From the K–12 edition of October 12, 2026
PGCPS Artificial Intelligence Declaration Agreement (AIDA): mandatory vendor AI disclosure, no-retain student PII, disable rights, and audit/remediation
Prince George’s County Public Schools · Large U.S. K–12 school district (procurement) · Prince George’s County, Maryland, United States
- Publisher
- PGCPS Purchasing and Supply Services – Appendix P AIDA
- Original publication
- Undated (active Appendix P procurement form)
- Source retrieved
- 2026-10-13
What happened
Prince George’s County Public Schools Purchasing Appendix P requires every digital-tool vendor to complete an Artificial Intelligence Declaration Agreement (AIDA). If AI is present, vendors must disclose models/training-data sources/local-vs-cloud storage/improvement methods; primary user audience; FERPA/COPPA/state-privacy confidentiality verification; Student Data points used for personalization; verification that generative models will not retain/store Student Data or PII entered during use and that outputs are not linked to individuals; ban on secondary use without PGCPS and parental approval (termination risk); bias/privacy/harm monitoring with results shareable on request; enable/disable directions; explainability for advancement-impacting recommendations; and third-party processor disclosure including geography. Vendors must notify within 60 days of new AI-containing versions; PGCPS may enable/disable AI features, terminate for unilateral T&C/privacy changes, audit AI systems/data practices, and require remediation within 60 days at vendor cost. AIDA supersedes vendor AI policies. Why now: newly relevant alongside Vermont reporting of uneven privacy-agreement practice—shows a concrete district-level AI declaration control not previously archived.
Why it matters
High for K–12 procurement: a reusable contract addendum that forces AI feature disclosure and student-data retention limits before tools ship.
Evidence and measured results
Official district purchasing PDF (Appendix P); contractual requirements without published compliance statistics.
Limitations and uncertainty
Undated PDF; no published rates of vendor completion or audit findings; filename misspells ‘declaration’.
Put this evidence to work
Lighthouse Advisory interpretation, grounded in this source. Enriched 2026-10-13; this does not change the original publication date. Each role follows the same checklist so takeaways compare across sources.
Sales
Role takeaway
- Customer problem
- Districts need enforceable vendor commitments when digital tools quietly add generative AI that may retain student prompts or change privacy terms.
- Stakeholders
- Purchasing/supply services
- CIO/CITO
- Data privacy officer
- Curriculum/tech evaluation teams
- Vendors of digital tools
- Discovery questions
- Does the product contain AI features for any user group?
- Can generative features be disabled by the district?
- Will prompts/PII be retained or used to improve models?
- Which subprocessors and geographies process student data?
- Value hypothesis
- Interpretation: helping a district operationalize an AIDA-like addendum can reduce undisclosed AI risk; it cannot guarantee vendor truthfulness without audit.
- Potential engagement
- Bounded procurement-control design: adapt AIDA checklist into the district’s digital-tool approval packet and vendor onboarding.
- Unsupported claims
- That PGCPS measured learning gains from AI
- Guaranteed vendor compliance without audits
- That all Maryland districts use AIDA
- FERPA compliance by declaration alone
Pre-sales engineering
Role takeaway
- Fit
- Fits districts standardizing AI disclosures across all digital tools, including products that later bolt on generative features.
- Architecture and integration
- Require feature flags for generative components; document data flows local/cloud; list subprocessors and storage regions.
- Prerequisites
- Digital-tool inventory (Appendix L equivalent)
- Legal review of addendum
- Process to receive 60-day AI-version notices at a monitored mailbox
- Constraints
- Undated form; local Maryland legal context
- Vendors may resist no-retain or audit clauses
- Non-disableable AI triggers reassessment
- Security
- No-retain Student Data/PII in generative models; FERPA/COPPA assertions; bias/privacy/harm monitoring with shareable results; audit rights with 60-day remediation.
- Proof of value
- Sample completed AIDA packets for three vendors
- Verify disable paths in a staging tenant
- Confirm notice mailbox receives version-change alerts
Delivery
Role takeaway
- Work
- Insert AIDA into vendor onboarding; collect disclosures; wire enable/disable decisions to approval status; exercise audit clause when risk warrants.
- Dependencies
- Purchasing workflow
- Legal counsel
- IT security review
- Vendor cooperation
- Ownership
- PGCPS Purchasing and Supply Services with CITO notification channel (cito@pgcps.org for version notices).
- Skills and adoption
- Procurement and IT staff need AI-feature literacy to evaluate 1a–j responses.
- Governance checkpoints
- No AI tool approval without completed AIDA
- 60-day notice review for new AI versions
- Termination path for unilateral privacy/T&C changes
- Acceptance criteria
- Proposed: 100% of new digital-tool contracts include AIDA
- Proposed: generative features have documented disable steps
- Proposed: audit findings remediated within 60 days when invoked
- Risks
- Paper compliance without technical verification
- Vendors adding non-disableable AI
- Resource limits on exercising audit rights
Implementation considerations
Lighthouse Advisory interpretation across the operating dimensions a public-sector buyer must settle before this evidence becomes a design. Each note answers the question under its heading for this specific source.
Architecture and integration
What must connect, and where does the AI sit in the workflow?
Requires vendors to document local vs cloud storage, model improvement methods, and feature enable/disable; supports district kill-switches when AI cannot be disabled.
Governance
Who approves, reviews and stays accountable for outcomes?
AIDA is part of the Agreement and supersedes vendor AI policies; breach can terminate the Agreement; external audit rights reserved.
Security and privacy
What data, permissions and controls need testing?
Explicit no-retain/store Student Data or PII in generative models; FERPA/COPPA/state-law confidentiality assertions; subprocessor geography disclosure; secondary-use ban without PGCPS and parental approval.
Accessibility and workforce
Who is affected, and what skills or accommodations follow?
Explainability demanded for recommendations affecting student advancement; audience (teachers/students/all) must be declared.
Procurement
What should contracts, pricing and exit terms secure?
Required for all digital tools identified in Appendix L; 60-day notice for new AI versions; unilateral privacy/T&C changes can trigger termination.
Operating model
Which teams own the service once it runs?
Shifts AI governance into purchasing—vendors must declare AI before or during approval, and district retains runtime enable/disable control.
Publication history
- 2026-10-12K–12 · Issue 363 resources
Stable resource ID: pgcps-ai-declaration-addendum-aida