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Protecting your children's privacy: The Facts
Scroll down OR use the topic links at the right for more information about protecting your children's privacy.
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Sheila Kaplan
3 Pierrepont Pl.
Brooklyn, NY 11201
347-486-0361
www.educationnewyork.com
sheila@educationnewyork.com
twitter.com/educationny
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National Opt-Out Campaign Informs Parents How to Protect the Privacy of their Children's School Records
Parents have rights under the Family Educational Rights Privacy Act to restrict access to their children's personal information.
New York, N.Y. -- As cases of identity theft, database hacking, and the sale of personal information increase daily, the need to protect children's privacy becomes even more urgent. Schools are a rich source of personal information about children that can be legally and illegally accessed by third parties. That's why Education New York's National Opt-out Campaign is alerting parents to their rights under the federal Family Educational Rights Privacy Act (FERPA) to restrict third-party access to their children's information and encouraging them to review their school's annual FERPA notification at the beginning of the school year.
Parents concerned about their children's privacy should be aware of how easily personally identifiable information can be bought and sold by marketers as well as by identity thieves. The Federal Trade Commission recently issued a Consumer Alert to parents warning of the risk of children's identity theft and urging parents to safeguard their children's school records and directory information. http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt056.shtm
FERPA was enacted in 1974 to protect the privacy of education records and directory information -- which can include name, address, phone number, date of birth, and e-mail address, among other personally identifiable information. However, under FERPA, directory information can be disclosed without parental consent.
Parents should be aware that FERPA protects the privacy of the record and not the child. Kathleen Styles, the Chief Privacy Officer at the U.S. Department of Education, which oversees FERPA, said: "One thing that's important to remember about FERPA is that it's not a confidentiality statute for information about children -- it's a confidentiality statute for information in education records." http://www.educationnewyork.com/files/071211_sess3.pdf
As the new school year gets under way across the country, parents have an opportunity to become proactive by finding out who has access to their children's personal information and "opt out" of allowing the school to share any or all of that information with third parties.
With the Opt Out Campaign, Education New York is informing parents of their rights under FERPA as well as the gaps in the law that have resulted in numerous information privacy breaches around the country and a robust market in children's personal information.
Parents and others interested in children's privacy are encouraged to visit http://www.educationnewyork.com/optout to learn more about:
- The growing problem of child identity theft.
- Current law and legislation protecting children's privacy.
- Who's illegally accessing your children's personal information.
- How opt-out forms can be adapted to give parents more options to protect information.
- What some states are doing to further restrict access to student information.
Education New York is an independent source of education news from around the nation. Education New York was founded in 1995 by Sheila Kaplan, an education and information policy expert and researcher. For more information, visit http://www.educationnewyork.com or e-mail Sheila@EducationNewYork.com. Follow Education New York on Twitter: http://www.twitter.com/educationNY
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Scroll down OR use the topic links at the right for more information about protecting your children's privacy.
compiled by education new york online
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Updated Tuesday February 14, 2012 12:08 AM
BMI: Body Mass Index | Child identity theftA Better Start: Clearing Up Credit Records for California Foster Children | Date Captured | Tuesday September 13, 2011 01:16 PM | | This report
summarizes the result of the project team’s work on behalf of over 2,110 foster children
in Los Angeles County, and it also recommends new procedures for use in helping this
vulnerable population statewide.
Key Findings of the Pilot Project
• The project team successfully cleared all negative items from the credit reports of
104 foster children.
• These 104 children (5% of the pilot project sample) had 247 separate accounts
reported in their names, as the result of errors or identity theft.
• The average account balance was $1,811, with the largest being a home loan of
over $200,000.
• The accounts found were two to three years old, opened when the child was 14
years old on average.
• 12% of the children had records loosely linked to them by Social Security number
only, which while not affecting their credit ratings could nevertheless pose
problems for them in the future. |
| FTC "STOLEN FUTURES" WEBCAST Session Two - FAMILIAL IDENTITY THEFT - July 12, 2011| Date Captured | Sunday September 11, 2011 12:04 AM | | VERY INTERESTING WEBCAST ON CHILD IDENTITY THEFT. DISCUSSES MOST AT RISK STUDENTS. Session 2 Linda Foley is the founder and research director of the Identity Theft Resource Center, a nationwide nonprofit, victim-services advocacy, and consumer-education program based in San Diego, California. Russell Butler is Executive Director of the Maryland Crime Victims Resource Center, which provides criminal justice information and education, support services, therapeutic individual, family, and group counseling, and legal information, referrals, and representation to victims of crime. Theresa Ronnebaum is the Identity Theft Program Specialist for the Florida Attorney General's office with over 15 years experience in victim advocacy. |
| PREPARED STATEMENT OF THE FEDERAL TRADE COMMISSION on CHILD IDENTITY THEFT| Date Captured | Friday September 02, 2011 09:38 PM | | PREPARED STATEMENT OF THE FEDERAL TRADE COMMISSION
Before the
SUBCOMMITTEE ON SOCIAL SECURITY
of the
HOUSE COMMITTEE ON WAYS AND MEANS
on
Child Identity Theft
Field Hearing
Plano, Texas
September 1, 2011; EXCERPT: A. The Child Identity Theft Forum Discussions [They noted that identity
thieves often steal children’s information from schools, businesses, and government agencies.]
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| Kindergarten Through 12 Grade Schools’ Collection and Use of Social Security Numbers (A-08-10-11057) | Date Captured | Thursday December 23, 2010 09:53 AM | | OFFICE OF THE INSPECTOR GENERAL SOCIAL SECURITY ADMINISTRATION - Despite the potential risks associated with using SSNs as primary student identifiers,
many K-12 schools continue this practice. While we recognize that SSA cannot prohibit
States or K-12 schools from collecting and using SSNs as student identifiers or for other
purposes, we believe SSA can help reduce the threat of identity theft and SSN misuse
by encouraging States and K-12 schools to reduce unnecessary collection of SSNs and
improve protections and safeguards when collected.
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| Cómo proteger la información personal de su hijo en la escuelaFTC Alerta para Consumidores: Cómo proteger la información personal de su hijo en la escuela | Date Captured | Sunday September 11, 2011 07:37 PM | | Pregunte en la escuela de su hijo cuál es la política aplicable al directorio de información de los estudiantes. En el directorio de
información de los estudiantes se pueden listar el nombre, domicilio, fecha de nacimiento, número de teléfono, domicilio de email y foto de
su hijo. La ley FERPA establece que las escuelas deben notificar a los padres y tutores sus respectivas políticas aplicables al directorio de
información de los estudiantes, y darle el derecho de optar por que no se suministre esa información a terceros. Es mejor que presente su
solicitud por escrito y que guarde una copia para sus archivos. Si usted no ejerce su derecho de optar por que no se comparta la
información de su hijo, los datos listados en el directorio de la escuela pueden estar a disposición no sólo de los compañeros de clase y
personal de la escuela de su hijo, sino también del público en general. |
| Current law & proposed legislationAPPENDIX A: FERPA Guidance for Reasonable Methods and Written Agreements| Date Captured | Thursday January 05, 2012 05:57 PM | | FERPA represents the floor for protecting [student] privacy, not the ceiling. PAGE A-5 Federal Register/Vol. 76, No. 232/Friday, December 2, 2011/Rules and Regulations. |
| DEPARTMENT OF EDUCATION 34 CFR Part 99 in the Federal Register (76 FR 19726)| Date Captured | Monday December 05, 2011 11:20 AM | | SUMMARY: The Secretary of Education
(Secretary) amends the regulations
implementing section 444 of the General
Education Provisions Act (GEPA),
which is commonly referred to as the
Family Educational Rights and Privacy
Act (FERPA). These amendments are
needed to ensure that the U.S.
Department of Education (Department
or we) continues to implement FERPA
in a way that protects the privacy of
education records while allowing for the
effective use of data. Improved access to
data will facilitate States’ ability to
evaluate education programs, to ensure
limited resources are invested
effectively, to build upon what works
and discard what does not, to increase
accountability and transparency, and to
contribute to a culture of innovation and
continuous improvement in education.
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| NYS Assembly Bill A8474 same as Senate Bill 2357b| Date Captured | Monday September 05, 2011 10:16 AM | | BILL NO A08474
Same as S 2357-B (Sponsor: Sen. Suzi Oppenheimer - passed Senate 62-0)
ASSEMBLY SPONSOR Rosenthal (MS)
COSPONSOR Nolan: A SCHOOL MAY NOT, EVEN WITH THE AFFIRMATIVE CONSENT OF THE PARENT OF THE STUDENT IN ATTENDANCE OR THE
ELIGIBLE STUDENT IN ATTENDANCE, DISCLOSE PERSONALLY IDENTIFIABLE STUDENT INFORMATION FOR A COMMERCIAL, FOR-PROFIT ACTIVITY INCLUDING BUT NOT LIMITED TO USE FOR: (I) MARKETING PRODUCTS OR SERVICES;
(II) SELLING PERSONALLY IDENTIFIABLE STUDENT INFORMATION FOR USE IN MARKETING PRODUCTS OR SERVICES; (III) CREATING OR CORRECTING AN INDIVIDUAL OR HOUSEHOLD PROFILE; (IV) COMPILATION OF A STUDENT LIST.
DISCLOSABLE DIRECTORY INFORMATION (DDI) HEREAFTER REFERRED TO IN THIS SECTION AS "DIRECTORY INFORMATION", MEANS WITH RESPECT TO A STUDENT, THE STUDENT'S NAME; PHOTOGRAPH; AGE; MAJOR FIELD OF STUDY; GRADE LEVEL; ENROLLMENT STATUS (E.G., UNDERGRADUATE OR GRADUATE, FULL-TIME OR PART-TIME); DATES OF ATTENDANCE; PARTICIPATION IN OFFICIALLY RECOGNIZED ACTIVITIES AND SPORTS; WEIGHT AND HEIGHT OF MEMBERS OF ATHLETIC TEAMS; DEGREES, HONORS AND AWARDS RECEIVED; AND THE MOST RECENT EDUCATIONAL AGENCY OR INSTITUTION ATTENDED. (D) "PERSONALLY IDENTIFIABLE STUDENT INFORMATION (PISI)" SHALL INCLUDE DISCLOSABLE DIRECTORY INFORMATION, AND A STUDENT'S OR PARENT'S ADDRESS, TELEPHONE NUMBER, AND E-MAIL ADDRESS.
A SCHOOL MAY DISCLOSE PERSONALLY IDENTIFIABLE STUDENT INFORMATION ONLY WITH THE AFFIRMATIVE CONSENT OF THE PARENT OF THE STUDENT IN
ATTENDANCE OR THE ELIGIBLE STUDENT IN ATTENDANCE IN ACCORDANCE WITH THE PROCEDURE PROVIDED IN SUBDIVISION THREE OF THIS SECTION IF:
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| California AB.143 | Date Captured | Saturday September 03, 2011 02:40 PM | | INTRODUCED BY Assembly Member Fuentes; This bill would redefine directory information to no longer
include a pupil's place of birth and to also include a pupil's e-mail
address. |
| TITLE 20 > CHAPTER 31 > SUBCHAPTER III > Part 4 > § 1232g| Date Captured | Tuesday March 15, 2011 12:47 PM | | FERPA statute regarding directory information - note PICTURE and E-MAIL NOT in statute. US ED added through regulations -- they were not added by Congress: 5)(A) For the purposes of this section the term “directory information” relating to a student includes the following: the student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student. |
| OHIO 3319.321 Confidentiality| Date Captured | Thursday March 10, 2011 02:40 PM | | Ohio Revised Code » Title [33] XXXIII EDUCATION (A) No person shall release, or permit access to, the directory information concerning any students
attending a public school to any person or group for use in a profit-making plan or activity.
Notwithstanding division (B)(4) of section 149.43 of the Revised Code, a person may require disclosure
of the requestor’s identity or the intended use of the directory information concerning any students
attending a public school to ascertain whether the directory information is for use in a profit-making plan
or activity.
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| Plano ISD: Redefining the student directory | Date Captured | Friday October 30, 2009 10:30 AM | | [If the changes are approved, Plano ISD couldn't, without consent from the parents, print a student's address, telephone number or e-mail address in any district publication.
Some school districts -- and I'm not sure about Plano -- sell directory information to third parties as a money-making operation. Companies, such as Coca-Cola or Citi Bank, could buy the directories and market products to students.]
NOTE: CHANGES WERE APPROVED
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| FTC alert informs parents how to protect privacy of children FTC CONSUMER ALERT: Protecting Your Child's Personal Information at School| Date Captured | Friday September 02, 2011 06:10 PM | | [Ask your child's school about its directory information policy. Student directory information can include your child's name, address, date of birth, telephone number, email address, and photo. FERPA requires schools to notify parents and guardians about their school directory policy, and give you the right to opt-out of the release of directory information to third parties. It's best to put your request in writing and keep a copy for your files. If you don't opt-out, directory information may be available not only to the people in your child's class and school, but also to the general public.]
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| Illegal access to student informationPrivacy Rights Clearinghouse chronology of education breaches| Date Captured | Monday September 05, 2011 11:07 AM | | Beth Givens -- Privacy Rights Clearinghouse Education breach chronology from 2005 - 2011. |
| Office of Inadequate Security| Date Captured | Monday September 05, 2011 10:40 AM | | Education breaches |
| Opt out | New York State Sample Parental Notice Language for 2011-2012 School Year | Date Captured | Tuesday January 24, 2012 01:44 PM | | If you do not wish to have your child’s weight status group information included as part of the Health Department’s survey this year, please print and sign your name below and return this form: |
| Opt out: What you need to knowNOTICE OF DIRECTORY INFORMATION OPT-OUT| Date Captured | Tuesday September 20, 2011 05:14 PM | | This is a draft OPT-OUT form. Please comment by tweeting @EducationNY or Email to Sheila@EducationNewYork.com |
| US Education Department Model Notice for Directory Information| Date Captured | Monday September 05, 2011 12:21 PM | | The Family Educational Rights and Privacy Act (FERPA), a Federal law, requires that [School District], with certain exceptions, obtain your written consent prior to the disclosure of personally identifiable information from your child's education records. However, [School District] may disclose appropriately designated "directory information" without written consent, unless you have advised the District to the contrary in accordance with District procedures. Directory information may include: Student's name;
Address;
Telephone listing;
Electronic mail address;
Photograph;
Date and place of birth;
Major field of study;
Dates of attendance;
Grade level;
Participation in officially recognized activities and sports;
Weight and height of members of athletic teams;
Degrees, honors, and awards received;
The most recent educational agency or institution attended;
Student ID number, user ID, or other unique personal identifier used to communicate in electronic systems that cannot be used to access education records without a PIN, password, etc. (A student's SSN, in whole or in part, cannot be used for this purpose.) |
| Example of customized opt-out form | Date Captured | Sunday September 04, 2011 07:45 PM | | COLLEGE OF CHARLESTON
FERPA DIRECTORY INFORMATION OPT-OUT FORM - note parents or college students have choices as to which information they want to share. |
| FTC CONSUMER ALERT: Student Surveys: Ask Yourself Some Questions | Date Captured | Friday September 02, 2011 06:35 PM | | [The Protection of Pupil Rights Amendment (PPRA) is a federal law that affords certain rights to parents of
minor students with regard to surveys that ask questions of a personal nature, as well as to surveys designed to
collect personal information from students for marketing purposes. Briefly, with regard to marketing surveys,
PPRA generally requires schools to develop policies, notify parents about these surveys and permit them to opt
their children out of participation in those surveys. Surveys that are exclusively used for certain educational
purposes are excepted from these requirements.] [FTC recommends that you check to
see if the survey form includes a privacy statement. If there is no privacy statement, you may want to think
twice about distributing the survey. In any case, it is wise to know:
• who is collecting the information;
• how the information will be used;
• with whom the information will be shared; and
• whether students will have a choice about the use of their information.]
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| FTC CONSUMER ALERT: Protecting Your Child's Personal Information at School| Date Captured | Friday September 02, 2011 06:10 PM | | [Ask your child's school about its directory information policy. Student directory information can include your child's name, address, date of birth, telephone number, email address, and photo. FERPA requires schools to notify parents and guardians about their school directory policy, and give you the right to opt-out of the release of directory information to third parties. It's best to put your request in writing and keep a copy for your files. If you don't opt-out, directory information may be available not only to the people in your child's class and school, but also to the general public.]
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| Race to the Top (RttT)New York State Race to the Top Subgrants to Participating LEAs NOV 2010| Date Captured | Tuesday February 14, 2012 12:08 AM | | Race to the Top Subgrants to Participating LEA's (50% of Total) Based on Receipt of Letters of Intent total $348,323,000 in 2010. |
| NEW YORK: RACE TO THE TOP ANNUAL PERFORMANCE REPORT | Date Captured | Friday January 20, 2012 02:57 PM | | New York faces the ongoing challenge of communicating and collaborating with its various stakeholders. Similarly, the complexity of reviewing and approving Scopes of Work, budgets, expenditures, and evaluation plans
for all of the State’s participating LEAs presented a formidable
task that required a high level of strategic planning and logistical coordination by NYSED leadership. The State is working to overcome these challenges by investing in communication tools and leveraging other quality-control methods (such as a new online expenditure reporting tool) in order to increase its responsiveness and efficiency in the future. |
| State databasesFordham CLIP Comments on FERPA NPRM May 23, 2011 Docket: ED-2011-OM-0002 1 | Date Captured | Wednesday June 22, 2011 10:24 PM | | Fordham Professor of Law Joel Reidenberg: Proposed Amendments to the FERPA Regulations contradict Congressional Mandates; Impermissible expansion of “Authorized representative” proposed in §99.3; Problematic expansion of “directory information” proposed in §99.3; Impermissible expansion of the “audit and evaluation” provision proposed in § 99.35(a)(2); Questionable Enforcement proposed in §99.35 ;
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| Education New York comments re Student Privacy submitted to FERPA NPRM - May 23, 2011| Date Captured | Monday May 23, 2011 09:22 PM | | Document ID: ED-2011-OM-0002-0001: Family Educational Rights and Privacy. The proposed changes to FERPA do not adequately address the capacity of marketers
and other commercial enterprises to capture, use, and re-sell student information. Even
with privacy controls in place, it is also far too easy for individuals to get a hold of
student information and use it for illegal purposes, including identity theft, child
abduction in custody battles, and domestic violence. Few parents are aware, for
example, that anyone can request -- and receive -- a student directory from a school.
Data and information breaches occur every day in Pre-K-20 schools across the country,
so that protecting student privacy has become a matter of plugging holes in a dyke
rather than advancing a comprehensive policy that makes student privacy protection
the priority.
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| United States House of Representatives Committee on Education and Labor Hearing on “How Data Can be Used to Inform Educational Outcomes” April 14, 2010 | Date Captured | Monday March 14, 2011 07:36 PM | |
1. States are warehousing sensitive information about identifiable children.
2. The Fordham CLIP study documents that privacy protections are
lacking and rules need to be developed and implemented to assure that
children’s educational records are adequately protected.
3. As part of basic privacy standards, strong data security is necessary to
minimize the risks of data invasions, scandals and melt-downs from
centralized databases of children’s personal information.
Statement of Joel R. Reidenberg, Professor of Law and Founding Academic Director Center on Law and Information Policy, Fordham University School of Law New York, NY
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| CHILDREN’S EDUCATIONAL RECORDS AND PRIVACY -- A STUDY OF ELEMENTARY AND SECONDARY SCHOOL STATE REPORTING SYSTEMS -- October 28, 2009 | Date Captured | Friday October 30, 2009 09:44 AM | | [The Study reports on the results of a survey of all fifty states and finds that state educational databases across the country ignore key privacy protections for the nation's K-12 children. The Study finds that large amounts of personally identifiable data and sensitive personal information about children are stored by the state departments of education in electronic warehouses or for the states by third party vendors. These data warehouses typically lack adequate privacy protections, such as clear access and use restrictions and data retention policies, are often not compliant with the Family Educational Rights and Privacy Act, and leave K-12 children unprotected from data misuse, improper data release, and data breaches. The Study provides recommendations for best practices and legislative reform to address these privacy problems.]
Joel R. Reidenberg, Professor of Law and Founding Academic Director of CLIP
Jamela Debelak, Esq., Executive Director of CLIP |
| The market for information about your childrenCA: State colleges, alumni groups reap $6.6M in credit card royalties | Date Captured | Friday September 02, 2011 08:29 PM | | Erica Perez; Under the agreements, banks typically get exclusive rights to market credit cards to university students and alumni, and they pay royalties to the universities or related organizations based on the number of new credit card accounts opened.] Excerpt from source linked to entry: [university must give the bank mailing lists for alumni, faculty, staff, fans, ticket holders, donors, undergraduates and graduate students. The lists include postal addresses, telephone numbers and e-mail addresses.] |
| American Student List (ASL)| Date Captured | Monday March 07, 2011 05:39 PM | | Student data for sale ONLINE. College Bound High School Students - Over 3 million high school juniors and seniors who have indicated an interest in higher education. Selectable by class year, age, head of household, income, geography and more;
Teenage Lifestyle Interests - 5 million individuals ages 14-19. Selectable by self-reported interests in specific areas including sports, scholastic activities, careers, computers and more;
College Students -
Approximately 5 million students attending numerous colleges and universities. Home and/or school addresses and phone numbers are available. Selectable by class year, field of study, college attended, tuition level, competitive rank and more;
College Grads And Alumni - Approximately 17 million College Grads/Alumni. Selectable by school last attended, household income, home ownership and more; Families With Children -
20 million households with the presence of children, tweens and teens (newborn through age 19). Selectable by head of household, income, gender, ethnicity, geography and more.
Ethnic Lists - Over 3 million Ethnic Teens, 4.5 million Ethnic Families and 15 million Ethnic Young Adults. Numerous backgrounds are available including Hispanic/Latino, Asian-American, Native-American, African-American and more. Also available — Foreign-Speaking Teens — first- or second-generation teens who speak the language of their ethnic group. |
| Schools Selling Students' Personal Information| Date Captured | Wednesday October 06, 2010 03:17 PM | | [KPRC Local 2 investigative reporter Amy Davis obtained the data for thousands of students from the Houston Independent School District simply by asking for it. She shows you how a lot of other people are getting the same information you may not want them to have.]
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| FAIR INFORMATION PRACTICE PRINCIPLES| Date Captured | Friday October 30, 2009 11:08 AM | | Over the past quarter century, government agencies in the United States, Canada, and Europe have studied the manner in which entities collect and use personal information -- their "information practices" -- and the safeguards required to assure those practices are fair and provide adequate privacy protection. The result has been a series of reports, guidelines, and model codes that represent widely-accepted principles concerning fair information practices. Common to all of these documents [hereinafter referred to as "fair information practice codes"] are five core principles of privacy protection: (1) Notice/Awareness; (2) Choice/Consent; (3) Access/Participation; (4) Integrity/Security; and (5) Enforcement/Redress.
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| US Education Department | DEPARTMENT OF EDUCATION 34 CFR Part 99 in the Federal Register (76 FR 19726)| Date Captured | Monday December 05, 2011 11:20 AM | | SUMMARY: The Secretary of Education
(Secretary) amends the regulations
implementing section 444 of the General
Education Provisions Act (GEPA),
which is commonly referred to as the
Family Educational Rights and Privacy
Act (FERPA). These amendments are
needed to ensure that the U.S.
Department of Education (Department
or we) continues to implement FERPA
in a way that protects the privacy of
education records while allowing for the
effective use of data. Improved access to
data will facilitate States’ ability to
evaluate education programs, to ensure
limited resources are invested
effectively, to build upon what works
and discard what does not, to increase
accountability and transparency, and to
contribute to a culture of innovation and
continuous improvement in education.
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| Basic Concepts and Definitions for Privacy and Confidentiality in Student Education Records | Date Captured | Thursday March 03, 2011 01:21 PM | | NCES 2011-601 This first brief discusses basic concepts and definitions that establish a common set
of terms related to the protection of personally identifiable information, especially
in education records.
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| NCES 2011-602 Data Stewardship: Managing Personally Identifiable Information in Electronic Student Education Records | Date Captured | Tuesday January 04, 2011 09:55 PM | | SLDS Technical Brief - Guidance for Statewide Longitudinal Data Systems (SLDS) [A privacy and data protection program for student education records must include an array of
rules and procedures for protecting PII held in the record system. It also must include a full set
of public disclosures of the existence and uses of the information included in the data system,
a description of all parents’ or eligible students’ rights to review and appeal the contents of an
individual education record and of their rights and the procedures to appeal a violation. ]
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| WelfareDecember 2011 FERPA Regulations: Information Sharing Around Child Welfare and Education| Date Captured | Thursday January 26, 2012 08:02 AM | | The new rules offer expanded opportunities for state or local child welfare and education agencies to share information. However, given that these new regulations do not sufficiently eliminate the barriers to intersystem communication for children in care, we look forward to legislative changes to ensure that child welfare agencies can fulfill their duty to ensure that the educational needs of the children in their care are met. |
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