Critical Thinking Breakouts — Privacy, Compliance & Accessibility

1 · What this tool actually does

The Critical Thinking Breakouts are self-contained HTML files that run entirely inside the student's web browser. There is no server behind them, no account to create, and no database. Each breakout teaches real-world reasoning — logic, media literacy, and scientific skepticism — through a clue board and four locks.

One honest exception (external request): the page links to Google Fonts to load its two display fonts. That request goes to Google's font servers and, like any web font request, exposes standard request metadata (such as IP address and browser type) to Google — but carries no student work, no answers, and no identifying content from the breakouts. A school that wants a truly zero-external-request build can ask for a version with the fonts embedded in the file (or substitute system fonts); the breakouts is otherwise unchanged.

2 · Short version

• The Critical Thinking Breakouts does not require or create student accounts.
• It does not collect, store on a server, sell, or share student data.
• It does not use student data for advertising, profiling, or AI training.
• It uses no third-party trackers, ad networks, or analytics.
• The only data that exists is in-the-moment game progress, which stays in the browser and disappears when the tab is closed or reloaded.
• The breakouts runs offline after loading; the only optional outside request is the Google Fonts stylesheet.
• Teachers and schools decide how the breakouts is shared and where it is hosted.
• Because nothing is collected, there is no stored student record for anyone — including the author — to access, mine, or breach.

3 · Terms of use

Who may use it

The Critical Thinking Breakouts may be used by educators, students under school supervision, families, schools, and districts. When used with students, the teacher, school, or district decides whether it is appropriate for those students and obtains any consent their local policy requires.

Acceptable use

Use the breakouts for classroom and at-home critical-thinking practice. Do not modify it to collect personal data, add tracking, or present unsafe content to students. Do not represent the breakouts as endorsed by, or as collecting data on behalf of, any organization that has not agreed to that.

Ownership & license

The Critical Thinking Breakouts is an educational resource created by Miguel Guhlin (MGuhlin.org / TCEA). Schools, teachers, and others may freely use, copy, host, adapt, remix, and redistribute it — including for commercial purposes — with attribution, under a Creative Commons Attribution 4.0 International (CC BY 4.0) license. Because Creative Commons licenses are not designed for software, the underlying source code may alternatively be reused under the MIT License; either way, attribution to Miguel Guhlin / TCEA is required. Suggested attribution: “Critical Thinking Breakouts by Miguel Guhlin (TCEA), CC BY 4.0.”

As-is, no warranty

The breakouts is provided "as is," without warranty of uninterrupted availability, fitness for a particular purpose, or guaranteed legal compliance for a specific school system. Schools remain responsible for deciding whether it fits their requirements.

4 · Privacy policy

What "student personal information" means here

Student personal information is any information that identifies, relates to, or can reasonably be linked to a student — names, identifiers, work product, uploads, recordings, or activity logs tied to a student.

What the breakouts collects

None of the above. These breakouts have no field to enter a name, no upload, no microphone or camera use, no login, and no code that sends data to any server. It does not read precise location, contacts, or device identifiers.

What is processed, and where

• In-memory game state (which step you're on, which answers you picked, which cases you solved) lives only in the browser tab and is gone on close/reload.
• URL hash (e.g. #case=cupcakes) records only which case is open, so a teacher can link to a specific one. It contains no personal data.
• Google Fonts request — the single external call, described in section 1, carries no game content.

How any of it is used

Only to run the breakouts on the student's screen — show the case, check answers, and display progress. There is no other use, because there is no other place for the data to go.

What the breakouts does not do

No advertising, no behavioral profiling, no cross-site tracking, no sale or sharing of data, no AI model training, and no re-identification of anyone.

5 · Student-privacy commitments (PROTECT)

P — Parental rights & access

Because no student data is stored anywhere, there is no record to access, correct, export, or delete on a server. Parents and eligible students with questions should contact the teacher or school that assigned the breakouts (see section 11). Schools respond under FERPA, COPPA, state law, and local policy.

R — Retention & deletion

Nothing is retained off the device. To clear in-browser game state, close or reload the tab, or clear the browser's site data. There is no backup, snapshot, or stored copy to purge.

O — Opt-out options

There is nothing to opt out of: no ads, no profiling, no data sale, no AI training. A school wanting zero external requests can use the embedded-fonts build (section 1).

T — Transparency

This page lists every data behavior and the single external request. The full source is one readable HTML file a district can inspect.

E — Encryption & security

Serve the file over HTTPS in production so it is delivered securely. There is no server-side data store to encrypt because no data is stored server-side.

C — Consent & age

Designed for grades 3–8, which includes children under 13. Because the breakouts collects no personal information, it is built to be usable without triggering data-collection consent requirements; schools still follow their local consent and notice process. (See COPPA in section 7.)

T — Third-party management

No third-party service receives student data. The only third-party endpoint touched is the Google Fonts CDN, for fonts only (section 9).

6 · GDPR compliance summary

For schools where the UK GDPR or EU GDPR may apply (including EU/UK students or staff), the Critical Thinking Breakouts is designed around data minimization by default: it processes no personal data, so most GDPR obligations have nothing to attach to.

Roles

For any classroom deployment, the school or district is the data controller. The breakouts's author has no access to any student data and operates, at most, as a provider of software that performs no processing of personal data on the author's behalf.

Lawful basis & minimization

Because the tool collects and transmits no personal data, there is no processing requiring a lawful basis under Article 6, and the principle of data minimization (Article 5(1)(c)) is met at the strongest level — nothing is collected.

Data-subject rights (Articles 15–22)

International transfers

No personal data is transferred anywhere. The Google Fonts request involves Google as an independent font provider; schools with strict transfer requirements can eliminate even that by using the embedded-fonts build. [EU/UK districts: confirm font-CDN posture with your DPO if relevant.]

7 · Texas compliance

Plain-language mapping to the Texas and federal rules that apply to K–12 students. Not legal advice; your district counsel should confirm against your DSA.

Texas SCOPE Act (Securing Children Online through Parental Empowerment)

SCOPE protects Texas minors under 18 with rules on age registration, parental controls, harmful-content strategies, and data-use limits. These breakouts have no account system, so there is no age to register or lock, and it has no data-collection or advertising to limit. It presents only fixed, teacher-reviewable educational case content. Note that some SCOPE provisions have been challenged and partly enjoined in federal court; this tool reflects only what such a no-account, no-data tool would need, not enjoined provisions.

FERPA (Family Educational Rights and Privacy Act)

FERPA governs education records. The breakouts creates no education record (no stored, identifiable student work). When a school uses it for instruction, the school retains full control; there is no vendor-held record to inspect, correct, or disclose.

COPPA (Children's Online Privacy Protection Act)

COPPA governs collecting personal information from children under 13. The Critical Thinking Breakouts collects no personal information from any child, which is the cleanest possible COPPA posture. Where a school uses it with under-13 students, the district may act as the parent's agent for consent under its existing policy, though no collection is occurring.

Texas Education Code §32.151–32.156

This framework governs data agreements between districts and online service providers handling covered student information. Because the breakouts transmits no covered student information, there is no data exchange to govern; a district may still attach the short addendum in section 8 to its records.

CIPA (Children's Internet Protection Act)

CIPA is a network-level obligation on schools and libraries (an internet filter plus an internet-safety policy) — not a privacy law on a tool. The Critical Thinking Breakouts contains no external links for students to follow, no chat, no uploads, and no user-generated content, so it introduces no new filtering surface. It does not replace the district's required network filter or internet-safety policy.

8 · District data privacy addendum (short form)

A district that catalogs classroom tools may attach this short attestation. A full signature-ready addendum is unnecessary for a tool that collects no student data, but the fields below can be filled in for recordkeeping.

9 · Third-party & data inventory

Network egress declaration: aside from the optional Google Fonts stylesheet, the breakouts makes zero outbound network requests. It contains no analytics, advertising, tracking, social, or backend calls. This is verifiable by reading the single source file.

10 · Accessibility statement (VPAT-lite)

The Critical Thinking Breakouts aims to meet WCAG 2.1 Level AA for this kind of interactive content. This summary is for procurement reviewers who want a VPAT-style overview without the full form.

Known gaps (stated honestly)

• A complete keyboard-only and screen-reader audit has not yet been performed; some controls may lack ideal ARIA labeling or a visible focus ring.
• prefers-reduced-motion is not yet wired to the confetti animation.
• No structured ITI VPAT 2.5 document has been completed; this lite statement stands in its place.

To report an accessibility barrier, contact the deploying teacher or school, or reach the author directly: Miguel Guhlin — mguhlin@tcea.org.

11 · Contact, requests & policy changes

For classroom use, privacy or accessibility requests should go first to the teacher, school, or district that deployed the breakouts. Because no student data is collected or stored by the tool, there is no provider-held record to retrieve or delete; schools handle any related education-record requests under their own FERPA/COPPA process and should acknowledge within 10 school days and complete within 30 calendar days when feasible.

Author / resource contact: Miguel Guhlin — mguhlin@tcea.org (TCEA / MGuhlin.org).

Material changes to this policy will be posted here with an updated date and version.

Version history