All of us at Windham Central Supervisory Union (WCSU) are excited about the growing use of software, management platforms and apps that our teachers are using to support student learning. Technology tools and apps are making it possible for educators and students to collaborate, create, and share ideas more easily than ever, especially in our current environment. We believe in technology as a positive and enabling force for student engagement and student outcomes, and we encourage the creative use of technology to support student learning. WCSU also takes seriously the responsibility to both support the effective use of student information and safeguard student privacy and information security.

Windham Central Supervisory Union takes all necessary precautions to protect the privacy of our students. WCSU only contracts with vendors who comply with student privacy and student data laws including the Family Educational Rights and Privacy Act (FERPA), and Children’s Online Privacy and Protection Act (COPPA). We are a member of the Vermont Student Privacy Alliance (VSPA) which has negotiated terms of service with vendors to ensure, among other things, the appropriate protections for privacy of our students’ data. We have also created a list of centrally supported and approved tools that have signed VSPA contracts, established a vetting process for new resources, and provided guidelines for teachers to protect student privacy. Additionally, all WCSU employees and volunteers complete an annual mandatory policies training that includes information about student privacy protections, confidentiality and best practices.

We are providing the following resources to better understand student data privacy and the laws and practices WCSU adheres to in order to protect student data and privacy.

Student Data Privacy Resources for Parents:

• Protecting Student Privacy (US DOE)
• Student Privacy 101: FERPA for Parents and Students
• CommonSenseMedia

Applicable Federal and State Laws that Impact Technology Use and Student Privacy

• Children’s Online Privacy Protection Act (COPPA)
• Children’s Internet Protection Act (CIPA)
• Individuals with Disabilities in Education Act (IDEA)
• Family Educational Rights and Privacy Act (FERPA)
• VT AOE Data Governance

If you have any questions about student data privacy or the above guidelines, please reach out to your student’s building administrator.

We realize that the educational software market is evolving rapidly. We also recognize that teachers want to creatively use additional technology tools in support of student engagement and student outcomes, and we support these efforts. Although there are many great technology tools out there for teachers and students, there are also many tools with limited functionality, monetizing or social media “hooks” or Privacy issues that should not be used with students.

All teachers should be aware of Protecting Student Data Privacy Guidelines for Teachers and no tool should be used with students before being vetted properly for Privacy and the considerations below. Be aware that showing your own use of a tool may constitute an “endorsement” and could encourage older students to explore themselves even if you are not specifically recommending it. Please contact your building administrator if you have a new tool you are interested in using. All software and apps must be approved by the building administrator before use with students.

Consider the following when investigating new digital tools:

• What is the content goal or task that you want students to accomplish? How will this tool help you accomplish your learning goals for students? Often it is the context and goals of an assignment that make it successful rather than the specific tool.
• What specific features does the new tool offer that are not available in other tools? Our Integration Specialists may be able to help identify similar tools and/or tools students have used previously.
• Data Privacy: is this a tool already in use in our WCSU or State? We should not be using any tool with students without a Student Data Privacy Contract in place. Any good tool will list their Privacy Policies and these should always be reviewed carefully. Information Technology (IT) is handling all contracts for the WCSU.
• Login process: Students should be logging in with Google only unless a tool has unique features unavailable elsewhere. Any tool that requires “setting up an account” is likely to ask students for personal information and should be avoided. If students ever need to set a password for a tool (not recommended) it should never be the same as their email password!
• Advertising and links to Social Media: This is a tricky one, but generally a tool with a lot of Ads and social media "hooks" is designed to gather and cross-reference user data, which is exactly what we are trying to avoid. A good tool designed for students does not include advertising or ties to social media.
• Export capability: Direct connection to Google Drive is ideal. Many free tools have limited export capability (watermarks, low-res export, share to social media only) or require upgrade in order to export content. Before you spend a lot of time creating content, make sure you know how to get your content out of the tool when you are finished!
• Limitations of free accounts: Many free accounts have limited features and encourage you to “Upgrade to Premium.” Some tools automatically set you up with full-featured accounts that expire after a short trial period and become limited. It is important to know the limitations of a free account and the cost of future upgrades.
• Interface, functionality, ease of use, learning curve: A lot of tools are at first appealing because "they're quick and easy to learn," however it is not accidental that this lands last on the list, as many “quick and easy” tools have critical issues in one or more categories above.

• Only use tools that have been approved by the SU or School. For the safety and privacy of all students, do not use any tools independently that have not been approved.
• Do not share your or students’ Personally Identifiable Information (PII) in online settings.
• Provide explicit instruction to students about what is and is not appropriate to share in public, online settings. Remind students that everything they do and say in a remote setting can be viewed by their teacher and classmates.
• Teach students appropriate safety protocols to ensure their own safety online and protect their personal information (i.e. privacy and security settings, passwords, using trusted sites).
• Gain student permission before you take a screenshot or capture images. Provide students the option to be off camera for the screen shot. Do not post images of class sessions (showing student faces or names) on social media.
• Be sure that your display does not include personal student information before you share your screen.
• Be transparent at the beginning of each lesson and let students know if you will be recording and why you are doing it.
• When recording, consider deleting portions of the lesson that feature students sharing social or personal information. When possible, delete student names or other personally identifiable information.
• Report any issues of harassment, hazing or bullying to your building administrator or designated employee.

For more resources and information on how to protect student privacy:

Wide Open School by Common Sense Media
Vermont Agency of Education Student Data Privacy & Safety Guidelines for Teachers
The Family Educational Rights and Privacy Act (FERPA)
The Children’s Online Privacy Protection Act (COPPA)
The Children’s Internet Protection Act (CIPA)

Why are we doing this?

To set standards of both practice and expectations around student privacy such that all parties involved have a common understanding of expectations. It is about compliance with the law and the ethical standpoint of being good stewards of student privacy.

What are we trying to protect?

​​​​​​Our students’ personally identifiable information (PII).

Do the services collect PII? Who do they share it with? Can they guarantee that any third-party services that they use follow the same guidelines?

Many services will take student data and trade it, sell it, or create advertising profiles. Not only do we not want that, but we are also legally obligated to prevent that.

What are COPPA, FERPA, CIPA and PPRA?

The primary goal of COPPA (Children’s Online Privacy Protection Act) is to place parents in control over what information is collected from their young children online. COPPA was designed to protect children under age 13 while accounting for the dynamic nature of the Internet. The Rule applies to operators of commercial websites and online services (including mobile apps) directed to children under 13 that collect, use, or disclose personal information from children, and operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13. The Rule also applies to websites or online services that have actual knowledge that they are collecting personal information directly from users of another website or online service directed to children.

FERPA (Family Educational Rights and Privacy Act) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds from the U.S. Department of Education. FERPA gives parents certain rights with respect to their children’s education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level.

CIPA (Children’s Internet Protection Act) was enacted by Congress in 2000 to address concerns about children’s access to obscene or harmful content over the Internet.

PPRA (Protection of Pupil Rights Amendment) is intended to protect the rights of parents and students in two ways:

• It seeks to ensure that schools and contractors make instructional materials available for inspection by parents if those materials will be used in connection with an ED-funded survey, analysis, or evaluation in which their children participate; and
• It seeks to ensure that schools and contractors obtain written parental consent before minor students are required to participate in any ED-funded survey, analysis, or evaluation that reveals certain information.

Helpful Links

For more information on privacy laws:
Office of Educational Technology: Privacy

To see how Vemont and WCSU are working with vendors to protect data privacy:
Vermont Student Privacy Alliance

Resources for parents and teachers:
Common Sense Media

Why?

Student and faculty safety and privacy is a top priority at Lamoille South Unified Union. We have established procedures based on best practices for approving and managing apps, web-based resources, and platforms that we use in our schools.

What you should do before requesting review of an app or website?

• See if an app is already in use that does what you need.
• We will update the elementary and middle/high school resources to support learning out of school documents.
• Check the student and teacher dashboard pages on the website to see what is already in use.

When do you need to ask for a review?

• In general, if there is no login required and little to no personally identifiable information with the site or app then no review is needed. You should still read the Terms of Use and Privacy Policy before using the site.
• If only a teacher login is required
  • And students will NOT be using the site - no review is needed, for example, a teacher resource or curriculum library site
  • And students will be using the site (even without a login) - ask for a review
• If a student login is required - ask for a review

How to ask for review

Send an email to tech support ([email protected])

Please include:

• The name of the app
• Link to the website
• Who will be using it (Teacher only? Teachers and Students?)
• Does it require accounts
• Is this a purchased app or free
• Who the administrators of the app will be, if not the data manager
• Any known special education needs

How we prioritize requests

• Requests that have come from multiple teachers will be given priority. For example a request from a team or department.
• Platforms and apps that have been approved by other Vermont school districts for the Student Data Privacy Resource Registry may have an accelerated approval process.
• Platforms and apps that require funding will need to also go through the financial procurement process in addition to the technology department approval.

Who makes accounts

• IT will make all student accounts.
• Teachers can make their own account if they are the only one interacting with the platform.
• It is best practice to always have more than one admin account so please include one other person as an administrator (data manager is the best option) or share your administrator credentials with one other person.

How will I know if my request has been approved?

• We will make updates to the tech ticket.
• We will email the teacher(s) who made the request.
• We will update the list of available apps.
• We will update the elementary and middle/high school resources to support learning out of school documents.
• For iPads, the app will be pushed to the appropriate classes or grades.
• The app will be added to Clever.

What if I have been using an app for a while that did not go through the approval process?

This happens sometimes. Please reach out to tech support and we can work with you to find a solution to support teachers, students, and learning.