2014 NMSBA School Law Conference

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1 2014 NMSBA School Law Conference STUDENT PRIVACY IN THE CLOUD Andrew M. Sanchez Jun Roh June 7, 2014

2 Student Privacy Concerns What is cloud computing? Kinds of Clouds: Public Cloud managed, owned and provided by some other than the school district; Private Cloud created by, located on, and/or maintained and controlled by the school district; Community Cloud shared private cloud among entities or agencies; Hybrid Cloud includes both public and private services and can be of varying types or models: two examples, first putting different things in different places, perhaps, having personally identifiable student and/or employee information in a private cloud and having public school policies or curriculum information in a public cloud, or, two, having the same application running in two places; Partner Cloud services offered by a provider to a limited and well defined number of parties.

3 Student Privacy Concerns Types of Cloud Services: Software as a Service (SaaS) Software hosting Platform as a Service (PaaS) Application development or deployment Infrastructure as a Service (IaaS) Data hosting

4 Procurement of Computer-based services and data services Technology advances: Becoming paperless educational system Computer-based everything Data storage Where does the information go? Who has access to it? Who is responsible for it s safekeeping? Can you audit compliance with contracts for services or data storage?

5 Why do we care about privacy? Data mining by companies like Google and Mircrosoft. Advertisements based on search engine history, Facebook, etc. Search cloud storage for trends and commonality to sell.

6 Privacy Privacy Lack of school district control Lack of training and expertise to supervise contracts Unauthorized secondary usage Complexity of regulatory compliance Addressing transborder dataflow restrictions Litigation Legal uncertainty

7 Privacy Not knowing how much regulated data is on or accessible by: Mobile devices and clouds or used by school employees or transferred to cloud-based file sharing applications Unsecured student and employee mobile devices.

8 Basic Computer Security IT Security Gaps in firewall and security applications Unwanted access Inadequate data deletion Compromise of management interface Inadequate monitoring, compliance and audit. The Cloud computing provider acts as a landlord and can lock you out under certain circumstances.

9 Federal laws-ferpa Family Educational Rights and Privacy Act is the law governing this issue. Storing student information is permitted in the cloud depending on the contract terms ensuring confidentiality.

10 FERPA requires Secure cloud services (personally identifiable information) Disclosure of student records exception to parent/student consent school officials are to manage records not cloud employees Reasonable methods to ensure that only school officials access student records and only those with a legitimate educational purpose or interest.

11 FERPA Limitations Do not give student records or information to cloud provider for product development and marketing School districts are responsible for privacy and security of student records and information in the cloud No private cause of action OCR complaint and action Recommendations for school districts use of cloud computing

12 Children s Online Privacy Protection Act Commercial websites that knowingly collect information about or target children under the age of 13 Privacy Policy is required for the website Verifiable parent consent required in some situations Lists responsibility of operator to protect children s privacy and security on-line, including restrictions on marketing. Protects personally identifiable information, including geolocation data (tracking cookies), photos etc., containing the child s image or voice.

13 COPPA requirements Applies to third-party plug-ins, websites and some on-line services. Student access to school district websites or on-line service, including may require parent consent. Cloud providers allowing data mining by other providers or by the cloud provider itself of stored-information, including student information is outside of COPPA for them They can create behavioral advertising and build user profiles from data.

14 Early Litigation Google sued over unlawful interception of electronic communications ( s and other federally protected communications) using Google Apps for Education (GAFE) accounts. Google claims that scanning (data mining) is part of their ordinary business practices and users agree to the scanning in Google s terms of service. Have you read any of these or did your IT employee just press accept Why was the issue not part of the RFP and contract for the school district?

15 Mobile Apps Apps now support advertising and product targeting. Epson printer app collected personally identifiable information on users. User agreement allowed Sold to advertisers Your apps are Watching You Wall Street Journal (December 17, 2010)

16 Mobile Apps Future of Privacy Forum (November 7, 2012) Privacy-Papers-for-Policy-Makers Find my iphone app Apple has access/app provider AT&T family and friends locator AT&T has access

17 CONTRACTS School district owns its data exclusively What the provider will do to protect the school district for data loss, unauthorized disclosure and changes and theft Set forth the provider s responsibility in the event of a data breach Address the unique data confidentiality requirements of the school district in detail (FERPA, IPRA etc.)

18 CONTRACTS Provide for an effective privacy and security audit Limit the provider s use of data to solely what is necessary for its fulfillment of its obligations under the contract Specifically exclude the provider from any data mining of student/parent or employee and school district data or allowing third parties or affiliated parties to do so Exclude all other collateral commercial uses of student/parent, employee and school district data

19 CONTRACTS School District must be able to access its data in a specific format when it is needed for audits, investigations and litigation Provider will not be allowed to modify or destroy the school district s data, the school district should be able to control when its data is destroyed, duplicated and preserved Restrict the provider from storing the data to the United States where the laws protecting data enforceable. Outside countries may allow data mining.

20 CONTRACT LANGUAGE Beware of deals, programs or additional services to be purchased to provide data privacy and security from the provider who can do it under contract at no additional cost Beware of indemnification provisions in user agreements, requiring the school district to indemnify the provider it has data breach or security breach Beware of dispute resolution provisions barring litigation and requiring arbitration Beware of disputer resolution provisions providing that if there is litigation it will be limited to the home state of the provider or some other jurisdiction outside of New Mexico.

21 Questions

22 Contact Information Andrew M. Sanchez (505) Jun Roh (505)

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