KairosED™ Meets the Federal AI Standard

Zero Student Data Used for AI Model Training

KairosED™ never uses student or educator data to train AI models, directly satisfying the framework's requirement to affirm limits on data collection for model training. Prompts are stored as cryptographic hashes — original inputs cannot be reconstructed.

Evidence: Privacy Policy: "does not use student data to train AI models" | prompts stored as cryptographic hashes

COPPA School-Operator Model Compliance

KairosED™ operates under COPPA's school-operator model. The district is the authorizing party for all student access. No direct marketing to students, no PII collected for commercial purposes. Students cannot self-register — all accounts require district roster provisioning.

Evidence: Privacy Policy: COPPA section | Consent page: "Your child cannot sign up for KairosED independently"

No Targeted Advertising or Commercial Student Data Use

No advertising exists on the platform. No student or educator data is sold, rented, or traded. The platform collects only name, email, role, usage logs, and safety events — no birth date, address, phone number, photos, or financial data.

Evidence: Consent page: "We do not sell student data. We do not use student data for advertising."

District-Controlled Student Access via Roster Sync

Student access is provisioned entirely through district roster sync (OneRoster/SIS). No student self-registration is permitted, ensuring institutional oversight of all minor access to AI systems.

Evidence: Main site: "Roster sync ready — OneRoster integration provisions users automatically"

Explicit CSAM and Self-Harm Content Safety Framework (Gap 2)

A dedicated /safety page documents two hardcoded protections no district can disable: CSAM triggers immediate blocking and mandatory authority reporting; self-harm content is blocked using AFSP and SPRC guidelines. Detection is layered — both pre-generation and post-generation screening. All safety events are immutably logged.

Evidence: kairosed.ai/safety: "Any content that sexually exploits, depicts, describes, or facilitates the abuse of minors is absolutely prohibited. This protection cannot be disabled."

Formal Age-Assurance Mechanism Published (Gap 3)

The /age-assurance page documents three provisioning methods: (1) Roster sync via OneRoster/SIS as the primary age-gate; (2) manual admin provisioning with district attestation; (3) the allowStudentTools gate, which is disabled by default. An optional parental attestation workflow is available on request.

Evidence: kairosed.ai/age-assurance: "Student-facing AI tools are disabled by default. A district administrator must explicitly enable the Allow Student Tools setting."

Deepfake, Synthetic Media, and Digital Replica Prohibition (Gap 4)

Terms of Service Section 15 explicitly prohibits generating deepfakes, synthetic voice or likeness clones, and digital replicas of real individuals without explicit informed consent. No district-level override is permitted.

Evidence: ToS Section 15: explicit prohibition on deepfakes, synthetic voice clones, and digital replicas without consent

Parent and Guardian Consent, Rights, and Opt-Out Interface (Gap 1)

The public /consent page gives parents documented rights: review data, request corrections, request deletion (10 business days), and opt out of student-facing AI tools. Two opt-out paths are available — district technology administrator or directly via privacy@kairosed.ai (5-business-day response). The admin parent reports interface lets districts generate and share student AI activity reports with families.

Evidence: kairosed.ai/consent (public) | kairosed.ai/dashboard/admin/parent-reports (district admin)

Content Safety System Blocks Threats, Violence, and Illegal Activity

The layered content safety system blocks instructions for creating weapons, committing violence, and engaging in illegal activity. Bullying, harassment, and coordinated hate speech targeting individuals or groups are prohibited. Safety events are immutably logged.

Evidence: kairosed.ai/safety: Weapons, Violence, and Illegal Activity category | Bullying, Harassment, and Hate Speech category

Synthetic Voice and Likeness Prohibition Addresses AI-Enabled Impersonation (Gap 4)

ToS Section 15's prohibition on synthetic voice clones and digital replicas directly addresses the framework's concern about AI-enabled fraud and impersonation. Generating audio or video that misrepresents what a real person said or did is explicitly prohibited platform-wide.

Evidence: ToS Section 15: "Synthetic voice or likeness clones of students, teachers, administrators, or any other identifiable individual"

No Training on User-Generated Content

District content, teacher-created materials, and student data are never used to train AI models, directly aligning with the framework's requirement that platforms affirmatively protect against data collection for AI training purposes.

Evidence: Privacy Policy: "does not use student data to train AI models"

IP Ownership of All AI-Generated Outputs Assigned to District and Educator (Gap 5)

Terms of Service Section 8 explicitly assigns full ownership of all AI-generated outputs — lesson plans, rubrics, assessments, parent communications, IEP goals — to the district and educator. KairosED™ makes no intellectual property claim of any kind on AI-generated outputs.

Evidence: ToS Section 8: "All AI-generated outputs...belong to the District and the educator who generated them. KairosED makes no intellectual property claim of any kind on AI-generated outputs."

Unified Digital Replica and Synthetic Media Restriction (Gap 6)

ToS Section 15 prohibits generating digital replicas of any real individual without explicit informed consent, creating a unified policy addressing both child-specific protections and the broader individual protections the framework contemplates.

Evidence: ToS Section 15: "Digital replicas created without that person's explicit, informed consent" — prohibited universally

Explicit Anti-Censorship Policy in Published Safety Framework (Gap 7)

The /safety page contains public language directly satisfying this requirement: safety filters must serve harm prevention exclusively — not suppression of viewpoints or political speech unrelated to student safety. This applies to all district administrator configurations of the content safety system.

Evidence: kairosed.ai/safety: "Safety filters must serve harm prevention exclusively — not suppression of viewpoints or political speech unrelated to student safety."

Hardcoded Safety Floor That No Administrator Can Override (Gap 7)

CSAM and self-harm protections are hardcoded and cannot be disabled by any district administrator. Districts may adjust sensitivity levels for other content categories, but the minimum safety floor is not negotiable. This structure simultaneously prevents misuse of content controls for political censorship while keeping the most critical child protections always active.

Evidence: kairosed.ai/safety: "Districts may customize rules and sensitivity levels but cannot disable hardcoded protections for CSAM and self-harm."

Sector-Specific AI Built Entirely Within Existing Federal Frameworks

KairosED™ operates within FERPA and COPPA — the existing federal regulatory frameworks governing student data — rather than requiring new AI-specific regulation. This is the model the framework endorses: sector-specific AI governed by existing regulatory bodies with subject matter expertise.

Evidence: FERPA-aligned and COPPA school-operator compliant | DPAs and FERPA addendums available via support@kairosed.ai

Purpose-Built for Education, Not Repurposed Generic AI

All tools were designed specifically for K-12 education workflows — lesson design, assessment creation, standards unpacking, coaching feedback, parent communication, and student homework support. This is not enterprise AI adapted for schools.

Evidence: Main site: "Built for education, by educators" | "Designed for school districts, not just schools"

Rapid Deployment Removes Institutional Barriers to AI Adoption

Setup under one week and SSO-only authentication via Google Workspace or Microsoft Entra ID removes the procurement and IT friction that has kept AI out of public school systems. OneRoster integration automates user provisioning from existing SIS data.

Evidence: Main site: setup "typically within one week" | OneRoster integration | SSO only

Direct Embodiment of the Framework's Core Education Mission

KairosED™'s mission is to incorporate AI into K-12 education programs. Purpose-built tools bring AI into lesson planning, assessment creation, standards alignment, professional coaching, and student support — across every role in a school district.

Evidence: Main site: 30+ tools for teachers and admins, 5 student-facing tools including Homework Tutor, ACT Coach, SAT Coach, Trades Explorer, Code Studio

Teacher AI Literacy Through Structured, Guided Tool Use

The district-curated Shared Prompt Library and standards-aligned toolset give teachers a scaffolded environment for developing real AI competency — effective prompting, output evaluation, and workflow integration in an educational context.

Evidence: Admin console: Shared Prompt Library with district-curated, standards-aligned prompts

Student Access to AI-Guided Learning Support

The Student Homework Tutor and other district-enabled student-facing tools provide K-12 students with direct access to AI-guided academic support, controlled by the district via the allowStudentTools gate.

Evidence: Age-assurance page: "Student-facing AI tools are disabled by default. A district administrator must explicitly enable the Allow Student Tools setting."

Student AI Literacy Module — Teaching Students About AI, Not Just With It (Gap 8)

A dedicated AI literacy learning environment is available within the authenticated platform, giving students structured content about AI itself — moving beyond AI as a homework tool to building genuine AI literacy skills students carry into the workforce.

Evidence: kairosed.ai/dashboard/learn (authenticated) — live route

Structured Teacher AI Professional Development Pathway (Gap 9)

A dedicated professional development environment is available within the authenticated platform, giving educators a structured pathway for building genuine AI competency — directly satisfying the framework's distinction between providing AI tools and providing AI training.

Evidence: kairosed.ai/dashboard/professional-development (authenticated) — live route

Already Compliant with Existing Federal Education Data Standards

KairosED™ operates as a "school official" under FERPA with data minimization, multi-tenant isolation, role-based access controls, a maximum 365-day retention limit, self-service deletion, and Data Processing Agreements available on request.

Evidence: Privacy Policy: FERPA "school official" designation | DPAs and FERPA addendums available via support@kairosed.ai

District Governance Model Aligns with Preserved State and Local Authority

The framework explicitly preserves state and local authority over public education AI procurement and use. KairosED™'s architecture — where districts control all tool access, data retention, safety rules, and user provisioning — is built for exactly this governance model.

Evidence: Main site: "District-controlled AI — Administrators decide available tools, configure safety rules, manage access; teachers cannot bypass guardrails"

Multi-Tenant Isolation and Data Processing Agreements

Strict tenant isolation ensures no cross-district data access. Data Processing Agreements provide the contractual accountability structure that procurement offices and legal reviewers expect as federal AI standards develop.

Evidence: Privacy Policy: "Multi-tenant isolation (strict district separation)" | DPAs available upon request

Federal AI Compliance Tracking Dashboard (Gap 10)

A dedicated compliance interface in the admin platform gives district administrators visibility into the platform's compliance posture against evolving federal AI standards, including this framework. This is the infrastructure for demonstrating and tracking regulatory alignment as this framework's legislative components move through Congress.

Evidence: kairosed.ai/dashboard/admin/compliance (authenticated) — live route

AI Safety Incident Response Protocol and Reporting Interface (Gap 11)

A dedicated incident response interface in the admin platform provides formal incident management and escalation infrastructure for district administrators and regulators, defining division of responsibilities between KairosED™ and the district.

Evidence: kairosed.ai/dashboard/admin/incident-response (authenticated) — live route | safety@kairosed.ai for external reporting