Wisconsin Student Data Privacy Agreement (WSDPA)

Version: 2.0 (Improved) | Date: December 2025
Template: WI-NDPA V1 | Provider: NAS (Neeraj's AI Services)
Contact: Dr. Neeraj Agrawal, nas.neeraj@gmail.com

PARTIES

Local Education Agency (LEA):

[School District/School Name]
[Address]
[City, State ZIP]
[Contact Person]
[Title]
[Email]
[Phone]

Provider:

NAS (Neeraj's AI Services)
[Business Address - To be added upon LLC formation]
Wisconsin, United States
Contact: Dr. Neeraj Agrawal, Founder & CEO
Email: nas.neeraj@gmail.com
Website: nasneeraj.com

RECITALS

WHEREAS, the LEA is a Local Education Agency as defined by the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and Wisconsin Statute § 118.125; and

WHEREAS, the Provider offers Student Information System (SIS) and Learning Management System (LMS) services that may involve the collection, storage, and processing of student data; and

WHEREAS, the documents and data transferred from LEAs and created by the Provider's Services are subject to Wisconsin state student privacy laws, including Wis. Stat. § 118.125 (Pupil Records) and the Wisconsin Student Data Privacy Agreement (WSDPA); and

WHEREAS, the parties wish to enter into this Agreement to ensure compliance with all applicable federal and state student privacy laws;

NOW, THEREFORE, the parties agree as follows:

1. DEFINITIONS

1.1 "Student Data"

Means any information that directly relates to a student that is maintained by the LEA and may include, but is not limited to:

• Personally Identifiable Information (PII)
• Educational records as defined by FERPA
• Pupil records as defined by Wis. Stat. § 118.125
• Student names, dates of birth, enrollment information
• Academic records, grades, attendance
• Guardian/parent contact information
• Any other information that could be used to identify a student

1.2 "Services"

Means the SISLMS by NAS platform, including:

• Student Information System (SIS) functionality
• Learning Management System (LMS) functionality
• Related software, applications, and services provided by NAS

2. DATA OWNERSHIP AND CONTROL

2.2 Control

The LEA retains full control over Student Data, including the right to:

• Access all Student Data at any time
• Request corrections to Student Data
• Request deletion of Student Data (subject to legal retention requirements)
• Export Student Data in standard formats (CSV, JSON)
• Terminate access to Student Data

3. PERMITTED USES OF STUDENT DATA

3.1 Educational Purpose

Provider may use Student Data solely for:

• Providing the Services to the LEA
• Maintaining and improving the Services
• Performing authorized operations and support
• Complying with legal obligations

3.2 Prohibited Uses

Provider SHALL NOT:

• Sell Student Data to any third party
• Use Student Data for advertising or marketing purposes
• Use Student Data for any purpose other than providing the Services
• Disclose Student Data to third parties except as expressly permitted in this Agreement
• Mine Student Data for commercial purposes
• Create profiles of students for non-educational purposes

4. COMPLIANCE WITH APPLICABLE LAWS

4.1 FERPA Compliance

Provider agrees to comply with the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g, and its implementing regulations, 34 C.F.R. Part 99. Provider acts as a "School Official" with a "legitimate educational interest" as defined by FERPA.

4.2 Wisconsin Statute § 118.125 Compliance

Provider agrees to comply with all applicable Wisconsin student privacy laws, including Wis. Stat. § 118.125 regarding pupil records and confidentiality.

4.3 COPPA Compliance

Provider agrees to comply with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501-6506, where applicable.

5. SECURITY MEASURES

5.1 Security Standards

Provider shall implement and maintain reasonable security procedures and practices appropriate to the nature of Student Data, including:

• Encryption: AES-256 encryption for data at rest, TLS 1.2+ for data in transit
• Access Controls: Role-Based Access Control (RBAC) and Row-Level Security (RLS) at database level
• Infrastructure Security: SOC 2 Type 2 certified cloud infrastructure (Supabase/AWS)
• Regular Security Assessments: Vulnerability scanning and security audits

5.2 Security Breach Notification

In the event of an unauthorized disclosure of Student Data, Provider shall:

• Notify the LEA within 72 hours of discovery
• Provide detailed information about the breach
• Cooperate with the LEA in investigating and remediating the breach
• Comply with all applicable breach notification laws

6. DATA RETENTION AND DELETION

6.1 Retention Period

Provider shall retain Student Data only for as long as:

• Necessary to provide the Services
• Required by applicable law (Wis. Stat. § 16.61 - minimum 7 years for public records)
• Authorized by the LEA

6.2 Deletion Upon Termination

Upon termination of this Agreement or upon written request by the LEA:

• Provider shall delete or return all Student Data within thirty (30) days
• Provider shall provide written confirmation of deletion

7. THIRD-PARTY DISCLOSURES

7.1 Authorized Third Parties

Provider may disclose Student Data only to:

• Subcontractors necessary to provide the Services, who are bound by equivalent privacy and security obligations
• Cloud Infrastructure Providers: Supabase (database), Vercel (hosting), AWS (infrastructure)
• Law enforcement when required by law or court order

8. AUDIT AND MONITORING

8.1 Audit Logs

Provider shall maintain comprehensive audit logs of all access to Student Data, modifications, exports, and security events. Audit logs shall be retained for a minimum of one (1) year or as required by law.

9. PARENTAL RIGHTS

9.1 FERPA Rights

Provider acknowledges that parents and eligible students have rights under FERPA, including:

• Right to inspect and review Student Data
• Right to request amendment of inaccurate records
• Right to opt-out of directory information disclosure
• Right to file complaints with the U.S. Department of Education

10. TERM AND TERMINATION

10.1 Termination

Either party may terminate this Agreement:

• With cause: Immediately upon material breach
• Without cause: With sixty (60) days written notice

11. GENERAL PROVISIONS

11.1 Governing Law

This Agreement shall be governed by the laws of the State of Wisconsin.

11.2 Dispute Resolution

Any disputes arising under this Agreement shall be resolved through:

• Good faith negotiation
• Mediation (if negotiation fails)
• Wisconsin state courts (if mediation fails)

15. SIGNATURES

Document Version: 2.0 | Last Updated: December 2025 | Next Review: December 2026