Please provide your comments to the FTC on student privacy – deadline Monday 11/21/22

Right now, the Federal Trade Commission is collecting comments from the public about how their oversight of the use of personal data by commercial enterprises can be improved. As you know, many parents are rightly concerned that too many vendors that collect personal student data at the behest of schools and districts have recklessly allowed that data to breach, and/or have used it for advertising, sale, or other commercial purposes. The comment period to the FTC has been extended through this Monday, Nov. 21, 2022, and we encourage all parents to submit comments by the end of that day.

Since the pandemic, the risky use of digital programs and apps in schools has soared. Most of these programs are operated and owned by for-profit companies who have been collecting personal student data without parental consent, sufficient oversight, restrictions, and/or security protections. As a result, the number of student data breaches has exploded.

This is in part because the existing data security provisions in federal law are weak or non-existent. The Children’s Online Privacy Protection Act, or COPPA, only requires “reasonable” security without the FTC having defined that term, while FERPA does not specify any security standards at all. And too many vendors are using personal data to target ads to students or their families, and/or to build new programs and services around, which are clearly commercial and not educational purposes.

We encourage you to submit your comments here; no later than this Monday at 11:59 pm. Let the FTC know that they should use all their authority to ensure that student data is safe and secure and used ONLY for educational purposes. A sample email is below, but please edit it any way you like. MOST important is for you to add any examples of when your children’s data was breached or improperly used. Please also share any such experiences with us, to aid us in our work going forward, by emailing us at info@studentprivacymatters.org

A sample email message is below. Thanks!

______

To the FTC:

I am a parent and am very concerned about how the number of student data breaches has skyrocketed in recent years, through hacking, ransomware, and other cybersecurity events. Moreover, too often school vendors are also using and abusing student data for commercial uses. I urge you to require enforceable contracts that require encryption, as well as other strong security standards for the collection, disclosure, and use of student data. Also, these contracts must prohibit vendors from accessing or using any data they do not need for the purposes of carrying out their contracted services, and the information they do collect should be deleted as soon as possible, preferably at the conclusion of each school year or at the very least, when students graduate or leave the district.

I also urge you to strongly prohibit the use of student data for any commercial purpose, including allowing vendors to sell it, to use it to target ads, and/or to use it to develop new products or services.

Yours sincerely [ add your name here].

And have a great Thanksgiving!

Leonie Haimson & Cassie Creswell, co-chairs
Parent Coalition for Student Privacy
124 Waverly Pl.
New York, NY 10011
info@studentprivacymatters.org
Follow @parents4privacy
Subscribe to Parent Coalition for Student Privacy newsletter at https://www.studentprivacymatters.org/join-us

Presentation at 1st Int. Congress on Democratic Digital Education and Open Edtech.

I just gave a brief presentation at the 1st International Congress on Democratic Digital Education and Open Edtech in Barcelona (remotely), on how the Parent Coalition began and how our fight continues.

We also engaged in a brief discussion about how the pandemic has undermined student learning & privacy thru the expanded use of online products – but push to privatize schooling via ed tech started before pandemic & sadly will continue long after its over.

My presentation is below.

New and emerging threats to student & teacher data privacy

On May 6, the NY Post revealed that about two million students in NY State alone may have had their privacy violated by the massive Illuminate data breach; students in CT and CO were also affected.

This is an update from reporting in  The Journal, based on FOILed records from NYSED that found at least one million students affected, across  24 school districts and 18 charter schools in New York, plus one Board of Cooperative Educational Service .

The NY State Education Dept. and the NYC DOE need to do a far better job protected personal student data and complying with the NY State Student privacy law 2D, which was passed in 2014, and to minimize the sharing of student data, ensuring strict security standards including encryption, and requiring that vendors delete it as soon as possible and at the very least when students graduate, none of which happened here.

Illuminate has reported that the hackers accessed a ” database storing some information in unencrypted format “, according to  the The Record news site, and that the data may have included student and parent names, email addresses, grades, attendance, birth dates, ID numbers, genders, race and ethnicity, languages spoken at home, Title I and disability status and more.  Data from the records of students in Colorado and Connecticut may also have breached.

Last weekend, Leonie Haimson, co-chair of the Parent Coalition for Student Privacy and Doug Levin, Co-Founder and National Director, K12 Security Information Exchange and a national expert on student data breaches,  gave  presentations at the Network for Public Education national conference in Philadelphia, in which we discussed the Illuminate Breach and the how districts and schools can better protect the privacy of their students and teachers.

Below are the videos of the this session, separated into Part I and Part II, along with questions and comments from the audience, and their power point presentations.

 

Send a letter to Congress: Support strong privacy legislation that protects children and students

Parents and students, if you are concerned about how the apps and technology you’re using in school and at home are collecting and sharing children’s data, please let your members of Congress know by sending this message.

In his March 2022 State of the Union address, President Biden specifically said we must do more to protect children from surveillance and harm of Big Tech.

“These companies know everything from where users are physically located at any moment, to how many seconds they spend reading a particular post, to intimate personal data like what medical symptoms they have been researching. Children are also subject to the platforms’ intensive and excessive data collection vacuum, which they use to deliver sensational and harmful content and troves of paid advertising to our kids. By one estimate, online advertising firms hold 72 million data points on the average child by the time they reach the age of 13. The President is calling on Congress to ban excessive data collection on and targeted advertising online for children and young people.”

We know that tech and screens are addictive, with children often caught in a loop, scrolling through sometimes harmful content. Facebook whistleblower, Frances Haugen, says teens fall into a trap of algorithms, especially on social media. In an interview with 60 Minutes, Ms. Haugen revealed that “Facebook internal studies … show 13.5% of teen girls say Instagram makes thoughts of suicide worse; 17% of teen girls say Instagram makes eating disorders worse.”

We also know that edtech programs collect massive amounts of sensitive demographic data on children, including their email, home, income, grades, disabilities, citizenship status, discipline and criminal history, religious preference, behavior and more. In many cases, we have no idea how they use and share this data with other companies.

Yet a recent study found that 60% of school apps are improperly sharing student data with third parties. The Markup, in its investigations into Naviance and PowerSchool, found that when parents and schools asked to see their students’ data, these companies refused to share that information.

The Markup also found that Naviance allowed their customers to target students and their families with ads, based on their income and race. PowerSchool, which owns Naviance, can collect as many as 7,000 data fields per student, and uses algorithms to predict a student’s risk of not graduating high school on time starting in first grade.

Please click here to send a message to your members of Congress, asking them to support strong privacy legislation that will protect all minors and students. We need to reign in Big Tech from surveilling and monetizing kids.   Thanks!