Principal [redacted],
My name is Sam Davies, father of [redacted], a sixth grader at [a Richmond, VA middle school]. I’m writing about the letter you sent home dated January 23rd, 2019 about [the middle school] participating in a Google Apps for Education pilot.
I have reservations about sharing my child’s personal data with a third-party service provider, especially one that makes its revenue using individualized profiles to target users for advertising. I feel the need to approach this pilot with a healthy skepticism.
Most pressing, your letter indicates that this pilot starts on Tuesday, January 29th, 2019, less than one week from the date of your letter. Under the Family Educational Rights and Privacy Act, schools are required to obtain written consent from parents before disclosing students’ records or any personally identifiable information to any third parties. Neither my wife nor I have given such consent. Also, my daughter will only be 12 at the time the pilot starts, and unable to give consent under the Children’s Online Privacy Protection Act.
Google’s own documentation states in the “Can G Suite for Education be used in compliance with the Children’s Online Privacy Protection Act (COPPA) of 1998?” section:
We contractually require that schools using G Suite for Education get the parental consent required by COPPA. Our services can be used in compliance with COPPA as long as a school has parental consent.
I’m not fundamentally opposed to services like this for my child, but I want to ensure that her privacy is protected. The omission of parental consent has me concerned that Richmond Public Schools might not have taken the proper steps required of it by Federal and State laws to protect the personally identifiable data of my child. I’m excited at the chance for my daughter to participate in a more 21st Century classroom, but not if we adults haven’t done our jobs to protect her privacy.
Some specific questions:
- What information about students will be provided to Google?
- What is the privacy policy related to RPS students use of Google services?
- Can a RPS student expect any 4th amendment privacy when using Google Apps for Education?
- What are the terms of service regarding what data is being collected from students by Google and how it will be used?
- Can RPS provide me a copy of the contract it has signed with Google for these services?
- Is there an option for students/families to opt out of this technology? Is there an alternative technology that can be used?
I understand that you, as principal, probably don’t have answers to these questions yourself. I’m available to meet personally with whichever RPS official(s) might be able to address my concerns. I do hope that my concerns can be addressed for the positive so that my child can fully participate in her great school.
Sincerely,
Sam Davies
