Broome-Tioga BOCES/South Central RIC is considered the “vendor” for ClearTrack200 and RTI Edge software. While BOCES/RICs are not subject to the “third party contractor” requirements of Education Law 2-d or Part 121 of the Commissioner’s Regulations because they are local educational agencies, we, like all BOCES/RICs, are still subject to all of the other provisions of Education Law 2-d or Part 121 of the Commissioner’s Regulations and we take data privacy and security seriously.