Children's Online Privacy
Protection Notice
Access 2 Play serves youth athletes. This notice explains exactly how we handle personal information about children, what rights parents and guardians have, and the safeguards we maintain to protect every child we serve.
For Parents & Guardians: This notice describes every aspect of how Access 2 Play handles information about the young athletes in our programs. We collect only what is necessary for grant administration, never sell children's data, never market to minors, and never post photos of children without your written consent. Your child's privacy is not negotiable for us.
Overview & Our Commitment
Access 2 Play, Inc. ("A2P") exists to serve youth athletes — children and teenagers who deserve access to sports regardless of their family's financial situation. Because our mission centers on young people, we take children's privacy exceptionally seriously.
This notice describes our practices with respect to the personal information of children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and the implementing regulations at 16 C.F.R. Part 312.
We also extend heightened privacy protections to athletes between the ages of 13 and 17, even though they are not covered by COPPA, because we believe every minor deserves strong privacy safeguards.
Our core commitments regarding children's data:
We collect only what is necessary. We never sell children's data. We never market to minors. We never share children's information beyond what is needed to administer their grant. We never post photos or videos of minors without written parental consent. Parents can request, correct, or delete their child's information at any time.
Who This Notice Applies To
This COPPA Notice applies specifically to:
- Children under 13 whose information is submitted in connection with A2P programs (governed by COPPA)
- Minors ages 13–17 who participate in A2P-funded programs (subject to A2P's extended protections)
- Parents and legal guardians of minor athletes who submit information on their child's behalf
This notice applies to information collected through our website, grant application forms, event registrations, and any other A2P program interaction involving minors.
Our Website & Children
Our website is directed at adults — not children. The Access 2 Play website is designed for parents, guardians, coaches, donors, corporate partners, and community members. Children under 13 should not submit personal information through our website independently.
We do not knowingly collect personal information directly from children under 13 through general website interactions such as:
- Newsletter signups
- Contact forms
- Blog comments
- Event registrations without parental submission
What Happens if a Child Submits Information
If we discover that we have inadvertently collected personal information directly from a child under 13 without verifiable parental consent, we will:
Upon discovery, we will immediately remove the information from our records and any third-party service providers who received it.
If we have contact information for a parent or guardian, we will notify them of the situation.
We will review how the information was collected to prevent recurrence.
If you believe your child has submitted information to our website without your consent, please contact us immediately at info@access2play.org with the subject line "COPPA — Unauthorized Submission."
Grant Applications & Minors
Our youth athlete grant program is the primary way A2P interacts with information about minors. Grant applications are submitted by parents or legal guardians on behalf of their child.
Parental Submission Requirement
By submitting a grant application that includes information about a minor, the submitting adult represents and warrants that they are:
- The parent or legal guardian of the minor named in the application, or
- Otherwise legally authorized to submit the minor's personal information on their behalf
Coach Verification
As part of our grant verification process, we contact the coach or program director listed in the application to confirm the athlete's participation. This contact receives only the athlete's first name, sport, and grant status — no household financial information, date of birth, or home address is shared with the coach for verification purposes.
Important: If you are a coach or program director who receives a verification inquiry from A2P, you are receiving it because a parent or guardian listed you in their grant application. Your response helps us ensure grant funds reach athletes who are actively participating in organized programs.
What We Collect About Minors
The following information about minor athletes may be collected as part of a grant application submitted by a parent or guardian:
| Information Type | Why We Collect It | Required? |
|---|---|---|
| First and last name | Identify the grant recipient | Required |
| Date of birth | Verify age eligibility (5–18) | Required |
| County of residence | Confirm Maryland service area | Required |
| Home address | Geographic verification | Required |
| Sport and program name | Determine grant eligibility and type | Required |
| School enrollment status | Verify active participation | Required |
| Specific funding need description | Assess appropriate grant amount | Required |
| Prior A2P grant history | Manage repeat applicants and fund allocation | Required |
We do not collect the following about minors:
- Social Security numbers or government ID numbers
- Medical or health records (beyond self-reported conditions in liability waivers)
- Geolocation data
- Device identifiers or online activity data
- Photos or videos without explicit written parental consent
How We Use Information About Minors
Information about minor athletes is used solely for the following purposes:
- Reviewing and deciding on grant applications
- Verifying athlete enrollment and program participation with the listed coach or director
- Disbursing approved grant funds to the identified program, club, or vendor
- Following up with parents or guardians about grant status or renewal opportunities
- Producing aggregate, de-identified impact reports (e.g., "X athletes funded in Baltimore County")
- Complying with legal obligations including mandatory child safety reporting
We never use minor athletes' information for:
- Marketing, advertising, or promotional targeting
- Sale, rental, or licensing to third parties
- Profiling or automated decision-making beyond grant review
- Research that has not been approved by organizational leadership
- Any purpose not described in this notice
How We Protect Information About Minors
We apply heightened security measures to records containing information about minors:
Access Controls
Grant application records are accessible only to A2P staff and board members directly involved in grant review and administration. Access is role-based and audited.
Secure Transmission
All grant application submissions are transmitted via HTTPS encryption. We use reputable form processing providers with their own security standards.
Storage Security
Grant records are stored in secure, access-controlled systems. We do not store children's data on personal devices or in unsecured cloud environments.
Staff Training
All A2P staff, coaches, and volunteers with access to athlete information are trained on confidentiality obligations and the requirements of this COPPA Notice.
Breach Response
In the event of a data breach involving minor athletes' information, A2P will notify affected parents or guardians within 72 hours of discovery and take immediate remediation steps.
Who We Share Minor Data With
We do not sell, rent, or trade information about minors to any third party under any circumstances.
Limited sharing occurs only in the following situations:
Coaches & Program Directors (Verification Only)
The coach or program director listed in a grant application receives: athlete first name, sport, and whether a grant has been approved. No household income, date of birth, home address, or other personal details are shared.
Grant Fund Recipients
When a grant is approved, funds are disbursed directly to the program, club, league, or equipment vendor — not to individual families. The recipient receives the athlete's name and the specific funding purpose (e.g., "league registration fee"). No other personal information is included.
Legal Obligations
We may be required by law to share information about a minor if:
- Required by court order or legal process
- Required under Maryland's mandatory reporting law for child abuse or neglect (see Section 14)
- Necessary to protect the immediate health or safety of a child
Service Providers
Our grant application form provider (Formspree) and email service may technically process submitted data as part of form delivery. These providers are bound by their own privacy policies and do not have permission to use A2P data for their own purposes. We do not knowingly allow service providers to retain, use, or disclose children's personal information beyond what is necessary to provide their services to us.
Data Retention for Minor Athletes
We retain information about minor athletes for the minimum period necessary to fulfill the purposes described in this notice and comply with legal obligations.
| Record Type | Retention Period | Legal Basis |
|---|---|---|
| Approved grant applications | 7 years after grant period | IRS requirements for 501(c)(3) organizations |
| Denied grant applications | 3 years | Appeal period and audit trail |
| Athlete photos/videos (with consent) | Until consent is withdrawn, then deleted within 30 days | Parental consent |
| Signed liability waivers | 7 years after minor turns 18 | Statute of limitations for minors |
| Background of reviewing staff | Per staff/volunteer records policy | Organizational safety |
After the applicable retention period, all records containing minor athletes' personal information are securely deleted or fully anonymized. Physical records are shredded; digital records are permanently deleted.
Photos, Video & Media of Minors
We will never post, publish, or distribute photos or videos of minor athletes without prior written parental or guardian consent. This applies to our website, social media accounts, grant reports, donor communications, and all other A2P materials.
How We Obtain Consent
Photo and media consent is obtained through our Participant Waiver & Liability Release form, which includes a specific media consent section. Parents may:
- Grant consent — allowing A2P to use photos/video of their child for organizational purposes
- Decline consent — in which case A2P will not photograph, record, or use images of the child in any publication
Scope of Consent
When consent is granted, photos and videos of minor athletes may be used for:
- A2P website content (no personally identifying captions without additional consent)
- A2P social media accounts (@access2play on Instagram and other platforms)
- Grant reports submitted to foundations or government funders
- Donor communications and fundraising materials
- Print collateral such as brochures and event programs
Photos and videos of minor athletes are never sold, licensed, or shared with third parties for commercial purposes.
Withdrawing Media Consent
Parents or guardians may withdraw media consent at any time by emailing info@access2play.org with the subject line "Media Consent Withdrawal — [Athlete Name]." Upon receipt, we will:
- Stop using new photos or videos of the child within 5 business days
- Remove existing photos from our website and social media within 14 days where technically feasible
- Note that material already printed or distributed (e.g., published reports) cannot be recalled, but will not be republished
Parental Rights
Parents and legal guardians of minor athletes have the following rights with respect to their child's personal information held by Access 2 Play:
Right to Review
You may request a copy of the personal information A2P holds about your child. We will provide this within 30 days of a verified request.
Right to Correct
You may request correction of inaccurate or incomplete information about your child at any time.
Right to Delete
You may request deletion of your child's personal information. We will delete the information unless we are legally required to retain it (e.g., approved grant records for IRS compliance).
Right to Withdraw Consent
You may withdraw consent for photo/media use at any time. See Section 10 for details on the withdrawal process.
Right to Refuse Further Collection
You may direct A2P to stop collecting or using your child's personal information. Note that this may affect your child's eligibility for continued grant support.
Right to Non-Discrimination
Exercising any of these rights will not result in your child being denied services to which they are otherwise entitled, though some requests (e.g., deletion of a pending application) may affect the ability to process a grant.
How to Exercise Parental Rights
Email info@access2play.org with the subject line "COPPA Request — [Child's First Name]." Describe the type of request (access, correction, deletion, withdrawal, etc.).
To protect your child's information, we may ask you to verify your identity and your relationship to the child before processing the request. This may include providing your name and confirming information from the original application.
We will acknowledge your request within 5 business days and fulfill it within 30 days. If we need additional time due to complexity, we will notify you.
We will send you written confirmation when your request has been completed, including details of what action was taken.
If you are not satisfied with our response, you may file a complaint with the Federal Trade Commission at reportfraud.ftc.gov or call 1-877-FTC-HELP. The FTC enforces COPPA and investigates complaints about children's online privacy.
Online Safety for Athletes
Access 2 Play coaches, mentors, and volunteers are prohibited from:
- Contacting minor athletes via personal social media accounts, personal email, or personal phone numbers
- Accepting friend or follow requests from minor athletes on personal social media
- Communicating with minor athletes one-on-one through any channel without a parent or guardian copied
- Posting photos or videos of minor athletes on personal social media accounts
- Requesting that minor athletes keep communications secret from parents or guardians
All A2P communications with minor athletes should go through parents or guardians, or through A2P's official organizational channels.
If a coach, volunteer, or staff member violates these policies, please report it immediately using our Reporting Concerns process or by emailing info@access2play.org.
Mandatory Reporting of Child Abuse
Maryland Law Requirement: Under Maryland Family Law Article § 5-704, certain individuals — including teachers, coaches, and healthcare workers — are mandatory reporters of suspected child abuse or neglect. A2P coaches, staff, and certain volunteers may be mandatory reporters under Maryland law.
If an A2P coach, volunteer, or staff member suspects child abuse or neglect, they are required to:
Emergency situations always take priority. Call 911 first.
Contact the Maryland Department of Social Services Child Protective Services at 1-800-332-6347. Reports may be made anonymously.
Notify the A2P Program Director or Executive Director as soon as possible after making the required report.
Making a mandatory report may require disclosure of the child's identity and circumstances to child protective services authorities. This disclosure is required by law and does not violate A2P's privacy obligations.
A2P will not retaliate against any coach, volunteer, or staff member who makes a good-faith mandatory report.
Contact Us & Filing Complaints
For any questions, concerns, or requests related to children's privacy at Access 2 Play:
Access 2 Play, Inc. — Children's Privacy
EIN: 33-1921117 · Maryland 501(c)(3) Nonprofit
Email: info@access2play.org
Subject line: "COPPA Request — [Child's First Name]"
Response time: Acknowledged within 5 business days; fulfilled within 30 days.
Website: www.access2play.org
External Resources
FTC — COPPA Enforcement
File a COPPA complaint with the Federal Trade Commission.
reportfraud.ftc.govU.S. Center for SafeSport
Report athlete abuse in sport — independent of sports organizations.
safesport.orgMD Attorney General
Consumer protection and nonprofit oversight in Maryland.
marylandattorneygeneral.gov