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97 changes: 97 additions & 0 deletions Governance/compliance/CHILDRENS_DATA.md
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# Children's Data Policy

## Purpose

This policy sets how TeachLink Web handles personal data about children. As an
education-focused project, it may be used by or on behalf of young learners, and
children deserve extra care. The policy defines the age thresholds, how parental
consent is handled, and how data collected about children is kept to a minimum.
This document is a governance statement, not legal advice; maintainers consult
qualified counsel before relying on it for a legal decision.

## Scope

This policy applies to any feature or integration that collects, processes, or
shares personal data from or about people under the age of majority or digital
consent in their jurisdiction. It is applied together with the [Privacy Notice
governance](../domains/PRIVACY_NOTICE.md), the [Cookie and Consent
governance](../domains/COOKIE_CONSENT.md) and the [Analytics Data
Collection](../domains/ANALYTICS_DATA.md).

## Age Thresholds

The project uses age thresholds that follow the applicable law:

- **Under 13** is treated as a child everywhere; no personal data is collected
from these users without verifiable parental consent, in line with laws such
as COPPA.
- **13 to 15** is treated as a child in jurisdictions where the age of digital
consent is higher (for example up to 16 under the GDPR, which member states
may lower to 13), and parental consent is required there.
- **16 and over** is treated as an adult for consent purposes unless local law
says otherwise.
- Where the user's location is not known, the stricter threshold applies. The
product does not target children under 13 for general use; features designed
for children are introduced only through the project's [RFC
process](../processes/RFC_PROCESS.md) with a privacy review.
- Age is asked for in a neutral way, without encouraging users to misstate it,
and the answer is used only to apply this policy.

## Parental Consent Handling

Where parental consent is required:

- Consent is requested from a parent or guardian, not the child, in plain
language that explains what is collected and why, and how to refuse or
withdraw.
- The method of verifying the parent is proportionate to the risk (for example a
confirmation sent to a parent email address for limited data, stronger checks
for riskier uses). Verification data is used only for verification and deleted
afterwards.
- Consent is recorded as set out in the consent management policy, and a parent
can review the child's data, ask for it to be deleted, and withdraw consent at
any time. The right-to-erasure policy applies, and the deletion is completed
promptly.
- Where a school or institution gives consent on behalf of parents, the
agreement says so and limits the use to the educational purpose.
- If it comes to light that data was collected from a child without valid
consent, collection stops, the data is deleted unless the law requires
otherwise, and the family is told.

## Data Minimisation

Children's data is held to a higher standard:

- Collect only what is strictly needed to provide the educational feature; no
profiling, behavioural advertising, or sale of children's data.
- No optional analytics, third-party trackers, or public profiles for children
by default (see the [Third-Party Scripts
governance](../domains/THIRD_PARTY_SCRIPTS.md)), and default settings are the
most private ones.
- Do not publish children's names, photos, or contributions with identifying
details without parental consent, and never display contact information.
- Retention is as short as possible, and data is deleted when the purpose ends
or when the account is closed, following the record retention and legal hold
policy.
- Maintainers must not copy children's data into issues, chats, or test
fixtures; use synthetic data.
- A privacy review is required before any feature that could be used by children
is released.

## Ownership and Review

- Maintainers own this document and are accountable for applying it
consistently.
- The privacy owner reviews this policy once a year and whenever laws on
children's data change.
- Changes are proposed in a pull request that touches only the `Governance/`
folder and are reviewed like any other governance change (see the [Review
Policy](../policies/REVIEW_POLICY.md)).
- This document is versioned with the repository and describes how the project
actually operates rather than an aspiration.

## Success

This policy succeeds when no personal data is collected from a child without the
consent the law requires, when parents can see and control what is held, and
when the project holds as little about children as it can.
83 changes: 83 additions & 0 deletions Governance/compliance/EXPORT_CONTROL.md
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# Export Control Policy

## Purpose

This policy explains how TeachLink Web handles export control laws, which
restrict transferring certain technology, software, or services across borders
or to certain parties. It helps the project and its contributors stay within the
law without hindering open collaboration. This document is a governance
statement, not legal advice; maintainers consult qualified counsel before
relying on it for a legal decision.

## Scope

This policy applies to the software, documentation, and any encryption or other
controlled technology published by the project, and to maintainers and
contributors who handle project releases, distribution, and contracts. It
applies alongside the sanctions compliance policy in this folder
([SANCTIONS.md](SANCTIONS.md)).

## Applicable Restrictions

The project aims to understand and respect the restrictions that may apply:

- Laws such as the US Export Administration Regulations and the equivalent rules
of the EU and other jurisdictions where maintainers or infrastructure are
located.
- Controls on cryptography and security software: the project's use of standard
encryption in a web application, and any publicly available open-source source
code, is generally treated as eligible for broad release, but this is
confirmed with counsel when the code changes materially.
- Controls on destinations, end users, and end uses (for example embargoed
regions and military end uses).
- A classification note for the project is kept by the maintainers, stating what
was assessed, by whom, and when, and is reviewed whenever new cryptographic
functionality or a new distribution channel is added.

## Screening Process

Screening is risk-based and proportionate:

- Open publication of source code on a public repository is not individually
screened; the project does not collect enough information to do so.
- Before entering a contract, accepting a sponsorship, or providing private
services or support, a maintainer screens the counterparty against the lists
named in the sanctions compliance policy and records the result.
- Before a release or change that adds or modifies cryptographic features, a
maintainer checks the classification note and asks counsel when unsure.
- Maintainers who suspect that a transfer, contribution, or request would breach
export controls stop and raise it with the lead maintainers before proceeding.

## Exception Handling

When a restriction applies or may apply:

- The lead maintainers decide how to proceed, usually after consulting counsel:
for example restricting a service for a party, applying for a licence, or
changing a release.
- An exception to the usual practice (for example proceeding while a
classification is pending) needs written approval from two maintainers and
counsel's advice, and is recorded with its reason and expiry.
- No exception permits a transfer that is prohibited by law.
- Possible violations are reported privately to the lead maintainers, who
investigate, contain the issue, assess any duty to disclose to authorities,
and record the outcome. People who report in good faith are protected from
retaliation under the [Code of Conduct](../CODE_OF_CONDUCT.md).

## Ownership and Review

- Maintainers own this document and are accountable for applying it
consistently.
- The classification note and screening records are reviewed at least once a
year and at every change in cryptographic functionality.
- Changes are proposed in a pull request that touches only the `Governance/`
folder and are reviewed like any other governance change (see the [Review
Policy](../policies/REVIEW_POLICY.md)).
- This document is versioned with the repository and describes how the project
actually operates rather than an aspiration.

## Success

This policy succeeds when the project can show what it assessed and when, when
screening happens before private transfers, and when concerns are raised early
and resolved on the advice of counsel.
89 changes: 89 additions & 0 deletions Governance/compliance/PRIVACY_POLICY_GOVERNANCE.md
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# Privacy Policy Governance

## Purpose

This document governs the privacy policy that TeachLink Web publishes to its
users: who owns it, how it is updated and reviewed, and how its versions are
tracked. It ensures the published policy always matches what the project
actually does with personal data, and that users are told when it changes. This
document is a governance statement, not legal advice; maintainers consult
qualified counsel before relying on it for a legal decision.

## Scope

This document applies to the user-facing privacy policy and to any notice that
describes how personal data is collected, used, shared, or retained. The content
rules for the notice are in the [Privacy Notice
governance](../domains/PRIVACY_NOTICE.md); consent rules are in the [Cookie and
Consent governance](../domains/COOKIE_CONSENT.md); and what data may be
collected is in [Analytics Data Collection](../domains/ANALYTICS_DATA.md).

## Ownership

Responsibility for the privacy policy is clear:

- A maintainer is named **privacy owner**, is responsible for the accuracy of
the published policy, and acts as the contact for privacy questions.
- A second maintainer is named **deputy** so the role is never vacant; both are
recorded in the maintainer records.
- Counsel or an external privacy adviser is consulted for material changes, new
jurisdictions, and legal requests.
- The privacy owner does not approve their own changes; another maintainer
reviews every edit.
- If no owner is in place, the lead maintainers act as owners until one is
appointed within 30 days.

## Update and Review Process

The policy changes only through a controlled process:

- **Trigger.** A change to what data is collected, why, who receives it, where
it is stored, or how long it is kept requires an update before the change
ships. Legal changes, a new vendor, or an incident can also trigger one.
- **Draft.** The privacy owner proposes the change in a pull request that
explains what changed and why, with a plain-language summary of the effect on
users.
- **Review.** At least two maintainers review it, one of them independent of the
change. Material changes also get input from counsel and are open to community
comment for at least 14 days, unless an urgent legal or security reason
shortens it.
- **Publication.** The approved policy is published with its version and
effective date, and users are notified of material changes at least 30 days
before they take effect where the law or the change makes this appropriate.
- **Scheduled review.** The policy is reviewed at least once a year even if
nothing has changed, and the review is recorded.

## Versioning

Every published policy has a version and an archive:

- Versions use `MAJOR.MINOR`: a **major** version changes what is collected, the
purposes, or users' rights; a **minor** version corrects wording without
changing meaning.
- Each version shows its number, effective date, and a short change log at the
top of the published policy.
- Earlier versions are kept in an accessible archive so a user can see what
applied when they signed up or consented, which supports the consent records
described in the consent management policy.
- Changes that need new consent trigger a new consent request instead of relying
on the earlier one.
- The version in the product, the repository, and any translation must match;
mismatches are fixed as defects.

## Ownership and Review

- Maintainers own this document and are accountable for applying it
consistently.
- The privacy owner reports to the maintainers each year on reviews done,
changes made, and open privacy questions.
- Changes are proposed in a pull request that touches only the `Governance/`
folder and are reviewed like any other governance change (see the [Review
Policy](../policies/REVIEW_POLICY.md)).
- This document is versioned with the repository and describes how the project
actually operates rather than an aspiration.

## Success

This document succeeds when the published privacy policy is accurate, owned, and
versioned, when users are told about material changes in time, and when every
past version can be retrieved.
86 changes: 86 additions & 0 deletions Governance/compliance/SANCTIONS.md
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# Sanctions Compliance Policy

## Purpose

This policy sets out how TeachLink Web complies with economic and trade
sanctions: the screening that is required, how dealings with a prohibited party
are handled, and how doubts are escalated. It protects the project, its
maintainers, and its funders from inadvertently breaching sanctions law. This
document is a governance statement, not legal advice; maintainers consult
qualified counsel before relying on it for a legal decision.

## Scope

This policy applies to financial and contractual dealings of the project:
receiving donations or sponsorship, paying vendors or contributors, entering
agreements, hosting events, and granting paid or privileged access to services.
It does not restrict participation in the public open-source repository, which
follows the [Code of Conduct](../CODE_OF_CONDUCT.md) and legal advice on open
publication, and it complements the export control policy in this folder
([EXPORT_CONTROL.md](EXPORT_CONTROL.md)).

## Screening Requirement

Before a financial or contractual relationship starts:

- A maintainer, usually the [Treasurer role](../roles/TREASURER.md), screens the
individual or organisation, and any known beneficial owners, against the
consolidated sanctions lists of the jurisdictions that apply to the project,
such as those of the US Treasury (OFAC), the UN, the EU, and the UK.
- Screening is repeated at least once a year for recurring relationships, and
whenever the lists change in a way that may affect an existing partner.
- Results and the lists checked are recorded with the date and the person who
screened them; a match, a partial match, or an inability to complete screening
is recorded as such.
- The project does not rely on a counterparty's own assurances alone for
relationships of significant value.

## Prohibited Parties Handling

If a party is on a sanctions list, or the dealing would involve a sanctioned
country or party:

- The relationship is not started, or is paused at once if already under way.
Funds are not accepted or sent, and no services are provided.
- If funds have been received from a prohibited party, they are not used or
returned without legal advice, as returning them can also be prohibited; the
funds are held and counsel is consulted.
- The party is told only as much as is necessary and legally permitted. The
matter is kept confidential and not discussed in public channels.
- Contributors do not circumvent sanctions on behalf of anyone, for example by
routing payments through intermediaries.
- Ordinary open-source participation, such as reading the public code or filing
issues, is not blocked by this policy unless counsel advises that the law
requires it.

## Escalation

Anyone who suspects a sanctions issue acts promptly:

- Raise it privately with the treasurer or the lead maintainers; do not
investigate on your own or tip off the party.
- The lead maintainers decide on the response, consult counsel, and decide
whether authorities or banks must be notified.
- Decisions and their reasons are recorded, and the screening process is
reviewed afterwards for gaps.
- Retaliation against someone who raises a concern in good faith is a conduct
matter under the [Code of Conduct reporting](../COC_REPORTING.md).
- This policy is reviewed once a year and after any sanctions incident.

## Ownership and Review

- Maintainers own this document and are accountable for applying it
consistently.
- The treasurer keeps the screening log and reports on screenings and matches to
the maintainers each year.
- Changes are proposed in a pull request that touches only the `Governance/`
folder and are reviewed like any other governance change (see the [Review
Policy](../policies/REVIEW_POLICY.md)).
- This document is versioned with the repository and describes how the project
actually operates rather than an aspiration.

## Success

This policy succeeds when screening is done and recorded before relationships
begin, when prohibited dealings are stopped and escalated early, and when the
project never has to explain a breach it could have prevented.
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