From: Kim Belcher <kkbelcher713@aol.com>
To: ashleyvann <ashleyvann@katyisd.org>; courtneydoyle <courtneydoyle@katyisd.org>; charlesgriffin <charlesgriffin@katyisd.org>; rebeccafox <rebeccafox@katyisd.org>; billlacy <billlacy@katyisd.org>; bryanmichalsky <bryanmichalsky@katyisd.org>; georgescott <georgescott@katyisd.org>
Cc: lancehindt <lancehindt@katyisd.org>
Sent: Wed, May 17, 2017 8:59 am
Subject: KISD Use of Technology / Student, Teacher Privacy and Protection

Good morning.

I addressed the previous president and board, as well as the superintendent on a number of occasions over the last year regarding the protection and privacy of student and teacher data.

As Katy ISD continues to extend the use of technology, the Texas Education Commissioner and our State Legislature have been aggressively pursuing new ways to collect data on our children and teachers. I observed Commissioner Mike Morath in early Next Generation Assessment and Accountability hearings as he explored the system that will eventually follow the STAAR. I challenged Texas Senate Education Committee Chairman Larry Taylor during the Senate hearing on data driven initiatives.

Commissioner Morath gleefully boasted about Texas and the federal government “already collecting millions of metrics of data” on our students and how he was thrilled that the NGAA system would increase those numbers exponentially. He was ecstatic about this, despite admitting that they have no idea what to do with a great deal of the data or how it will ultimately be used in the future as it compounds.

Senator Taylor pounded his fist on the dais in front of a room full of hardware, software and IT infrastructure salesmen in Austin last September, as he stated, “We have to hurry up and implement this!” He was referring to putting the infrastructure in place to equip students with 1:1 scenarios of chromebooks or similar devices so that we may track the “progress” of every student.

Progress it seems is not just something that is being considered in the form of academics. Commissioner Morath went on in later hearings to inform us of his plans to implement standards for social emotional learning (SEL) and how he looked forward to being able to not only track student and teacher academic performance, but also their most intimate data, social and emotional responses to stimuli in the classroom. He elaborated on the SEL standards to explain how we should be setting the standards for the attitudes, behaviors and beliefs of our children, but that is a story for another day.

I share all of this with you to return to my point that I have expressed over the last year, that has been left unaddressed by Superintendent Hindt and the previous board.

Our district should be paving the way in exhibiting some form of local control over how student and teacher data is collected, stored, disseminated and destroyed. Whether the district should challenge some of the data required by state and federal mandates is a different issue, although I think it is worth mentioning for future consideration.

As the district accelerates its use of technology in the form of devices, software and “apps,” parent, teacher and student rights and privacy must be at the forefront of planning, despite loopholes in laws or regulations like FERPA and COPPA.

Since my first request to you a year ago, I have worked with my campus to develop a plan for my child. It is is not ideal, but for the most part, we have made it work. It meant that I had to opt him out of everything and start from scratch working with each teacher to determine what data collection points he would encounter for each class and why. In some cases, I approved of the applications and in others, I did not, particularly if there was personally identifiable information involved. For 70,000+ students, this is not an ideal process, as it would be overly burdensome to teachers and staff. I think the district should address it from an overall standpoint.

The district should take proactive steps to review its contracts with providers of technology. You will find, in some cases, contracts with providers like Google, name the provider as a “school official” entitling the provider to the same access to data and use of data as the district. In some cases, teachers are using apps and tools that are not administered by the district that are sourced to them through other groups. There is not necessarily a contract in place other than perhaps a user agreement the teacher may use to accept terms and conditions, which leave the district, students and teachers vulnerable.

This link provides a list of software and hardware that was provided to me at the beginning of the year. I would venture to guess that it has changed since that time. https://lookaside.fbsbx.com/…/Katy%20ISD%20Software%20Hardw… ;

I would encourage the district to consider questions like:
* Does this device or application collect student or teacher information?
* For what purpose?
* For whose purpose?
* Where is the research to support this use of this application?
* Who will measure the effectiveness of the data collected and when?
* How is the data shared with 3rd parties and their extended parties?
* Where is the data housed?
* How is data security ensured once it leaves the district?
* Can providers provide guarantees of data privacy and protection once it leaves the district or is shared with other entities?
* Who profits from the data, whether monetary or otherwise?
* Are 3rd parties permitted to share data without limits?
* What is the retention of the data?
* Who is responsible for managing the retention and/or destruction at each level that it is shared?
* Who is responsible for the compliance to ensure that all of the entities involved manage their responsibilities?

There are dozens of other questions that I think should be taken into consideration, but they all center around responsible contract management and whether there is a purpose for which the data is collected to ensure that teachers and students are ensure privacy and protection of their data, as well as protecting the rights of parents to ensure their authority is not undermined. The district should know and be able to share the life cycle of data collection for each and every point of collection.

This link is to a toolkit that is provided by the Parent Coalition for Student Privacy. It contains a great deal of useful information and resources: https://www.studentprivacymatters.org/toolkit/. ;

Given new leadership and a new member to the board, I am hopeful that the future relationship between the board/district and the community will be more productive in solving issues like this.

I would appreciate a response to indicate whether this is an issue that the board will consider asking administration to address.

Thank you for your consideration.

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