PRIVACY POLICY

Hózhó Academy
515 Park Ave.
Gallup, NM 87301
(505) 722-8922
office@hozhoacademy.org

Last Updated: April 8, 2025

INTRODUCTION

Hózhó Academy ("we," "our," or "the School") is a tuition-free New Mexico Charter School committed to developing students in mind and character through a classical, content-rich curriculum that emphasizes the principles of virtuous living, traditional learning, and civic responsibility. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of personal information in compliance with federal and state laws, including the Family Educational Rights and Privacy Act (FERPA), Children's Online Privacy Protection Act (COPPA), Protection of Pupil Rights Amendment (PPRA), Individuals with Disabilities Education Act (IDEA), Health Insurance Portability and Accountability Act (HIPAA), and applicable New Mexico state laws.

SCOPE

This Privacy Policy applies to all information collected by or submitted to Hózhó Academy, including:

  • Our website and online services
  • School applications and enrollment processes
  • Educational services and programs
  • School events and activities
  • Employment applications and processes
  • Vendor and contractor relationships

INFORMATION WE COLLECT

Student Information

We collect the following categories of student information:

  • Personal identifiers (name, date of birth, address, contact information)
  • Demographic information (race, ethnicity, language preference, tribal affiliation if applicable)
  • Academic records (grades, test scores, attendance, disciplinary records)
  • Health information (medical conditions, immunization records, medications)
  • Special education documentation and individualized education plans
  • Photographs and video recordings for educational and school-related purposes
  • Online activity information when using school-provided devices or networks

Parent/Guardian Information

  • Personal identifiers (name, address, contact information)
  • Relationship to student(s)
  • Communication preferences
  • Financial information for school-related programs or services

Employee Information

  • Personal identifiers and contact information
  • Employment history and qualifications
  • Background check results
  • Performance evaluations
  • Benefits and payroll information

Website and Technology Information

  • IP addresses and device information
  • Browser type and settings
  • Usage data and cookies
  • Log files and analytics

HOW WE USE INFORMATION

We use the information we collect for the following purposes:

  • To provide classical education services and support student learning in mind and character
  • To communicate with parents/guardians about student progress and school activities
  • To maintain a safe and secure school environment
  • To comply with reporting requirements to state and federal agencies
  • To improve our educational programs and content-rich curriculum
  • To administer employment benefits and payroll
  • To respond to inquiries and provide customer service
  • To maintain and improve our website and technology resources

LEGAL BASIS FOR INFORMATION COLLECTION AND USE

We collect and use personal information based on one or more of the following legal bases:

  • To fulfill our educational mission of traditional learning and civic responsibility
  • To comply with legal and regulatory requirements
  • With consent, where required by law
  • For the legitimate interests of operating a New Mexico Charter School

INFORMATION SHARING AND DISCLOSURE

We may share personal information with the following categories of recipients:

Educational Partners and Service Providers

We may share information with third parties who provide services to support our educational mission, including:

  • Educational software and application providers
  • Student information systems
  • Assessment platforms
  • Transportation services
  • Food service providers
  • Consultants and professional service providers

All service providers are required to maintain the confidentiality and security of the information we provide and are prohibited from using it for purposes other than providing services to the School.

Government Agencies

We may disclose information to government agencies as required by law, including:

  • New Mexico Public Education Department
  • McKinley County officials
  • U.S. Department of Education
  • Other federal, state, or local agencies as required

Directory Information

Consistent with FERPA, we may disclose directory information, which includes:

  • Student's name
  • Address
  • Telephone number
  • Date and place of birth
  • Honors and awards
  • Dates of attendance

Parents/guardians have the right to opt out of the disclosure of directory information by submitting a written request to the School administration at registrar@hozhoacademy.org.

Emergency Situations

We may disclose personal information in emergency situations where the health or safety of a student or other individuals is at risk.

STUDENT DATA PRIVACY PROTECTIONS

We are committed to protecting student data privacy in accordance with applicable laws:

FERPA Compliance

The Family Educational Rights and Privacy Act (FERPA) gives parents/guardians and eligible students (18 years or older) certain rights regarding student education records, including:

  • The right to inspect and review education records
  • The right to request amendment of records believed to be inaccurate
  • The right to consent to disclosures of personally identifiable information, except as provided by law
  • The right to file a complaint with the U.S. Department of Education

COPPA Compliance

For online services directed to children under 13, we comply with the Children's Online Privacy Protection Act (COPPA) by:

  • Obtaining verifiable parental consent before collecting personal information from children
  • Providing notice about our information practices
  • Giving parents the ability to review and delete their child's information
  • Maintaining the confidentiality and security of children's information

PPRA Compliance

In accordance with the Protection of Pupil Rights Amendment (PPRA), we:

  • Obtain written consent before students are required to participate in surveys that reveal protected information
  • Provide notice and opt-out opportunities for certain activities
  • Develop policies in consultation with parents regarding these protections

DATA SECURITY

We implement appropriate physical, technical, and administrative security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Secure storage systems for physical records
  • Access controls and authentication procedures
  • Encryption for sensitive data
  • Regular security assessments and audits
  • Staff training on data privacy and security practices

Despite our efforts, no security measures are perfect or impenetrable. In the event of a data breach that compromises personal information, we will provide notice as required by applicable law.

DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Student records are maintained in accordance with state and federal requirements.

YOUR RIGHTS AND CHOICES

Parents/Guardians and Eligible Students

In addition to FERPA rights, parents/guardians and eligible students may:

  • Request access to personal information we hold
  • Request correction of inaccurate information
  • Opt out of directory information disclosure
  • Withdraw consent for specific uses of information where applicable
  • Request deletion of information where applicable and not contrary to legal requirements

To exercise these rights, please contact our Privacy Officer at registrar@hozhoacademy.org.

Employees

Employees may:

  • Access and update personal information maintained in employment records
  • Request additional privacy protections for sensitive information
  • Receive notice of information disclosures as required by law

Website Visitors

Visitors to our website may:

  • Disable cookies through browser settings
  • Opt out of analytics tracking where available
  • Request information about data collected through our website

NATIVE AMERICAN STUDENT PROTECTIONS

In recognition of our diverse student population including many Native American students, we implement additional protections for tribal cultural information and identity:

  • Respect for and protection of cultural information shared in educational contexts
  • Consultation with tribal authorities when applicable regarding student information
  • Compliance with the Indian Child Welfare Act where applicable
  • Protection of tribal affiliation information

SPECIAL EDUCATION RECORDS

For students receiving special education services, we maintain additional protections for these sensitive records in compliance with IDEA, including:

  • Heightened security for special education files
  • Limited access to authorized personnel
  • Specific consent requirements for certain disclosures
  • Extended record retention schedules as required by law

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will post the updated Privacy Policy on our website and indicate the date of the latest revision. For significant changes, we will provide additional notice as required by law.

CONTACT INFORMATION

For questions or concerns about this Privacy Policy or our privacy practices, please contact:

Privacy OfficerHózhó Academy515 Park Ave.Gallup, NM 87301(505) 722-8922registrar@hozhoacademy.org

ADDITIONAL RIGHTS UNDER NEW MEXICO LAW

Under New Mexico law, individuals have additional rights regarding personal information, including:

  • The right to be informed about the personal information we collect and how it is used
  • The right to request disclosure of security breaches involving personal information
  • Specific protections under the New Mexico Inspection of Public Records Act

GOVERNING LAW

This Privacy Policy is governed by the laws of the State of New Mexico and applicable federal laws of the United States.

By enrolling your child in Hózhó Academy, applying for employment, or using our services, you acknowledge that you have read and understand this Privacy Policy.

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