Draft for review by a licensed attorney before publication.

Learning names of students, young people, and members: consent guidance

For teachers, coaches, youth leaders, congregation staff, and anyone else who wants to use Names Trainer to learn the names of people in their care. Effective [EFFECTIVE DATE].

The short version

1. Keep the deck private (on your device) or link-only with the people who need it. Never publish it.
2. Only use photos and names you are allowed to use under your school's or organisation's rules, and get consent where those rules require it.
3. No children in a published deck, ever.
4. Delete the deck at the end of the term, season, or role.

Who is responsible for what

Names Trainer is a tool. When you upload photos and names of students or members, you (and your school or organisation) are the ones deciding to collect and use that information, so your institution's policies and the law that applies to it govern what you may do. We store the content on your behalf, keep it private unless you share it, and do not use it for anything else. We have no facial recognition and create no biometric data. See the Privacy Policy.

Schools (FERPA and state law, US)

Student photos and names are education records or "directory information" under FERPA, depending on how your district has classified them. Many districts let staff use class photos for legitimate educational purposes, which learning your students' names clearly is, but some require parental opt-in and some families opt out of directory-information disclosure. Before you build a deck:

• Check your district's policy on staff use of student photos and on third-party apps. Some districts require apps to be on an approved list or to sign a data-privacy agreement; if yours does, email [CONTACT EMAIL] and we will work with you.
• Respect opt-outs. Leave out any student whose family has restricted directory information or photo use.
• Use photos the school already holds (the yearbook or roster system) rather than photos from social media or your own phone.
• Treat it like the class roster: private, on a device you control, and not shared outside staff who teach those students.
• State student-privacy laws (for example SOPIPA in California, and similar laws in many states) and COPPA apply to schools and vendors differently; your district's technology office is the right place to ask.

Outside the US (GDPR, UK GDPR, and similar)

Photos and names of children are personal data. Your school, club, or church is the data controller and needs a lawful basis. In practice: follow your organisation's photo policy, use only photos the organisation already holds with appropriate consent, keep the deck private, and delete it when you no longer need it. If your organisation keeps a register of apps that process personal data, add Names Trainer to it, and point your data protection lead to our Privacy Policy.

Coaches, youth groups, and congregations

There is usually no FERPA-style law, but there is usually a policy, and there is always a reasonable expectation: a parent who handed over a team photo did not expect it to end up on the internet. Follow your organisation's safeguarding or child-protection rules, which often restrict images of minors. Use a directory photo the family has already agreed to, not a candid from your phone. If there is no policy, ask the parents. A one-line note such as "I'm using a private flashcard app on my own phone to learn the kids' names; it isn't shared or published, and I'll delete it at season's end" is usually all it takes.

Congregation directories are sensitive: they reveal religious affiliation, family relationships, and sometimes addresses. Keep those decks private to the people who serve the congregation, leave addresses and family notes out of the deck, and remove anyone who asks.

Practical rules inside the app

• Private or link-only. Make a deck of minors private, or share it by link only with colleagues who have the same need, and stop the link when they no longer do. The app does not list a link-only deck anywhere.
• Do not publish. The app asks you to confirm that the people are public figures or have agreed before publishing. Children cannot give that agreement, and a parent's consent for a class photo is not consent to publish. We will unpublish, and may close accounts, where decks of minors are published.
• Keep it minimal. Names and faces are enough. Do not add health, behaviour, grades, family circumstances, or addresses in the notes.
• Delete when done. Delete the deck at the end of the term or season. Deleting a deck deletes its photos from the cloud. If other staff joined the deck, remove them first or tell them to delete their copy.
• Protect the device. Use a passcode on any device that holds the deck, and sign out of shared devices.
• Honour requests. If a parent, student, or member asks to be removed, remove them the same day.

Consent wording you can adapt

"[Teacher/Leader name] uses a private flashcard app on a passcode-protected device to learn the names of [students/members]. It holds only a name and a photo, is never published or shared outside [staff/leaders], and will be deleted by [date]. If you would rather your child not be included, tell [name] and they will be left out."

In-app notice text

When a deck is made public (shown above the confirmation checkbox):

A public deck can be seen by anyone. Only publish people who are public figures, or who have agreed to appear in a public deck. Never publish a deck that includes children, students, or members of a private group; share those by link or keep them private instead.

On the importer (shown once, on the first import of photos, and available again from the importer's help link):

Your photos stay on this device unless you sign in and upload a deck. Only add photos and names you have the right to use. If these are students, young people, or a private group, keep the deck private or link-only and delete it when you are done; see our guidance for teachers and leaders.

Questions

[CONTACT EMAIL]. If you are a school or organisation that needs a data-processing agreement, a vendor questionnaire answered, or a particular student's data deleted, say so in the subject line and we will prioritise it.