09 - Security, Compliance, And Operational Risk

Security Baseline

  • Identity and access management with least privilege and strict parent/tutor/admin separation.

  • Encryption in transit and at rest.

  • Centralized logging and audit trails with 1-year retention minimum.

  • Vulnerability management with remediation SLAs.

  • Annual penetration test before broad MSP scaling.

Compliance Scope

Standard

Required

Current Status

Gap

Owner

COPPA

Yes

In progress

Parental consent record automation

Product + Legal

FERPA

Conditional (school channel)

In progress

Data sharing agreement templates per partner

Legal

SOC 2 Type I

Yes (MSP)

Planned

Control evidence collection and auditor engagement

Security

SOC 2 Type II

Later phase

Not started

Operating period evidence

Security

GDPR/CCPA

Conditional by region

Planned

DSAR automation and deletion workflows

Engineering

Risk Register

Risk

Category

Probability

Impact

Mitigation

Owner

Exposure of student PII through misconfigured access

Security

Low

Critical

Strict RBAC defaults, access reviews, tenant boundary tests

Security

Child safety incident in live session context

Safety

Low

Critical

Tutor screening, session conduct policy, reporting and escalation workflow

Tutor Ops + Legal

Scheduling or tutor availability gaps reduce continuity

Operational

Medium

High

Capacity planning, backup bench, continuity SLA monitoring

Tutor Ops

Payment failures or billing confusion increase churn

Commercial

Medium

Medium

Dunning logic, clear billing UX, rapid support handoff

Revenue Ops

Bias or uneven efficacy across student subgroups

Product/Ethics

Medium

High

Subgroup outcome monitoring and curriculum review checkpoints

PM + Curriculum

Incident Management

  • Incident severity model defined (Sev-1 to Sev-4).

  • On-call and escalation policy documented.

  • Target response times: Sev-1 acknowledge <=15 minutes, Sev-2 <=30 minutes.

  • Post-incident review required within 5 business days.

Reliability Targets

  • Availability SLO: 99.9% monthly for core learner, tutor, and parent workflows.

  • Latency SLO: p95 <=400 ms for key session and scheduling interactions.

  • Error budget policy: Monthly error budget tied to feature release velocity; freeze high-risk launches when budget exhausted.

Controls Review Cadence

  • Monthly control audit.

  • Quarterly tabletop incident exercise.

  • Annual external assessment.

  • Quarterly privacy review for student data minimization and retention limits.