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Adopt a district approval and oversight process before any student uses an AI tutoring system. The policy should identify approved tools, limit collection and reuse of student data, define permitted learning and assignment uses, protect accessibility and age needs, and require educators and vendors to explain and review how the systems operate.
What a district AI-tutoring policy must decide
An AI tutoring policy is an operating rule for student-facing software, not a statement that every use of artificial intelligence is good or bad. It should tell a principal, teacher, student, family, technology administrator and vendor what is allowed, who makes the decision, what information may be entered, and what happens when a system produces an unsafe or unreliable answer.
Start by writing a purpose statement tied to learning. The 2025 model policy from the Ohio Department of Education and Workforce describes artificial intelligence as a support for learning and teaching, “not a substitute for student effort or the role of the educator.” That principle is useful outside Ohio when it is translated into enforceable procedures: a tool may provide practice, hints or feedback, while students still demonstrate their own understanding and educators retain instructional judgment.
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Use plain-language definitions
Explain what counts as an AI tutoring system. A practical definition is software that uses machine-learning or generative models to provide individualized explanations, questions, hints, feedback, practice or conversational help to a student. Distinguish generative systems that create new text or other content from routine spelling or grammar suggestions when the difference changes the approval or disclosure rule. Ohio’s model policy makes a similar distinction and allows a district to tailor the terms to its own tools.
Define student data broadly enough to cover education-record information, names, identifiers, account credentials, chat transcripts, voice or image inputs, inferred profiles, disability or language information, location data and device identifiers. Say that a student’s prompt can itself be personal information even when it does not contain a student ID.
Choose a governance model that fits district capacity
Districts generally choose between a broad framework with many approved tools and detailed permissions, or a restrictive model with a small number of centrally managed systems. Neither is universally best. Compare the operating consequences before adopting one.
| Decision factor | Broad approved-tool framework | Restrictive, centrally managed set |
|---|---|---|
| Privacy and contract control | More contracts and configurations to review; controls must be consistent across vendors. | Fewer vendors make data terms, settings and renewals easier to inspect. |
| Instructional flexibility | Teachers can select a tool suited to a subject, language or age when it meets the rules. | Common tools simplify support but may not fit every learning objective. |
| Staff workload | Requires a repeatable intake, training and approved-list maintenance process. | Lower day-to-day selection work, but central staff carry more responsibility for fit. |
| Accessibility and equity | Multiple options can address different disabilities, languages or connectivity limits, provided comparable access is funded. | Standardization can improve consistency but may leave some students without an effective alternative. |
| Family transparency | Requires a clear, current catalog of tools and purposes. | A short catalog is easier to explain and publish. |
| Monitoring | Usage and vendor changes are harder to compare across systems. | Central accounts and logs can make oversight more uniform. |
Whichever model you select, prohibit informal adoption by an individual classroom. The U.S. Department of Education advises teachers to check with school or district administration before using an online application, and the Federal Trade Commission recommends that schools or districts—not individual teachers—decide whether a service’s information practices are appropriate.
Build a district approval and procurement process
Approval should be a documented decision, not a check box based on a vendor demonstration. Assign a named review team that includes instructional leadership, classroom educators, information technology and security, procurement, privacy or records staff, legal counsel, and accessibility expertise. Add special-education, English-learner, library, counseling or assessment specialists when the proposed use affects their work.
Use this approval sequence
- Submit an intake. Record the product name and version, vendor and subcontractors, intended grades and subjects, learning objective, account type, expected prompts and outputs, device and connectivity requirements, proposed duration, and estimated cost. Identify whether the district or a teacher initiated the request.
- Test instructional fit. Have educators try representative tasks using non-identifying data. Check whether explanations align with the curriculum, whether the system can show its reasoning in an age-appropriate way, and whether it encourages productive student effort rather than supplying finished answers. Do not claim that a product improves achievement unless the district has a suitable evaluation.
- Review accessibility and equity. Test keyboard navigation, screen readers, captions, contrast, text resizing, language support and alternative input. Check whether students with disabilities, limited broadband, older devices or limited English proficiency can obtain a comparable support. A tool is not equitable merely because it is available in the app store.
- Review the contract and settings. Compare the proposed agreement, privacy notice, data-processing terms, default retention, account deletion process, security controls, breach notice, subprocessors, model-training permissions and advertising or profiling provisions with district requirements. Marketing claims do not replace contract language.
- Make a written decision. Approve, approve with conditions, defer for missing evidence, or reject. Record the grades, subjects, features and data fields covered by the decision, the responsible owner, the approval date, renewal date and triggers for an earlier review.
- Publish an approved-tool list. Give staff, students and families the product name, permitted purposes, age or grade limits, account method, prohibited data, support contact and last-review date. Remove or flag tools whose contracts expire or settings change.
- Provide an equivalent path. No assignment should require an unapproved service or force a student to create a personal account. Ohio’s model policy uses this principle; districts can meet it with a district-managed tool, a non-AI option or an educator-provided alternative.
Evaluate cost as a continuing obligation
Record license, implementation, training, integration, accessibility and support costs, not just the subscription price. Include the staff time needed for account administration, privacy review, incident response and renewal. If a free tier changes its data practices or limits an essential feature, the district should be able to switch to the approved alternative without disrupting an assignment.
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Review privacy, security and legal conditions
Use one vendor questionnaire for every student-facing AI service. Require the vendor and the proposed contract to answer these questions in specific terms.
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|---|---|
| What information is collected? | Field-level inventory covering prompts, outputs, account data, audio, images, identifiers, inferred characteristics, logs and device data. |
| Why is each field collected? | A purpose tied to the educational service, with optional fields disabled unless needed. |
| Who receives it? | Vendor entities, subprocessors, hosting locations and support personnel, with a current subprocessor list. |
| Is it used for advertising, profiling or model training? | Contractual prohibition or precise limits, including treatment of de-identified or aggregated data. |
| How long is it retained? | Default and maximum retention for live accounts, backups, logs and support tickets. |
| Can the district access and delete it? | Operational procedure, response time, export format and confirmation that deletion reaches subprocessors and backups where applicable. |
| How is it secured? | Authentication, role-based access, encryption, logging, vulnerability management and breach-notification commitments. |
| What age restrictions apply? | Minimum age, parental controls, child-directed features and any regional variation. |
| What happens when the contract ends? | Account closure, data return or deletion, certificate or other evidence, and treatment of student work that the district must retain. |
Apply FERPA based on the actual arrangement
The Department of Education’s FERPA FAQ on classroom online tools explains conditions relevant to an application relying on the school-official exception. The service must perform a function the school would otherwise use staff to perform, remain under the district’s direct control regarding education-record personally identifiable information, follow the district’s annual FERPA rights notice, and avoid unauthorized use or redisclosure.
Have counsel and the district’s privacy official test those conditions against the proposed product and contract. A vendor label such as “FERPA compliant” does not answer whether the district controls the data, whether a feature sends it to another party, or whether the product’s use falls within the educational function. Document the specific feature and account configuration reviewed; a later addition, such as voice recording or a public sharing mode, can change the analysis.
Apply COPPA narrowly for children under 13
The Federal Trade Commission’s Complying with COPPA: Frequently Asked Questions says a school may authorize a service to collect children’s personal information on parents’ behalf when the service is for the school’s use and benefit and for no other commercial purpose. The operator must give the school notice of its collection, use and disclosure practices and enable access and deletion upon request. School authorization is limited to that educational context; it is not blanket consent for every product feature or a vendor’s unrelated commercial use.
The FTC’s FAQ notes that the COPPA Rule was amended on April 22, 2025. Ask counsel to assess the current rule, state student-privacy laws and the exact age and audience of the product. Build a parent-notice and consent path when required, and retain records showing which service, purpose and data practices the district authorized.
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Prohibit students and staff from entering sensitive personal or education-record information into an AI tool unless the district has approved that exact use and its safeguards. Teach users to remove names, student numbers, health details, individualized education information, family circumstances and confidential staff notes from prompts. Configure pseudonymous accounts, disable chat-history sharing, limit administrator access and turn off optional microphone, camera, location and contact permissions. Specify retention, deletion, breach reporting, incident response and subprocessor controls in the agreement.
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Set instructional and assignment boundaries
A district policy should authorize learning purposes, not simply declare that AI is allowed or banned. The following categories give teachers a common vocabulary; each district should map them to grade, subject and assessment rules.
| Use category | Examples | Required condition |
|---|---|---|
| Practice and explanation | Generate additional practice questions, ask for a hint, request an explanation in simpler language, or rehearse vocabulary. | Teacher has verified that the tool and content fit the lesson; students check answers against class materials. |
| Feedback and revision | Ask for suggestions on clarity, structure, grammar or a worked solution after attempting the task. | Students submit their own reasoning and identify the assistance received when the assignment requires disclosure. |
| Language and access support | Translate directions, provide text-to-speech or rephrase a passage at an appropriate reading level. | Use an approved configuration that protects disability, language and identity information. |
| Brainstorming and planning | Generate possible questions, examples or an outline before the student develops the work. | Students evaluate suggestions for accuracy and produce the final response themselves. |
| Restricted or prohibited use | Submitting generated work as original, using a tutor during a closed assessment, entering confidential records, or relying on an unapproved account. | Follow the assignment rule and the district’s academic-integrity and privacy procedures. |
Teachers should state the rule on every assignment where ambiguity could affect grading. A short notice can specify: whether AI is prohibited, allowed for brainstorming, allowed for feedback after a first draft, or required for a named activity; which features may be used; what evidence of student thinking is required; and how assistance must be disclosed or cited. The same course may use different rules for a practice exercise, an oral presentation and a closed-book assessment.
Preserve the educator’s role in deciding whether an answer is correct, culturally appropriate and safe. Require students to verify factual, mathematical, historical and scientific claims against course materials or authoritative references. An AI tutor can be confidently wrong, omit context or reflect bias; a fluent response is not evidence of understanding.
Protect student well-being, accessibility and equity
Require age-appropriate design, supervision and escalation. Younger students may need an adult present, a limited interface, shorter sessions and a predetermined set of prompts. Prohibit systems that encourage secrecy, emotional dependency, unsafe challenges or disclosure of personal information. Give students an easy way to report an output that is harmful, discriminatory, sexually explicit, threatening, inaccurate or otherwise inappropriate, and tell them what an adult will do next.
Test the complete student experience, not just the login screen. Review screen-reader labels, keyboard-only operation, captions, speech input, text alternatives, adjustable reading level, translation quality and compatibility with district assistive technology. Check low-bandwidth behavior, offline alternatives and device requirements. Oregon Department of Education guidance identifies adaptive language supports, personalized feedback and accessible materials as possible benefits while emphasizing equity and careful review; these are potential uses, not guaranteed outcomes.
Provide a comparable non-AI route for students who cannot use the system because of disability, language, connectivity, family preference or an accommodation. Do not require a student to reveal a disability or family circumstance to obtain that alternative. Monitor whether access differs by school, grade, device or course and correct the disparity before expanding use.
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Make transparency and academic integrity practical
Publish a plain-language notice for families and students. It should name approved systems, educational purposes, age or grade limits, major categories of data collected, retention and deletion practices, vendor support contacts, the district privacy contact and the process for requesting an alternative. Update the notice when a material feature or vendor changes.
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Define disclosure expectations in the academic-integrity code. For example, a teacher may require a student to name the tool, describe the prompt or assistance, preserve a draft or chat transcript, and explain which parts of the final work are independently produced. Keep the requirement proportionate: a spelling suggestion need not receive the same citation treatment as generated paragraphs or a solved problem.
Address suspected misuse through existing, fair procedures and human review. Do not treat an automated AI detector as conclusive proof of misconduct; the guidance cited here does not establish detector accuracy. Examine drafts, process evidence, oral explanations, assignment instructions and the student’s account of what happened. Offer a way to challenge a decision and apply the same standard across classrooms.
Train people before opening access
Staff training should be role-specific. Teachers need practice setting assignment permissions, checking outputs, protecting student information, recognizing bias, providing accessible alternatives and documenting incidents. Technology and privacy staff need configuration, logging, deletion and breach-response procedures. Procurement and legal staff need a consistent contract checklist. Principals and counselors need escalation routes for harmful interactions. Students and families need examples of permitted prompts, prohibited data, disclosure expectations and reporting channels.
Use a short, required onboarding module before an account is issued, then provide coaching during the first implementation. Keep a current help page with the approved-tool list, classroom examples, known limitations, accessibility contacts and a form for requesting review of a new feature or use case.
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Monitor outcomes, incidents and vendor changes
Approval is the beginning of oversight. Name an owner for each product and a district owner for the overall policy. Track which schools and grades use a tool, the approved features, training completion, support requests, reported harms, access complaints, data incidents, opt-out or alternative requests, and whether assignments remain aligned with the stated learning objectives. Collect only the information needed for oversight and protect the monitoring records.
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Set a routine review interval in the policy, such as an annual review aligned with procurement and board calendars, and require an earlier review when a vendor changes its model, terms, subprocessor list, age settings, retention, pricing or security; a law or regulation changes; a breach or harmful-output incident occurs; an accessibility audit finds a barrier; or evaluation shows that the tool is not meeting its instructional purpose. Reapprove the exact configuration, not merely the product name.
Use an incident-response branch
- Stop exposure. Ask the student to stop the interaction, preserve the relevant evidence without copying unnecessary personal information, and disable the feature or account if continuing use could cause harm.
- Route the report. Send privacy events to the privacy or security team, student-safety concerns to the designated safeguarding process, and instructional errors to the educator and product owner. Emergencies follow the district’s existing emergency procedure.
- Assess impact. Determine what students, data, prompts, outputs and recipients were involved; whether a vendor or subprocessor received information; and whether notification, deletion or legal reporting duties apply.
- Correct and communicate. Remove or correct harmful material, notify affected people through the appropriate channel, provide an alternative learning activity, and record the decision.
- Reconsider approval. Require vendor remediation, configuration changes, additional training, suspension or termination when the risk cannot be controlled.
Use Ohio’s model as a policy checklist, not a national mandate
Ohio’s Department of Education and Workforce provides a detailed 2025 model policy for Ohio districts and schools. Its sections address purpose, definitions, AI literacy, stakeholder engagement, privacy and security, procurement and tool evaluation, ethical and acceptable use, academic integrity, implementation and review. It is a practical structure for districts elsewhere, but it is not a nationwide legal requirement.
The agency’s AI Model Policy for Ohio Districts and Schools page, last modified January 29, 2026, states that covered traditional public districts, community schools and STEM schools had to adopt a formal AI policy by July 1, 2026. As of October 16, 2026, that Ohio deadline has passed. Districts in other states must check their own statutes, regulations, board rules and contract requirements rather than importing the date or assuming the Ohio coverage applies to them.
Policy language you can adapt
A concise policy should be backed by procedures, forms and technical settings. The following outline keeps the board-level rule readable while assigning operational details to administrative regulations.
- Purpose and principles: AI may support learning when it advances a stated objective; it does not replace student effort, educator judgment or required human support.
- Scope and definitions: Identify covered systems, grades, contexts, accounts, devices and the meaning of AI tutoring, student data and approved tool.
- Authorization: Require district review and written approval before student use; prohibit assignments that require an unavailable or unapproved service.
- Instructional use: Set age-, grade-, subject- and assignment-level permissions, verification duties and alternatives.
- Privacy and security: Specify data minimization, approved fields, access controls, retention, deletion, breach response, subprocessors, model training, advertising and profiling limits.
- Legal compliance: Require review of FERPA, COPPA, state student-privacy, records, accessibility and other applicable obligations for the actual configuration and contract.
- Student well-being: Require age-appropriate supervision, reporting of harmful output and a human escalation path.
- Academic integrity: Define disclosure, citation, evidence of process, prohibited assistance and fair investigation procedures.
- Transparency and participation: Publish the approved-tool list and notice; involve educators, students, families, IT, privacy, procurement, legal and relevant specialists.
- Training and review: Name owners, require training, set routine review and list events that trigger an earlier reassessment.
Turn the outline into three companion documents: a vendor intake and contract checklist, a public approved-tool catalog, and a one-page assignment notice that teachers can copy into a learning-management system. That combination gives the board a durable rule while allowing staff to update product-specific details without rewriting the entire policy.
Quick Recap
A launch checklist for district leaders
- Board or superintendent authority for the policy and a named accountable owner.
- Published scope covering grades, subjects, school and home use, accounts and devices.
- Cross-functional review team with instructional, privacy, IT, procurement, legal and accessibility expertise.
- Approved-tool inventory with purpose, age limits, data fields, settings, contract dates and support contacts.
- Documented FERPA, COPPA and state-law analysis for each proposed arrangement.
- Default-deny settings for optional collection, public sharing, advertising, profiling and model training unless expressly approved.
- Teacher assignment language explaining permitted assistance, disclosure and alternatives.
- Student and family notice, training and a simple reporting channel.
- Accessibility and equity testing, including a comparable non-AI path.
- Incident-response contacts, evidence-handling rules and suspension authority.
- Measures for instructional fit, access, incidents and support burden.
- Routine review date and earlier-review triggers for law, vendor, security, safety or outcome changes.
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