Legal
Security Statement
Last updated May 17, 2025
1. Definitions
- SSY
- Studio Source Yearbooks, a bundle of services marketed by IYP.
- IYP
- Independent Yearbook Publishing, LLC of Marana, AZ.
- ORGANIZATION
- The client making use of SSY
- ACCOUNT
- Credentials and associated licenses enabling an ORGANIZATION to operate SSY
- CONTRACT
- A formal agreement between IYP and the ORGANIZATION
- CONTRACT COMPLETION
- The moment when a contract between IYP and an ORGANIZATION terminates
- DEVICE
- A computing device, including mobile phone and desktop systems.
- FULFILLMENT PROVIDERS
- Third-party companies tasked with the production and delivery of physical PRODUCTS.
- SSY SERVER
- The physical location of the code and database accessed by SSY
- INDIVIDUAL
- A person whose information is stored by SSY
- INDIVIDUAL DATA
- Information uniquely associated with a specific INDIVIDUAL
- Includes
- content reported by ORGANIZATION database, including name / grade / student number / guardians / photographs
- content created by INDIVIDUALS, including textual responses and photographs submitted to SSY by INDIVIDUALS
- LEA ORGANIZATION
- A Local Educational Agency - a School or District – making use of SSY as a client, as the case may be
- GUARDIAN
- An INDIVIDUAL with custody over a STUDENT at an LEA ORGANIZATION, including parents and legal guardians
- RECORD
- Data associated with a specific INDIVIDUAL by SSY
- SSY PLATFORM
- The software published by IYP which collects INDIVIDUAL DATA and facilitates the creation of PRODUCTS.
- Includes
- Connection to the ORGANIZATION DATABASE
- Tools for ORGANIZATION staff and volunteers to create visual layouts
- Tools to render those yearbooks to a format suitable for printing and binding by FULFILLMENT PROVIDERS
- Tools for INDIVIDUALS and GUARDIANS to purchase and personalize PRODUCTS
- Reporting tools to update ORGANIZATIONS, STUDIOS, FULFILLMENT PROVIDERS, and other stakeholders with status
- STUDENT
- An INDIVIDUAL receiving instruction at an LEA ORGANIZATION, who may be a minor
- STAKEHOLDERS
- The totality of INDIVIDUALS, ORGANIZATION staff, GUARDIANS, and STUDIOS
- STUDIO
- A company unrelated to IYP, working directly with an ORGANIZATION; typically a photography studio.
- PRODUCTS
- Physical and digital goods including Yearbooks - a record of a school’s activities during a time interval, typically a printed annual book featuring students and activities from the current year.
2 Statements
IYP hereby states:
- RECORDS will be used in the following manner:
- Identifying INDIVIDUALS in PRODUCTS
- Offering PRODUCTS for sale to INDIVIDUALS, tracking transactions, ensuring delivery
- Provided to STUDIOS for the purpose of fulfilling their obligations to ORGANIZATION, including photography services.
- RECORDS continue to be the property of and under the control of the ORGANIZATION.
- RECORDS shall not be retained or available to IYP upon completion of agreements with ORGANIZATION.
- Personally identifiable information in RECORDS will not be used in targeted advertising unless specifically authorized by the ORGANIZATION.
- SSY will not condition a child's participation in a game, the offering of a prize, or another activity on the child disclosing more personal information than is reasonably necessary to use the platform.
- IYP does not intentionally gather any information which indicates the citizenship status of INDIVIDUALS. If in the normal course of operations IYP becomes aware of such status, it will not unilaterally report this information to any third party. IYP will fully comply with any lawful demand for information made of it by an appropriate authority.
3 Notifications
3.1 In-application notifications
In compliance with COPPA and other regulations, the following notifications will be visible in the SSY PLATFORM:
Link from the welcome page:
privacy information
Linked content:
The SSY platform makes use of information provided by this organization to identify students. This information was provided by the organization under the terms of a contract which imposes strict confidentiality requirements.
Individuals or guardians wishing to review or modify the information collected by this platform should present themselves to the organization, who may at their discretion comply with their request.
3.2 GUARDIAN notifications
In compliance with COPPA and other regulations, the following notifications will be suggested to the ORGANIZATION for presentation to GUARDIANs:
Our school has adopted the Studio Source Yearbooks platform.
This platform was selected to create, publish and sell a yearbook – gathering and presenting stories and memories from your student’s experiences at this organization.
The platform records the same data as our school information system - your student’s name, a photograph, which class they belong to. It may gather additional information, such as favorite memories, messages to or from specific individuals, candid photographs, and so on.
The information collected by the platform will not be shared with any third party with the exception of law enforcement, should the need arise.
You are welcome to ask your Organization for permission to see the records for your student, to opt out of marketing messages, or to have your student removed from the yearbook.
COPPA §312.4.c requires explicit GUARDIAN approval for disclosure of a child’s personal information, the ability to opt out of collection, and rules for automatically deleting students whose GUARDIANs have not provided permission within reasonable delay.
ORGANIZATIONS are assumed to withhold from IYP any PII for children whose GUARDIANS have not given this explicit approval.
GUARDIANS who express a more specific desire for their children to be omitted from the PRODUCT may do so via the ORGANIZATION or to IYP directly, via support@studiosourceyearbooks.com; upon receiving such notification, IYP will take commercially reasonable steps to ensure that PII for the affected children are removed.
4 RECORD contents
- SSY Required Information for all INDIVIDUALS
- Last Name
- First Name
- Role (student, staff, guardian…)
- SSY Preferred Information for STUDENTS
- Photograph
- Student ID Number (corresponding with Student’s permanent record)
- Grade
- Teacher / homeroom
- SSY Preferred Information for all INDIVIDUALS
- SMS-enabled mobile number
- Email Address
- List of dependents and guardians
5 Information & Data Security
- RECORDS are protected physically:
- No information is stored on-site at the ORGANIZATION except transient browser caches; all information resides on the SSY SERVER. There is no database present on ORGANIZATION hardware.
- Physical locations for the SSY PLATFORM are:
- For our domain (hosting and serving of pages) and for maintenance scripts: We use inMotionHosting, with data centers in Los Angeles and Ashburn, Virginia. Physical security measures are in place to prevent unauthorized entry to the site.
- For our database and web services: we use Amazon Web Services us-east-1 (North Virginia), a cloud-based system which stores data in U.S. locations.
- RECORDS are protected Electronically:
- All communications between the SSY PLATFORM and other sites such as your organization’s OneRoster interface are encrypted end-to-end via SSL.
- Hosting and database structures run on a secure host that restricts external access via password. Access tokens for the database are encrypted and persisted locally as cookies, a common and trusted approach to security.
- Application design:
- The front end is written in HTML, Javascript, and Typescript.
- To ensure that client and end-user data are ‘air-tight’ and free of accidental cross-access, the SSY API implements a tightly coupled resource check when users request resources in the Dashboard.
- SSY uses Amazon CloudWatch, a monitoring service offered by Amazon Web Services (AWS). CloudWatch allows users to track the performance and health of their AWS resources and applications, gather logs, and receive alarms based on predefined thresholds, according to AWS. This helps identify issues, optimize resource usage, and improve operational efficiency.
- SSY uses Amazon GuardDuty, a managed threat detection service that continuously monitors AWS accounts and workloads for malicious or unauthorized behavior. It provides real-time threat intelligence and detailed security findings to help detect and respond to potential security issues.
- SSY uses Amazon CloudTrail, a service that enables auditing, security monitoring, and operational troubleshooting by logging and tracking API calls and other actions within an AWS account. It captures events, including those made through the AWS Management Console, AWS SDKs, and the AWS Command Line Interface, to provide a detailed record of activity for governance, compliance, and risk auditing purposes.
- The database is backed up daily to ensure that logs and records are not lost in the event of catastrophic failure or application error.
6 Instructions and Procedures
- Actions taken to ensure the security and confidentiality of RECORDS
- IYP staff are designated able to view and modify all RECORDS as required in the accomplishment of their assigned tasks.
- STUDIO staff are designated able to view and modify RECORDS for the ORGANIZATIONS as required in the accomplishment of their assigned task for ORGANIZATIONS that they directly service.
- IYP staff are trained to avoid
- Sharing credentials by any means other than password-protected online documentation
- Releasing private information on ORGANIZATION visitors, staff, students or policies to anyone not associated with the administration of the ORGANIZATION
- Procedures for notifying STAKEHOLDERS in the event of an unauthorized disclosure of RECORDS
- IYP maintains contact information for administrators at all ORGANIZATIONs and STUDIOS.
- IYP will notify these same by email in the event of unauthorized disclosure. The email will include phone and email information to enable STAKEHOLDERS to contact IYP staff directly with their concerns.
- Removal of RECORDS
- At CONTRACT COMPLETION, unless otherwise instructed by one or more of the STAKEHOLDERS, IYP staff will remove RECORDS from operational and backup data stores within sixty (60) days of contract termination through a manual data deletion process.
- Notwithstanding the above, should an INDIVIDUAL choose to establish or maintain an account for the purpose of preserving RECORDS, IYP shall make commercially-reasonable efforts to comply.
- Demonstration that RECORDS have not been retained after contract completion
- At CONTRACT COMPLETION, staff from ORGANIZATION have the right to watch via screensharing technology as IYP staff clear RECORDS. ORGANIZATION staff will have the opportunity to test that their live database is empty prior to the termination of the ACCOUNT for the ORGANIZATION.
- Viewing of RECORDS (“right of access”)
- Regarding the viewing and downloading of RECORDS at a given ORGANIZATION:
- The following may view all INDIVIDUALS:
- ORGANIZATION staff
- STUDIO staff
- IYP staff
- These actions may be performed in the User Interface exposed to administrators, guardians, or students as the case may be.
- Correction of RECORDS (“right of rectification”)
- Regarding the modification of RECORDS at a given ORGANIZATION:
- The following may modify all INDIVIDUALS:
- ORGANIZATION staff
- STUDIO staff
- IYP staff
- The following may, at the ORGANIZATION’S discretion, modify aspects of their own records:
- GUARDIANS and INDIVIDUALS
- These actions may be performed in the User Interface exposed to administrators, guardians, or students as the case may be.
- Removal of RECORDS (“right to be forgotten”)
- Regarding the erasure of RECORDS at a given ORGANIZATION:
- The following may erase all INDIVIDUALS:
- ORGANIZATION staff
- STUDIO staff
- IYP staff
- The following have no means to remove RECORDS:
- GUARDIANS and INDIVIDUALS
- These actions may be performed in the User Interface exposed to administrators.
- Business Events
- In the event of the sales of all or a portion of the assets of IYP, RECORDS may be transferred to the successor entity.
- In the event of bankruptcy of IYP, RECORDS will not be considered as an asset that can be acquired by a third party.