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Policy & Disclaimer

This page is written in plain language so applicants, mentors, and guardians can understand it. It is not legal advice and has not been reviewed by an attorney. Before this platform handles real information from real minors, it needs a licensed attorney's review of privacy, minor-protection, and data-security obligations for every state and country it operates in.

Who this covers

This platform matches applicants — many of them 16–18 years old — with adult mentors across career pathways. This policy applies to applicants, parents and guardians, mentors, and administrators using the site.

Minor protection comes first

No mentor can message or meet an applicant under 18 until every one of these is true: a parent or guardian has consented, an administrator has approved the match, the mentor's identity has been verified, the mentor's background review has cleared, and communication has been explicitly authorized. Any one of these can be revoked at any time, which immediately cuts off further contact. This is enforced in the platform's code, not just described in writing — see src/lib/safety/minorProtection.ts for anyone who wants to verify that directly.

What we collect, and why

We collect what's needed to build a career profile and make a good mentor match: contact info, career interests, and answers to intake questions covering skills, goals, availability, and (for some pathways) physical-demand and health/fitness questions relevant to that specific career — for example, whether someone can meet a physical-fitness standard for firefighting. We do not collect medical records or treatment history, and we ask applicants not to submit any.

Does HIPAA apply to this platform?

Almost certainly not, and it's worth explaining why rather than just asserting it. HIPAA applies to "covered entities" — health plans, healthcare clearinghouses, and healthcare providers who transmit health information electronically for billing or treatment — and to their business associates. This platform doesn't provide medical treatment, doesn't bill insurance, and isn't a healthcare provider, so it doesn't fit the definition of a covered entity even though one of the career pathways is healthcare.

That doesn't mean health-adjacent answers (like fitness-for-duty questions) are unregulated, though. The FTC's Health Breach Notification Rule can apply to apps that handle consumer health information outside of HIPAA, and several states treat health data as "sensitive personal information" under their own privacy laws regardless of HIPAA. Practically, that means: minimize what health-adjacent data we ask for, encrypt it, restrict who can see it, and give people a way to have it deleted — the same practices HIPAA would require, applied voluntarily rather than because a statute demands it.

Does COPPA apply, and what about state 'kids code' laws?

COPPA (the Children's Online Privacy Protection Act) applies to services aimed at, or that knowingly collect personal information from, children under 13. Since this platform is built for 16–18 year olds and isn't directed at children under 13, COPPA itself doesn't apply — as long as we don't knowingly let anyone younger register.

That's a narrower answer than "we're compliant with children's privacy law," though. Several states (California, Maryland, and others) have passed or are litigating broader "age-appropriate design code" style laws that reach minors up to 18, not just under-13s, and most states have separate statutes governing background checks and consent requirements for adults who work with minors in mentoring, coaching, or volunteer programs. Those state-level minor-protection and background-check rules — not COPPA — are the ones most directly relevant to a mentor-matching platform like this one, which is why guardian consent and mentor background review are hard gates here rather than optional settings.

Current state of security — and what still needs to change

Being direct about where this platform actually stands today: applicant and mentor accounts are currently stored in memory with plaintext passwords for demo purposes, not in a production database with hashed credentials. That is explicitly called out as a known limitation in the project's own architecture notes, and it is not acceptable for handling real information from real minors. Before onboarding real users, this needs: a real database, hashed and salted passwords (or a real identity provider), encrypted data at rest and in transit, audit logs of who accessed a minor's information and when, and a written incident-response process.

About Vanta and compliance tooling

One correction worth stating plainly: Vanta is not a free product. It's a paid compliance-automation platform (continuous monitoring toward SOC 2, HIPAA, ISO 27001, and similar frameworks), typically sold on an annual contract. Since HIPAA doesn't apply here and this project doesn't yet need to prove SOC 2 compliance to an enterprise customer, paying for Vanta right now wouldn't buy much — the actual risk here is the plaintext-password, in-memory data store described above, and no compliance-automation subscription fixes that; only the engineering work does.

Free resources that are a better fit at this stage: the OWASP Top 10 and Application Security Verification Standard (self-service security checklists), NIST's Privacy Framework, CISA's free "Cyber Essentials" toolkit for small organizations, and each state's guidance on background-check requirements for youth-serving programs. If this platform later needs to formally prove compliance to a school district, funder, or enterprise partner, a paid tool like Vanta, Drata, or Secureframe becomes worth evaluating — budgeted for as a real line item, not assumed to be free.

Your rights

Applicants, guardians, and mentors can ask us what information we have, ask us to correct it, or ask us to delete it, by reaching out through the Contact page. Guardians of an applicant under 18 can revoke consent for mentor communication at any time, which immediately cuts off further contact per the minor-protection gate described above.

Changes to this policy

This is a living document for a platform still under active development. We'll update it as real data-handling, legal review, and infrastructure work replaces the current preview/demo setup, and we'll note material changes here.

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