Page 23 - THE Journal, October/November 2018

ADVOCACY
Linnette Attai
Prioritizing Privacy:
Managing Tracking Technologies
WHEN DOING THE WORK to protect student data privacy, a school district’s first priority is often to focus on the most sensitive
information, like Social Security numbers, financial information or health data, and ensure that information is adequately protected. Once
that work is complete, districts are able to address appropriate protec- tion measures for other important data, including student contact infor- mation, grades, test scores and more. It is an almost never-ending funnel
of information to cover, and it often cannot all be addressed at once.
Given the already wide array of responsibilities that school systems face and the lim- ited resources they possess, it is critical to prioritize the work based on a threat matrix,
as previously discussed by CoSN.
Not to be forgotten in all of this, however, is data that are passively collected through
tracking technologies used by various applications, including the school system website. Common situations that involve the use of tracking technologies include serving the web- site content to a user, understanding how a website is used, understanding if a website or application is functioning properly, providing users with the ability to easily interact with social media through a website or other online platform, as well as serving advertising.
All tracking technologies have privacy implications. Whether those implications would be problematic for your school system often depends on what third parties are
used to perform those functions, how they are configured and if the user is an adult or a student.
The first step in understanding if your tracking technologies are being used in ways that are appropriate and aligned with your legal responsibilities is to know what is being done and by whom. Doing so will help you make smart decisions about what third parties to permit and how to keep control over your data ecosystem. To get started, download the CoSN (the Con- sortium for School Networking) District Application Inventory Worksheet and take an inventory of not only the third parties operating on your website, but all of your key district applications.
With your inventory in hand, consider whether all of the tracking technologies are
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