Welcome to Seamless WBL!
Seamless WBL was created to help educators, students, and employer partners set up and manage work‐based learning programs quickly and effectively. To accomplish this goal, it is essential that Seamless WBL provides a secure and safe environment for all parties’ information. Anyone creating or using an account on Seamless WBL is protected by, and agrees to, the terms below.
Seamless WBL and FERPA
Because it accepts data on and from students under the age of 18, Seamless WBL is designed to be compliant with the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99), a federal law that protects the privacy of student education records. FERPA applies to all K-12 schools and institutions of higher education that receive funds under an applicable program of the U.S. Department of Education.
Seamless WBL operates under the “school official exception” for Online Education Service providers. Under the school official exception, schools and districts may disclose Personally Identifiable Information (PII) from students’ education records to a provider as long as the provider:
- Performs an institutional service or function for which the school or district would otherwise use its own employees;
- Has been determined to meet the criteria set forth in the school’s or district’s annual notification of FERPA rights for being a school official with a legitimate educational interest in the education records;
- Is under the direct control of the school or district with regard to the use and maintenance of education records; and
- Uses education records only for authorized purposes and may not re-disclose PII from education records to other parties (unless the provider has specific authorization from the school or district to do so and it is otherwise permitted by FERPA).
When Data is discussed in this document, it includes all Personally Identifiable Information (PII) and other non-‐public information including, but are not limited to, student data, metadata, and user content.
Seamless WBL collects basic contact information on educators, their employer partners, and students. For educators and employers, this includes basic professional information, including names, titles, organization names, physical addresses, email addresses, and phone numbers. Beginning in August, Seamless WBL will also host information on students. Student Identifiable Information is limited to name and email address. Educators will connect students to work-based learning activities, so there will be a record of those activities as well.
Seamless WBL hosts information on work-based learning and advisory board activities that have been entered by school/district administrators and educators. Additionally, students, educators, and employers are allowed to attach information and documents to work-based learning records in the system. This is done at the educator’s discretion (students and employers must be invited to do so).
NC3T acknowledges that all rights, including all intellectual property rights, shall remain the exclusive property of its clients, and that NC3T has a limited, nonexclusive license solely for the purpose of performing its obligations as outlined in the Agreement. This Agreement does not give Provider any rights, implied or otherwise, to this Data, content, or intellectual property, except as expressly required to fulfill the functions of this service. This includes the right to sell or trade Data.
Data is entered into the system by users, except where users request NC3T to upload information on their behalf. This includes creating an administrator account and doing bulk imports of data on behalf of clients. There are also circumstances in which emails generated by the system result in data being entered, such as when employers are emailed invitations to participate in a work-based learning activity, and they confirm or decline their participation.
Security and Data Stewardship
Parties agree that all rights, including all intellectual property rights, shall remain the exclusive property of the client, and NC3T has a limited, nonexclusive license solely for the purpose of performing its obligations as outlined in the Agreement. This Agreement does not give Provider any rights, implied or otherwise, to Data, content, or intellectual property, except as expressly stated in the Agreement. This includes the right to sell or trade Data.
Provider will store and process Data in accordance with industry best practices. This includes appropriate administrative, physical, and technical safeguards to secure Data from unauthorized access, disclosure, and use. Provider will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner. Provider will also have a written incident response plan, to include prompt notification of the client in the event of a security or privacy incident, as well as best practices for responding to a breach of PII. Details on the system’s security protocols will be provided upon request.
Data Use, Retention, Disclosure, and Destruction
Provider will use Data only for the purpose of fulfilling its duties and providing services under this Agreement, and for improving services under this Agreement. Data cannot be shared with any additional parties without prior written consent of the User except as required by law.
Data is retained in the system for the duration of a client’s subscription. For current subscribers, data on graduated students are archived and retained for a period of three years, allowing client to run activity reports and conduct historical analyses at their discretion; after three years those Data are destroyed. Once a client’s subscription has expired, its Data is archived for a period of three years to allow them to access these historical records, after which it is destroyed. In any case, any Data will be destroyed within 48 hours of a client request.
Identifiable client Data, including but not limited to student data, cannot be shared with outside parties. NC3T may only share information on activity in Seamless WBL if all Data has been de-identified.
Provider will ensure that all Data in its possession are destroyed or transferred to the client under the direction of the client when the Data are no longer needed for their specified purpose.
Clients have full access to, and authority over, their Data, and determine the access provided to educators, administrators, students, and employer partners. Any data held by the provider will be made available to the client upon request.
Parents and authorized guardians have the right to access any Data held on their child or children, and NC3T will provide such data upon request. Given the relationship between schools and parents, and the need to verify identity, NC3T requires that the school or district serve as the intermediary for these requests, wherein the parent requests access to any education records created and maintained by the provider directly from the school or district, and the school or district then obtains the records from the provider to give back to the parent.
Marketing and Advertising
Educators and administrators registered with the system may receive occasional email notices regarding new system features and resources, and those notices may contain some advertising: None of those communications will contain or use student data. Provider will not use any Data to advertise or market to students or their parents.
Modification, Duration, and Termination of This Agreement
This agreement remains in effect throughout the life of the client’s subscription and governs the security and deletion of data upon termination of the service. If any changes are made, current and former clients will be notified prior to changes being put into effect in order to allow them to change or terminate their subscriptions.