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FERPA Compliant

University Partnership Data Policy

Effective Date: March 30, 2026 | Last Updated: March 30, 2026

This policy governs the collection, use, and protection of student data shared by university partners with DAKDAN Talent in accordance with the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g.

University Partnership Programs

DAKDAN Talent partners with universities to facilitate student placements in internships, co-ops, and experiential learning programs across three tiers:

Tier 1: Experiential
  • • 50–100 students annually
  • • Basic job board access
  • • No credit required
Tier 2: Credit-Bearing
  • • 100–300 students annually
  • • For-credit internships
  • • Faculty supervision
Tier 3: Full Ecosystem
  • • 300+ students annually
  • • Dedicated support team
  • • Custom integrations

FERPA Compliance

School Official Exception (34 CFR § 99.31(a)(1))

Universities may disclose student education records to DAKDAN Talent as a "school official" with legitimate educational interests, provided certain conditions are met.

Requirements for School Official Status

  • Legitimate Educational Interest: Placement services directly support students' educational programs
  • Need-to-Know: DAKDAN only receives data necessary for job matching and placement
  • Direct Control: Written agreement with university maintains institutional control over data
  • Annual Notification: University notifies students of FERPA directory info disclosure in annual notice

FERPA Restrictions

DAKDAN may NOT further disclose education records to third parties (employers, recruiters) without explicit student consent or another FERPA exception. Students control all external sharing.

Student Data Categories

Directory Information (Public)

Universities may share without individual consent (unless student opts out):

  • • Name
  • • University email address
  • • Major/field of study
  • • Expected graduation date
  • • Degrees/honors received
  • • Enrollment status (full-time/part-time)

Non-Directory Information (Restricted)

Requires explicit student consent for disclosure:

  • • GPA and transcript data
  • • Course enrollment details
  • • Academic standing/probation
  • • Disciplinary records
  • • Financial aid information
  • • Social Security Number
  • • Student ID number

Student Consent Process

For non-directory data (e.g., GPA, transcripts), students provide explicit opt-in consent through the DAKDAN platform:

  1. 1.Student logs in and reviews data sharing preferences
  2. 2.Selects which data elements to share (granular controls)
  3. 3.Consent recorded with timestamp, IP address, and scope
  4. 4.Student can revoke consent at any time

How We Use Student Data

Permitted Uses

1

Job Matching

Match students to internships and jobs based on major, skills, and preferences

2

Application Processing

Facilitate application submission to employers selected by the student

3

Progress Tracking

Monitor placement outcomes for university reporting (aggregate data only)

4

Academic Credit

Coordinate with faculty for credit-bearing internships (Tier 2/3 only)

5

Career Services

Provide resume feedback, interview prep, and career guidance

6

Compliance Reporting

Generate de-identified reports for accreditation and outcomes assessment

Prohibited Uses

Selling or renting student lists to third-party recruiters
Sharing data with employers without explicit student action (application or consent)
Using GPA or academic standing for automated filtering (without consent)
Marketing non-educational products or services to students
Cross-referencing with external databases to enrich profiles

Data Retention & Deletion

Data TypeRetention PeriodPost-Graduation
Directory informationActive enrollment + 2 yearsDeleted or alumni opt-in
GPA & transcriptsConsent period onlyDeleted at graduation
Application historyActive + 3 yearsAnonymized for analytics
Placement outcomes7 years (aggregate)De-identified, retained
Credit-bearing recordsPer university policyReturned to university

Graduation Transition

Upon graduation, students are prompted to opt-in as alumni. If they decline, all education records are deleted within 90 days. Application history anonymized.

Early Deletion

Students may request full data deletion at any time. We delete within 30 days and notify the university. Credit-bearing records returned to institution first.

University Partner Controls

Universities maintain oversight and control over student data through:

Administrative Access

  • View student participation and placement data
  • Generate compliance and outcomes reports
  • Review employer partnerships and job postings
  • Remove students from platform if needed

Data Governance

  • Audit data access logs (available on request)
  • Review and approve third-party integrations
  • Request data deletion or de-identification
  • Terminate partnership and data return

Security Measures

Encryption

  • • AES-256 at rest
  • • TLS 1.3 in transit
  • • Field-level encryption for SSN
  • • Encrypted backups

Access Control

  • • Role-based permissions
  • • Multi-factor authentication
  • • IP allowlisting (enterprise)
  • • Annual access reviews

Monitoring

  • • 24/7 SOC monitoring
  • • Intrusion detection
  • • Audit logging (7 years)
  • • Incident response plan

Student Privacy Rights

Access Records

View all data shared by your university

Correct Inaccuracies

Update profile information and notify university

Opt-Out Directory

Request university withhold directory info

Revoke Consent

Withdraw consent for non-directory data sharing

Request Deletion

Delete account and all personal data

Complaint Rights

File complaint with university or U.S. Dept. of Education

File a FERPA Complaint

If you believe your FERPA rights have been violated:

Family Policy Compliance Office

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202-5920

University Partnership Contacts

University Partnerships Team

universities@dakdantalent.com

Student Privacy Officer

ferpa@dakdantalent.com

Data Protection Officer

dpo@dakdantalent.com

Version: 1.0 | Effective Date: March 30, 2026 | Last Updated: March 30, 2026
Complies with: FERPA (20 U.S.C. § 1232g), 34 CFR Part 99, GDPR, CCPA
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