During a recent workshop on student privacy and security, the US Department of Education’s Chief Privacy Officer, Kathleen Styles, said she wants to hear from parents, wants to know what is happening on the ground.  Ms. Styles in her closing remarks said  “the group which is hardest for us to hear from are parents.”   Wow.  I’ll take that invitation; I have written an open letter to Ms. Styles, linked at the end of this blog.

The workshop mentioned above was a joint project co-hosted by the Federal Trade Commission (FTC) and the US Department of Education (USDoE) to explore privacy issues related to education technology  (edtech). They invited public comments prior, which you can view here.  (The comments are few and brief. A quick read.) The workshop was held December 1, 2017 and you can see videos of all 4 panels here.  Please watch what you can, the videos are very informative.

Below I have highlighted a few excerpts from one panel in particular, the fourth and final panel, Where do we go from here?”   See this link for a list of the panelists.

excerpts: panel 4 video  https://www.ftc.gov/news-events/audio-video/ftc-events

  • at 35 minute mark of the panel 4 video, answering whether parents should be allowed to consent on what apps are used in the classroom,   Steve Smith says,  the consent model is too burdensome
  • at 35min 47 seconds,  Amelia Vance from Future of Privacy Forum asks, “What is the value of consent? … The thing that I worry about in a consent regime in addition to the administrative duties….like Steve said, we don’t have parents approve every single text book and the desk their child sits at and the gradebook that is used.  …You also have a situation that I worry about, if we are talking about bad districts; I worry about more a district passing the responsibility onto a parent who doesn’t probably have the expertise to evaluate the privacy and security implications of a particular app. If something is dangerous, it’s not that it needs parental consent, it’s that it should not be used in a school.  …and when we talk about consent, I think we need to be very careful about not passing the buck onto the parents.”
  • at 50 minute mark, FTC’s Kristen Cohen promises Fransicso Negrón from the National School Boards Association  that,  Let me just be very clear, the schools will never be held liable under COPPA”. 

For those not familiar, COPPA is meant to safeguard young children (children 13 years and younger) when they go online, safeguarding them from sites that collect and MARKET their data.  COPPA requires informed parental consent, except that a school can take the place of a parent and currently nonprofits and government agencies are exempt.

It is rather shocking to hear the FTC say that  schools will never be held liable under COPPA.

My question, will the FTC protect school children and will the FTC ever hold education technology vendors liable?  If not, who will?


  • at 1hr,12 minute mark of the panel 4 video,  parent Rachael Stickland, of the Parent Coalition for Student Privacy  answers a question as to whether a few vocal, privacy protective parents concerned about privacy should be able to veto the use of educational apps in the schools.  Ms. Stickland responded, “Privacy is one of parents’ concerns but the lack of evidence or research that these edtech products are going to do what they say they are going to do.  …So rather than vocal parents vetoing something, I think the school district should bring parents in at the very early preliminary stages and make the case for the edtech, work together, talk about not just benefits but talk about the reality of edtech, screen time, exposure to content that hasn’t been vetted.  I would never promote that vocal parents should be obstacles. I advocate that schools should see parents as allies and work together.”
  • at 1hr,13 minute mark David Monahan,  of the Campaign for a Commercial- Free Childhood says, “Something we bring to the discussion is questioning what is being done, whether kids are better off with the technology. We’re hearing tech is here, it’s in the classroom, accept it.  But there is not the evidence showing that kids are better off because of technology.”  Mr. Monahan mentions this recent piece in the NY Times where a Michigan Professor says she doesn’t allow laptops in the classroom because she has seen and studies show that laptops negatively impact both the student using the laptop and also the students situated near the laptop user. Mr. Monahan continues, “So when we talk about this transformation, not only have parents been left out in terms of consent, where’s the evidence that kids are better off?”
  • at 1hr,17 minute mark Ms. Vance suggests that the “solutions are training and funding and guidance”.
  • also at 1hr,17 minute mark Ms. Stickland follows up saying security is certainly an issue but “the bigger concern about the data being collected in schools are the ethical uses of Big Data, what that means for the future, where this data is going”.
  • at 1hr, 18 minute mark David Monahan says, “I don’t think it’s fair to put it all on the school districts for lack of funding. A lot of data breaches are from vendors not having strong safeguards in place.  Don’t ask government to… you [edtech] came to schools, you convinced them to buy these products and now you are saying it’s on them to protect the information. No, the vendors that are profiting ought to be investing in the protections to keep that data safe.” 
An interesting opinion piece was published in The Hill,  following the workshop. The piece, Securing student data is a challenge that requires cash, was written by privacy advocates from Common Sense Media and the Future of Privacy Forum and seems to ask the government for money to help the tech industry keep student data safe.
What are your thoughts?
As for me, while I appreciate the conversation and need for both security and privacy -we should be protecting students, not vendors.  I am incredibly grateful to David Monahan and Rachael Stickland for their testimony, and agree that vendors need to assume the responsibility.    I believe that vendors not only need to protect student data, they need to respect parent and student rights, need to prove their product is efficacious and safe prior to being introduced into a classroom…or be willing to accept a penalty, as in Europe.

An open letter to US Department of Education’s Chief Privacy Officer, Kathleen Styles:

Dear Ms. Styles, I am a parent.

I think many other parents would agree when I say parents want to reach you and other policy makers; we want a voice and want to be heard.  We are very much engaged, committed, and capable to represent our children.

Don’t discount us as not smart or unqualified. Don’t relieve us of the “burden” of making decisions for our own children when we are screaming from the rooftops that we WANT that “burden”.   Our children are our responsibility and consent is our right. COPPA and FERPA are not adequately protecting students’ privacy.  Minimizing data collection and sharing. adopting enforceable penalties would solve much of the security issues.  Frankly, the US Department of Ed  promotes edtech and doesn’t do enough to protect school children.

If GDPR gives Europeans (including students) more control on how their data is handled, including breach notification and penalty, data redaction, and consent.  Why would American students be any less deserving than students in Europe?  GDPR will have global implications.   Modernizing FERPA and COPPA to align with GDPR would be both practical and ethical.

Please, consider parents as equal if not incredibly important stakeholders.  Please let us choose how our children’s data is used and shared outside of school.

I was once told by a privacy “big fish” with millions of dollars in backing and edtech influence that,  “There is such a thing as being right, and then there is winning.”   Ms. Styles, I am a little fish, but children of little fish are no less deserving.

Why can’t we do what is right and protect children?  That is winning, in my book.

Thank you for holding this workshop and I sincerely appreciate you wanting to hear from parents.

Cheri Kiesecker,  a parent


Cheri Kiesecker

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