the actual guidelines in the linked pdf are not useful. it does seem to allow, for example, using the content of stuff kids write to train stats models. (writin

the actual guidelines in the linked pdf are not useful. it does seem to allow, for example, using the content of stuff kids write to train stats models. (writing content = 'reasonably necessary to participate in the service', guideline 1, and training a model isn't 'unrelated to provision of school requested service', guideline 2). and the trained model is no longer PII, but can definitely be used to advertise to kids on youtube. (via awareness of topics they like, for example). there are no strong anonymity requirements. no discussion of merging student's profile with their google ad profile in N years when they're out of school, or defaulting to being logged in in the browser. this reads like the ftc has no idea what the harms here are and is unwilling to come down on schools for requesting things that are dystopian, like eye tracking in exams.