authorized to access such student PII. CSP personnel are authorized
to access student PII on a need-to-know basis based on specific job functions. Authentication occurs through the use
of unique anonymous user identifications. All CSP personnel with access to CSP systems are assigned a unique user
identification to log in to such systems. CSP personnel maintain their own passwords. Any CSP software that
accesses student PPI requires a CSP assigned user identification and user-owned password. CSP personnel are
prohibited from sharing identifications and passwords.

CSP will not authorize access to customers’ student PII to any of its agents, affiliates, contractors, subcontractors or
auditors unless such agent, affiliate, contractor, subcontractor or auditor has entered into a written Vendor Data
Sharing/Privacy agreement with CSP agreeing to protect the confidentiality and security of each student PII. If
required by customer, CSP will not authorize access to customers’ student PII to any of its agents, affiliates,
contractors, subcontractors or auditors unless such agent, affiliate, contractor, subcontractor or auditor has entered
into a written Vendor Data Sharing/Privacy agreement with CSP and customer agreeing to protect the confidentiality
and security of each student PII.

CSP has implemented policies, procedures and security measures to protect against reasonable foreseeable
unauthorized access to, or disclosure of, customers’ student PII and to prevent other reasonably foreseeable events,
the result of unauthorized access to or disclosure of PII, that may result in substantial harm to a customer or any
individual student identified in such PII.

CSP will not distribute, repurpose or share customers’ data with anyone or any system not used for providing services
to customers.

CSP will not allow unauthorized access to or allow the release of customers’ student PII to any individual or entity.
Subcontractors of CSP providing services related to the support maintenance and security of CSP software products
are authorized to access customer data and customers’ student PII only within the terms of the Vendor Data
Sharing/Privacy Agreement executed between CSP and the subcontractor.

CSP has implemented policies and procedures addressing a potential Data Breach and a Data Breach response plan,
in doing so is committed to comply with all applicable federal and state laws that require notification to individual,
entities, state and federal agencies in the event of a Data Breach.

CSP has implemented policies and procedures to address the storage, retention and disposition of all customer data.

Information Required for Teacher and Student Usage of CSP Online Software

For purposes of setting up accounts and allowing the software to report student responses and grades to teachers
and students, only the following information is needed.

District Accounts

District Name, Administrator first name, last name and email address.

Teacher Accounts

School or Site Name, Teacher’s first name, last name and email address.

Student Accounts

Teacher’s Name, Class Name, Student’s first name, last name and email address.

Email Constraints to CSP Online Software to be Addressed by Education Institutions

In order for students to change their password in an online program, the URL for the program purchased should be
whitelisted by the school.

May 3, 2018
January 1, 2019
March 15, 2019
Revised January 1, 2023