Data Privacy & Security Service
Issue 13
CoSN RESOURCES FOR ED TECH LEADERS Protecting Student Data Privacy Starts with Leadership by Linnette Attai, Project Director for CoSN’s Privacy Initiative & Trusted Learning Environment Program and President, Playwell, LLC
Developing a data privacy governance program is not the job of one person or one team. It is a multi-stakeholder endeavor that requires every- one’s involvement and atten- tion, and no such program can be successful without effective leadership support. In fact, given the importance of the is- sue and the depth and breadth of work that’s required to build a robust student data privacy program, the effort must begin with leadership. Strong leadership brings atten- tion to the issue, establishes the tone, sets the direction and establishes key data protec- tion policies. Leadership is responsible for ensuring that the school system has the re- sources required to build and maintain a strong student data privacy program and that the organization takes a holistic approach to the work. Creating the proper approach to the work takes some plan- ning. Here are some key steps to set your district up for success: • Understand federal and state student data privacy laws and ensure that lead- ership discussions include ongoing consideration for
data privacy and security. Ensure that the leadership team is fluent in the re- quirements so that discus- sions are well-informed and comprehensive. • Prepare and maintain policies that reflect the regulatory requirements for protecting student data privacy. Remember that the policies you set are not a restatement of the laws, but an explanation of the expectations for district employee behavior in align- ment with what the laws require. • Ensure that there are de- fined procedures to accom- pany each policy. Partner with your school system departments to define the expectations for behav- ior in order to ensure that policies are implemented properly, in alignment with the laws and community norms. • Identify an executive-level leader to be responsible for development and imple- mentation of data privacy and security policies and practices. Be sure this person is qualified and has the training, resources and support necessary to do the work.
• Provide transparent, up- dated and accessible information for the commu- nity about how the school system protects the privacy of student data. Consider how you partner with your community to let them know how and why the school system is collecting data, and how it is used and protected. • Ensure that adequate re- sources are available to the school system to properly protect student data. Con- sider whether or not the work of protecting student data is prioritized properly
“Strong leadership brings attention to the issue, establishes the
tone, sets the direction and
establishes key data protection policies.”
in terms of both your atten- tion and budget.
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