New York education law 2-d compliance

Last updated: 17/03/2026

How Career Clutch aligns with NY Ed law 2-d

Educational purpose limitation

Career Clutch uses student data only to:

• Provide interview practice and career readiness tools
• Generate educational feedback
• Support educator insights
• Maintain platform security and reliability

Student data is never used for unrelated commercial purposes.

No sale of student data

Career Clutch does not:

• Sell student data
• Rent student data
• Share student data for advertising
• Build commercial profiles of students
• Track students across other platforms

Data security safeguards

Career Clutch maintains safeguards designed to protect student data including:

• Encryption in transit and at rest
• Role-based access controls
• Secure cloud infrastructure
• Security monitoring
• Incident response procedures

Security practices align with industry standards and SOC 2 security principles.

Vendor & sub-processor controls

Career Clutch uses trusted service providers only to operate the platform.

These providers:

• Are contractually required to protect student data
• May only process data to support Career Clutch services
• May not use data independently
• May not sell student information
• A Sub-Processor List is available upon request.

Data retention & destruction

Career Clutch retains student data only as long as necessary to provide services.

Schools may request:

• Data export
• Data correction
• Data deletion

Upon contract termination, student data is deleted or returned in accordance with district agreements.

Breach notification

Career Clutch maintains incident response procedures.

If a breach involving student data is confirmed:

• The affected school or district will be notified without undue delay
• Relevant information will be provided
• Career Clutch will cooperate with district response obligations

Parent rights

Consistent with FERPA and New York requirements:

Parents and eligible students may:

• Request access to student records
• Request corrections
• Request deletion through the school

Career Clutch supports schools in fulfilling these rights.

AI use transparency

Career Clutch uses AI only to support educational practice and learning.

AI does not:

• Make placement decisions
• Replace educators
• Provide therapy
• Create commercial datasets

AI outputs support learning and require educator oversight.

Data Privacy Agreement (DPA)

Career Clutch supports New York districts in executing required Data Privacy Agreements (DPAs) consistent with NY Education Law 2-d.

Additional documentation available upon request:

• Privacy Policy
• FERPA Addendum
• Security FAQ
• Sub-Processor List
• Vendor Security Responses

Contact & procurement support

For privacy, security, or compliance inquiries:

Email: privacy@careerclutch.ai
Security: security@careerclutch.ai

Districts may request:

• Security questionnaires and responses
• Sub-processor disclosures
• Data protection documentation
• District-specific addenda (e.g., Texas, California, NYC DOE)