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FERPA, the SAPL shall be considered a School Official, under the control and direction of the <br />SAUSD as it pertains to the use of Student Data notwithstanding the above. <br />Third Party Access to Student Data: SAUSD allows the SAPL's integrated library system called The <br />Library Corporation (TLC) to access student data in order to establish a library card account for <br />students. Such student data shall consist of participating student's name, student ID number, <br />home address, grade, school, and the student's parent's/guardian's name, phone numberand/or <br />email address. Except for TLC, should a third party, including law enforcement and government <br />entities, contact SAPL with a request for data held by the SAPL pursuant to the MOU, the SAPL <br />shall redirect the third party to request the data directly from the SAUSD. SAPL shall notify the <br />SAUSD in advance of a compelled disclosure to a third party. <br />3. Subprocessors: SAPL shall enter into written agreements with all subprocessors performing <br />functions pursuant to the MOU, whereby the subprocessors agree to protect student data in <br />manner consistent with the terms of this DSA. <br />ARTICLE III: DUTIES OF SAUSD <br />1. Privacy Compliance: SAUSD shall provide data for the purposes of the MOU in compliance with <br />FERPA, COPPA, PPRA, SOPIPA, AB 1584 and all other California privacy statutes. <br />ARTICLE IV: DUTIES OF SAPL <br />1. Privacy Compliance: The SAPL shall comply with all applicable state and federal laws and <br />regulations pertaining to data privacy and security, including FERPA, COPPA, PPRA, SOPIPA, AB <br />1584 and all other California privacy statutes. <br />2. Authorized Use: The data shared pursuant to the MOU shall be used for no other purpose than <br />the Student Success Library Card Program. <br />3. Employee Obligation: SAPL shall require all employees who have access to student data to comply <br />with all applicable provisions of this DSA with respect to the data shared under the MOU. <br />4. Disposition of Data: Upon written request, SAPL shall dispose or delete all student data obtained <br />under the MOU when it is no longer needed for the purpose for which it was obtained. <br />5. Advertising Prohibition: SAPL is prohibited from using or selling student data to market or <br />advertise to students or families/guardians. <br />ARTICLE V: DATA PROVISIONS <br />1. Data Security: The SAPL agrees to abide by and maintain adequate data security measures, <br />consistent with industry standards and technology use practices, to protect student data from <br />unauthorized disclosure or acquisition by an unauthorized person. These measures shall include, <br />but not limited to: <br />