How Titan Toolkit handles data, AI, and student privacy

1. Scope & intended users

Titan Toolkit is a staff-only instructional planning tool for Lorain High School educators. It generates teacher-facing worksheets, rubrics, lesson plans, and SchoolAI handoff prompts. It is not a student-facing application. Students do not log in, do not submit work through it, and do not have accounts.

Because students never interact directly with this site, COPPA (Children's Online Privacy Protection Act, 16 C.F.R. Part 312) does not apply to its operation. Teacher use of the tool to plan instruction for minors remains governed by FERPA, Ohio student data privacy law, and Lorain City Schools' Acceptable Use Policy.

2. Keeping students anonymous (FERPA & student records)

The Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99) protects personally identifiable information from a student's education record. Titan Toolkit is designed so that no education record data ever needs to be entered.

Specifically, do not enter any of the following into any field, prompt, or note:

• Student first or last names, initials, or nicknames
• Student IDs, lunch numbers, or schedule identifiers
• IEP / 504 plan content, accommodations tied to a named student, or eligibility category
• Discipline, attendance, grade, or assessment data tied to a named student
• Medical, family, or socioeconomic detail tied to a named student
• Photos, video, audio, or work samples that identify a student

Use generic placeholders instead: "the student," "Group 1," "a Tier 2 reader," "an EL student at WIDA level 3." Aggregate, de-identified pedagogical context is appropriate; identified records are not.

3. Ohio student data privacy

Ohio Revised Code §§ 3319.321 and 3319.326 restrict the disclosure of personally identifiable student information by school districts and their contractors. Titan Toolkit does not function as a contracted data processor for Lorain City Schools: it does not collect, store, or transmit identified student records. Staff using the tool remain bound by district policy and Ohio law when authoring content.

The tool aligns with the Ohio Department of Education and Workforce Guidance on Artificial Intelligence in K–12 Education (2024) by (a) keeping a human educator in the loop for every artifact, (b) requiring teacher review before any AI-generated content is used with students, and (c) avoiding the input of identified student data into generative AI systems.

4. AI use & transparency

The ✦ Suggest buttons call Google's Gemini API directly from your browser using an API key you provide in Settings. The toolkit itself does not proxy, log, or retain prompts or responses.

• Teacher in the loop. All AI output is a draft. The educator is the author of record and must review, edit, and verify content before classroom use.
• Accuracy. Generative models can produce plausible-but-wrong content (hallucinations), outdated references, or culturally narrow examples. Treat output as a starting point, not a source of truth.
• Bias & equity. Review AI drafts for cultural responsiveness (Hammond, Ready for Rigor), linguistic accessibility for ELs (SIOP), and UDL multiple means of representation before use.
• Keep students anonymous in prompts. See section 2.
• Disclosure. When AI-assisted content is shared with students, families, or evaluators, label it as AI-assisted in a manner consistent with OTES 2.0 professional responsibility and district guidance.

The SchoolAI handoff feature copies a prompt for you to paste into the district-licensed SchoolAI platform. That paste action is governed by your district's data-sharing agreement with SchoolAI, not by this toolkit.

5. Data storage & residency

• Local-only by default. Saved worksheets, library entries, plans, and your Gemini API key live in your browser's localStorage on the device you are using. They do not sync, do not leave the device, and are not visible to administrators of this site.
• No analytics, no tracking pixels, no third-party cookies.
• Shared devices. Anyone with access to the browser profile can read the stored data. On shared staff workstations, use Settings → Erase all local data at the end of your session, or use a private/Incognito window.
• Retention. Data persists until you clear it, clear browser storage, or the browser is reset.

6. Third-party services

7. Accessibility (WCAG 2.2 AA)

Titan Toolkit targets conformance with the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA, in alignment with Section 504 of the Rehabilitation Act, the Americans with Disabilities Act (ADA Title II), and Lorain City Schools' obligations to students and staff with disabilities.

• Semantic landmarks, keyboard-operable controls, and visible focus indicators.
• Color contrast ≥ 4.5:1 for text; titan blue / steel gray / paper white palette tested for AA.
• prefers-reduced-motion respected — all transitions collapse for users who opt out of motion.
• Printed worksheets use outline-only ink-light layouts that remain legible at 100% scale and standard letter print.
• Form labels are programmatically associated with inputs; required fields are announced.

Known gaps are tracked publicly and remediated on a rolling basis. Report a barrier through the contact channel in section 10.

8. Acceptable use

Use of Titan Toolkit is subject to the Lorain City Schools Staff Acceptable Use Policy and the Ohio Educator Licensure Code of Professional Conduct. By using the tool you agree to:

• Use the tool for instructional planning purposes within your assigned role.
• Keep your Gemini API key confidential — treat it like a password.
• Keep students (and staff) anonymous in any AI-bound field — no real names, IDs, or identifying details. See section 2.
• Review every AI-generated artifact before classroom or family use.
• Not use the tool to harass, discriminate, or generate content that violates district policy or state law.
• Report security incidents promptly (section 10).

9. Security practices

• Transport. Served over HTTPS with HSTS (max-age=31536000; includeSubDomains; preload).
• Headers. X-Content-Type-Options: nosniff, X-Frame-Options: DENY, Referrer-Policy: strict-origin-when-cross-origin, restrictive Permissions-Policy, and a Content Security Policy that scopes script, style, font, image, and connect sources.
• No server-side accounts. No password database, no session store, no PII at rest on infrastructure under our control.
• Dependency surface. Tailwind CDN and Gemini API are the only runtime third parties; both are listed in section 6.
• Key handling. Your Gemini API key is held only in localStorage on your device and is sent only to generativelanguage.googleapis.com. Rotate it via Google AI Studio if exposure is suspected.

10. Rights, requests, and incident reporting

• Erase your data. Settings → Erase all local data wipes saved worksheets, library entries, and your API key from this browser.
• FERPA requests. Parents and eligible students seeking access to education records should contact the Lorain City Schools FERPA records officer through the district office; Titan Toolkit does not hold education records.
• Accessibility barriers. Report through the district's accessibility coordinator or the project maintainer.
• Suspected key exposure or security incident. Rotate the Gemini key immediately in Google AI Studio, then report to district IT and the project maintainer.

This statement may be updated as the toolkit evolves; the Last reviewed date at the top reflects the current revision. Material changes will be summarized in the project changelog.