Last updated: 17/03/2026
1. Vendor role under NY education law 2-d
Career Clutch acknowledges it is a Third-Party Contractor as defined under New York Education Law 2-d and will comply with all applicable requirements regarding the protection of student data and teacher/principal data.
Career Clutch agrees to:
- Maintain confidentiality of protected data
- Use data only for authorized educational purposes
- Implement reasonable security safeguards
- Not disclose protected data except as permitted by law or contract
2. Definitions of protected data
For purposes of NY Ed Law 2-d:
Protected Data includes:
- Student Personally Identifiable Information (PII)
- Education records as defined by FERPA
- Teacher and principal evaluation data (if applicable)
Career Clutch does not process teacher evaluation data unless specifically provided by the district.
3. Purpose of data use
Career Clutch will use protected data solely to:
- Provide Career Clutch educational services
- Support interview practice functionality
- Generate educational insights for educators
- Maintain platform security and operations
Career Clutch will not use protected data for:
- Advertising
- Marketing
- Data mining unrelated to services
- Commercial resale
- Behavioral profiling
4. Data security & privacy plan alignment
Career Clutch maintains safeguards aligned with NY Education Law 2-d requirements including:
Administrative safeguards:
- Access controls based on job role
- Staff access limited to operational necessity
- Security awareness practices
Technical safeguards:
- Encryption in transit
- Encryption at rest
- Secure cloud infrastructure
- Logging and monitoring
Physical safeguards:
- Cloud provider security controls
- Vendor infrastructure protections
Career Clutch security practices align with industry standards and SOC 2 security principles.
5. Data confidentiality obligations
Career Clutch agrees:
- Protected data remains confidential
- Data will not be disclosed without authorization
- Employees with access are subject to confidentiality obligations
- Access is limited to individuals with a legitimate need
6. Sub-processor requirements
Career Clutch may engage subcontractors only to support delivery of services.
Career Clutch ensures sub-processors:
- Maintain data protection safeguards
- Are contractually bound by confidentiality
- Use data only for service delivery
- Do not sell or independently use data
Career Clutch remains responsible for subcontractor compliance.
7. Data retention & secure destruction
Career Clutch will:
- Retain protected data only as long as necessary
- Delete or return data upon contract termination
- Securely dispose of protected data in accordance with industry practices
- Remove data from active systems within a reasonable timeframe
Backup systems are purged according to standard retention schedules.
8. Breach notification requirements
Career Clutch will notify the educational agency of any confirmed breach or unauthorized disclosure of protected data without unreasonable delay.
Notification will include:
- Nature of the incident
- Data affected (if known)
- Corrective actions taken
- Steps to prevent recurrence
Career Clutch will cooperate with district obligations under NY Ed Law 2-d.
9. Data access & parent rights support
Career Clutch will support educational agencies in fulfilling:
- Parent inspection rights
- Correction requests
- Deletion requests (where applicable)
Requests are processed through the school or district.
10. Prohibition on data sale
Career Clutch expressly agrees:
- Not to sell protected data
- Not to use protected data for advertising
- Not to create commercial student profiles
- Not to use protected data outside authorized purposes
11. Training & awareness
Career Clutch personnel with access to protected data are expected to follow internal security and privacy practices appropriate to their roles.
12. Compliance with laws
Career Clutch aligns with:
- FERPA
- COPPA
- NY Education Law 2-d
- NYSED Part 121 regulations
- Applicable student privacy laws
13. Right to review
Upon reasonable request, Career Clutch will provide information necessary to demonstrate compliance with contractual data protection obligations.
14. Data location
Career Clutch stores protected data primarily within the United States using secure cloud infrastructure.
Career Clutch does not knowingly transfer protected data outside the US without appropriate safeguards and district authorization.
15. AI use disclosure
Career Clutch uses AI only to support educational functionality such as interview simulations and feedback.
AI does not:
- Make personnel decisions
- Replace educator evaluation
- Provide therapy or diagnosis
- Create commercial data products
AI outputs support learning and require educator oversight.
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)