2018-15: Remove restriction on Account Creation for under 13 year olds

Owned by Patricia Donohue
Last updated: Jun 21, 2018
Request No. 2018-15
Date of RequestApril 5, 2018 
RequesterConnie Moise
Palomar College 
Application(s)OpenCCC 
Section / Page

Account Creation 

Steering Hearing DateMay 2, 2018 
ApprovalApproved for July 2018 Release (6.2.0)
Proposed Change to Download FileN/A 
Proposed Change to Residency LogicTBD 

Problem / Issue

As you’re aware, we need a way for our enrollment services team to create records on behalf of students whom we’ve verified through signed paper applications as legitimately enrolled at our institution.  Some of our students cannot (for different reasons) enroll online and create their own CCCID.  Examples include students under the age of 13 (listen to the attached voice message), incarcerated students, students enrolled as a Public Safety cohort (EME/Fire Tech/Police Academy), and students who do not speak English.

I appreciated the opportunity to speak with you, if briefly, regarding this.  It is becoming increasingly urgent that we find a viable way to address it.  I know that Palomar College is not the only institution concerned about this.  I would appreciate your guidance regarding how we assist these students in accessing online CCCCO supported systems such as StarFish, Canvas and others.  Please contact me as soon as possible with your recommended solution for these students.

Thank you for your help.

-Connie

Proposed Solution

This change was approved by the Tech Center and the CCCApply Steering Committee to support removing barriers.  This was also confirmed that the COPPA regulations do not apply for educational related accounts.

Requirements:

Update the logic in the Date of Birth question/field to remove restriction based on birthdate.  

Remove the first sentence in the onscreen text language for Date of Birth question. 


Notes

 Click here to expand...

Hi Connie,

Your problem has had me doing research and it appears that we missed a clarification of COPPA by the FTC in 2015 that exempts schools.

So how does COPPA apply to schools? Here’s the short answer: Schools – which are usually part of the local government – don’t fall within the legal definition of who’s covered by COPPA because they aren’t commercial “operators.” 


Hi Patty, 

With this clarification that COPPA does not apply to CCC (we are not commercial operators), we can collect data on individuals under the age of 13.

Please inform the steering committee and add this change request into the current June release if possible.

Whew. One less law to follow. 

Thanks,

Tim 

Fantastic! Thank you Tim. 

I appreciate the solution for our underage students.  We do still need a way to address the CCCID creation for our other special populations as I described below.

______________

We just want to eliminate any check on the students age.  Hoping this is not a big deal.

Supporting Documentation