Page 24 - THE Journal, October/November 2018
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permitted by current privacy laws and your district policies. It’s often easiest to start this work by examining your school system website. What third parties are operating on your site? What is the purpose for each, and what data are they collecting to do the work? Are they doing something more with the data than provid- ing the service to your district? If so, can they be configured differently to address the issue or not? Answering these questions will empower you to make well informed decisions about what should be on your website.
“We have found value in using selective third-party applications integrated into our website. We try to stay aware of what tracking elements are captured by the products, but that requires due diligence to understand. It’s a significant undertaking, but we are constantly improving. We work diligently to review our third-party integrations and to inform our visitors about them and about the data they may capture.”
– Louis McDonald, Director, Technology Services, Fauquier County Public Schools
Many districts rely on the hosting provider or developer to manage their websites, but remember that they are also your third- party service provider. While they may be able to provide you with answers to some of your questions about the tracking technologies that are being used, they do not own or operate the site — you do, and what ends up on the site is your responsibility.
In addition, ensure that your website has a privacy policy that comes from you, as the operator of your website, not from your third-party provider. The policy should adequately disclose how all personally identifiable data is being collected, handled and shared; this includes the information collected passively through tracking technologies and what is shared with your hosting provider.
Once you’ve successfully managed this work on your own web- site, you will be better informed and better equipped to examine how other technology providers are operating, improving the matu- rity of your district’s privacy program as you go.
For more information on tracking technologies and how to manage your school system website, check out these resources from CoSN.
Linnette Attai is is project director for the CoSN Protect- ing Privacy in Connected Learning Initiative and the Trusted Learning Environment Seal Program. She is also president of PlayWell LLC compliance consulting.

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