Intro
Indicators
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Examples
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Resources

Introduction

The purpose of this standard is to encourage you to reflect on the ways in which student data may be collected, used, and shared in your course. As a teacher, student privacy is especially important relating to how you may be sharing student information in your course and in the selection of online educational tools and technologies. Most online educational tools are designed to track student data in some way. For example, the college’s learning management system (LMS) collects data about how students interact with your course. As a teacher, you might use this type of information to nudge students who haven’t logged in recently, to compare student grades, or to improve quiz questions in your course. However, students are often unaware of how and why their data is being used and by whom. Disclosing this information to them creates transparency and helps students make more informed choices and encourages them to be more aware as digital citizens. Student data privacy is an ongoing topic of conversation in higher education and everyone shares the responsibility for protecting it, including federal and state governments, colleges, administrators, staff, technologists, instructional designers, students, faculty, and providers of online educational tools.

Online tools may track things like how much time a student spends completing a certain task along with additional information like the date, number of attempts, or related resources viewed. This type of additional information is called metadata and it describes and adds context to the student's data. When de-identified or when no login is required, data and metadata do not contain a student’s personally identifiable information (PII) which is protected by the Family Educational Rights and Privacy Act (FERPA) of 1974. Most online educational services collect user data for legitimate reasons like making product improvements or customizing the student's learning experience. However, some may collect student data for other less desirable purposes, like marketing additional products or services, selling student data to other parties, or exposing students to targeted advertising. A vendor's Privacy Policy or Privacy Statement will specify which types of data they collect, how they use it, how the data is shared and with whom, and how long the data is archived.

Why it Matters to Students ...

A friend just texted V saying “hey, you’re famous, just saw your picture on the college website” and sure enough, a picture of V, taken at a guest speaker event held last term, appears front and center on the Student Life page but V didn’t give anyone permission to use or post this image. (4.9.c) V is upset about the picture being used without consent and decides to search the college’s website for information about student privacy but doesn’t find anything. (4.9.a) V has actually been thinking a lot about privacy lately because it’s time for midterms and V’s Statistics teacher said that their online exam will be proctored and students will need to show their legal ID on camera, grant remote control to their computer, allow access to all files on their computer - even personal files, and be recorded on camera while a facial recognition program runs. (4.9.b) All of this makes V uncomfortable, especially since after the exam a reviewer will be able to see into V’s house and possibly see V’s family in the recording. The proctoring requirements seem like an invasion of privacy and V wonders what will happen to the recording after the test and also wonders how to make sure the software doesn’t allow access to unauthorized people. (4.9.b)

Consider This ...

What strategies do you use to ensure student data is protected in your course and to encourage students to be better digital citizens and stewards of their data?
When was the last time you read the Terms of Service (TOS) and/or Privacy Policy on an educational tool before deciding to use the tool in your course and clicking to accept the conditions? If you have read the TOS and Privacy policies for the tools in your course, how did you share that information with your students?
What process do you follow to vett the educational tools and technologies for privacy that are used in your course?

Indicators Explained

The Indicators for Standard 4.9 are organized by Essential, Best Practice, and Exemplary. Click the menu bars below to expand and read about the Indicators in each section.

Essential

Applying all Essential Indicators demonstrates that your course design includes the basic foundational elements that must be present for students to succeed in an online course.

4.9.a - Course includes links to college’s privacy policy.

A college’s privacy policy gives students information about how the college collects uses, shares, and protects student data. Such policies may also address the opt out rights students have and how students can report infringements. Many campuses have student privacy policies posted on their college website and often include privacy information related to all of the college's systems and services. For example, systems for registration, scheduling, tutoring, accessing grades, requesting transcripts, and/or library services. You might include information about the college’s privacy policy or a link to it in your syllabus, but it could also be highlighted in your “Start” module. Your institution or department might even require such a statement to be linked to, included in your syllabus, or included elsewhere in your course. You can further demonstrate your commitment to student data privacy by including a statement about student data use in your course and by discussing data use practices and data privacy considerations with your students.

4.9.b - Course includes links to privacy policies for course technologies and tools.

When selecting online tools and technologies for your course, you are the first line of defense so it is critical that you thoroughly read each vendor’s Terms of Service (TOS) and Privacy Policy carefully to avoid selecting tools where the vendor collects or stores unnecessary student data, sells or uses student data beyond the specified educational purpose, exposes students to behaviorally targeted advertising, or does not limit their data sharing. Students have a right to know how their data and personal information will be used. For transparency, you should be aware of and provide students with privacy information related to the educational tools and technologies used in your course. Providers of online educational tools and technologies, such as publisher’s learning platforms like McGraw Hill ALEKS or Pearson Education, study aids like Quizlet or Kahoot, proctoring tools like Honorock or Proctorio, web-conferencing platforms like Zoom or Big Blue Button, and recording tools like Panopto or Camtasia should all have their privacy policies posted on their website. The provider’s privacy policy will give students information about how their data is being collected, used, stored, shared, and protected by the provider. Such policies may also address rights students have and how students can report infringements. You might include a link to a provider’s privacy policy in your syllabus, but it could also be highlighted in your “Start” module and/or elsewhere in your course materials as you introduce new tools. You can further demonstrate your commitment to student data privacy by including a statement about student data use in your course and by discussing data use practices and data privacy considerations with your students.

4.9.c - Course design protects against unauthorized disclosure of non-directory student information.

A privacy law you are probably familiar with is the Family Educational Rights and Privacy Act (FERPA) of 1974. FERPA is a federal law protecting the privacy of personally identifiable information (PII) maintained in a student’s “education record” and it applies to all educational institutions receiving U.S. Department of Education funding. Education records maintained by a college include non-directory information like a student’s grades, transcripts, course schedules, and health records among other things - this type of information may not be disclosed. A student’s education record also includes disclosable directory information. In Washington state, the State Board for Community & Technical Colleges (SBCTC) governs the directory information colleges may share. Community and technical colleges in Washington can share a student's name, their major field of study, enrollment status, dates of attendance, participation in recognized sports, degree or certificate earned, term degree or certificate awarded, and honors received. You might be asking, what does FERPA have to do with the design of my online course? The list below outlines and offers guidance for the areas of your online course most likely to be impacted by FERPA.

Syllabus Netiquette Statement
- Advise students to ask questions or discuss topics of a more personal or sensitive nature in a private and confidential manner, especially if class sessions will be recorded or any type of open chat forum or an “Ask a Question” style discussion will be used.
Course Images & Lecture Recordings
- Get students’ permission before posting photos or screenshots in which they are clearly recognizable.
- Share class recordings that include the names, faces, voices, and chat participation of students only within the section of the course in which the recording was made.
Online Educational Tools
- Read the Terms of Service (TOS) and Privacy Policy for each online education tool used in your course. If a tool is free and/or students are required to create an account in order to gain access, the provider is probably collecting, and possibly sharing, your students’ data. Check to see if you and your students are eligible to sign-up for the education version of the tool which may have additional student privacy protections built-in. Advise students of their rights to opt out of a provider’s data sharing practices.
- Limit the use of tools and technologies, like proctoring software, that use highly intrusive practices like making students show their legal ID on camera, taking remote control of students’ computers, requiring access to all files - even personal files, using biometric information, and requiring cameras relaying facial recognition cues.
- Adjust application settings as needed to protect your students from unauthorized user access. For example, by changing the privacy settings in your web-conferencing room and/or account settings to deter “zoombombing”.
Grades
- Grant students access only to their own grades, grading feedback, and other progress-type check-ins using the Gradebook feature in your password protected LMS.
- Communicate grades to students only via secure channels avoiding tools like messaging apps, social media, and email which may be password protected, but not necessarily private or secure.
- Add observers and guest speakers to your online classroom using a role with permissions preventing access to student grades and other personally identifiable information.

When considering whether to use an online education tool, be sure to read the Terms of Service (TOS) agreement and Privacy Policy, especially if the tool hasn’t already been vetted by your college. Here are some questions to ask yourself and what to look for when vetting tools for privacy.

*Questions to Ask When Vetting Educational Tools & Technologies*
Questions to Ask	Desired Answer	Explanation
Does the product collect Personally Identifiable Information (PII)?	NO	PII is protected by FERPA. If yes, investigate further to determine how the data will be used.
Does the vendor share student information beyond what is needed to provide the educational service?	NO	The vendor should clearly promise never to sell a student's data.
Does the vendor create a profile of students beyond the specified educational purpose of their service?	NO	Vendors should create profiles only for the authorized educational purposes.
When a student cancels their account or deletes the app does the vendor delete all of the student’s data?	YES	Vendors should not maintain student data beyond the specified educational period.
Does the product expose students to targeted advertisements?	NO	Vendor sites displaying behaviorally targeted ads are undesirable.
Does the vendor allow students to access their data and request corrections?	YES	Students should be allowed to review and correct their data.
Does the vendor appropriately secure the data it collects?	YES	Vendors with secure products or services will specify use of encryption when storing or transmitting student information.
Does the vendor claim that it can change its privacy policy without notice at any time?	NO	Vendors may not make substantial changes to their privacy policies without notifying users and getting new consent for collection and use of user data.
Does the vendor state what happens to the data if the company is sold?	YES	Any sale or merger should require the new company to adhere to the same protections.
Do reviews or articles about the product or vendor raise any red flags that cause you concern?	NO	Searching for a product by name in combination with the phrase “student privacy” or “data breach” should not yield scary results.

Items in this section were adapted from "The Educator's Guide to Student Data Privacy" by Gallagher, Magid and Pruit licensed under CC BY 4.0

4.9.d - Course files include documented written consent to use identifiable images of students.

Images of students are protected by FERPA which means that any photo in which a student is clearly recognizable, should not be used without that student's express permission even if the photo was taken in a public place on campus. It is always better to err on the side of caution and use a release form for any identifiable student. Colleges and faculty should also be mindful of Washington state law Chapter 63.60 RCW: PERSONALITY RIGHTS pertaining to the use of an individual’s name, voice, signature, photograph, or likeness.

4.9.e - Course design limits the number of external account creations required by students.

In addition to being an inconvenience for students, the necessity of using multiple accounts external to, or outside of, the learning management system creates added opportunities for student data to be misused. Limiting the number of account logins required in your course can help protect student privacy and make learning easier for students. Be selective in the tools you use to ensure they align with your instructional goals and adequately protect student data. To help eliminate multiple logins, consider selecting a single tool or technology that meets the majority of your needs or using an existing tool in a new way rather than adding a new or different tool to your course. Having to learn too many new tools during a single term can be frustrating and time-consuming for both you and your students.

Next Steps

Applying all Essentials Indicators for this Standard combined with one or more of the following Next Steps Indicators demonstrates that your course design includes the basic foundational elements necessary for students to succeed in an online course plus additional elements that are intentionally designed to increase student success in your online course.

4.9.f - Course includes information about or engages students in discussion about why data privacy is important.

XXX

4.9.g - Course technologies and tools meet requirements for protecting student data privacy.

Students have a right to know how their data and personal information will be used and faculty have the responsibility of selecting tools that not only align with the learning goals of the course and that are equitable and accessible in use, but that also protect student data. One way you can help protect student data and respect student privacy is to select online educational tools and technologies that have been vetted for privacy. Some campuses may maintain a list of vetted online educational tools and technologies for you to choose from. This is a great place to start when selecting learning tools for your course. If your campus does not maintain its own list of approved tools, you can often find information about privacy vetted applications yourself simply by doing a quick internet search. A good place to start is to locate and read the provider's privacy policy. Some providers may even have additional information posted on their privacy page relating to privacy evaluation ratings they’ve earned through IMS Global’s TrustEd Apps Seal or Common Sense’s Privacy Program.

If you cannot find any information indicating that a specific tool has been vetted by your college or another organization, you can also vett the tool yourself using IMS Global’s TrustEd Apps Rubric or by researching the answers to the questions below.

*Questions to Ask When Vetting Educational Tools & Technologies*
Questions to Ask	Desired Answer	Explanation
Does the product collect Personally Identifiable Information (PII)?	NO	PII is protected by FERPA. If yes, investigate further to determine how the data will be used.
Does the vendor share student information beyond what is needed to provide the educational service?	NO	The vendor should clearly promise never to sell a student's data.
Does the vendor create a profile of students beyond the specified educational purpose of their service?	NO	Vendors should create profiles only for the authorized educational purposes.
When a student cancels their account or deletes the app does the vendor delete all of the student’s data?	YES	Vendors should not maintain student data beyond the specified educational period.
Does the product expose students to targeted advertisements?	NO	Vendor sites displaying behaviorally targeted ads are undesirable.
Does the vendor allow students to access their data and request corrections?	YES	Students should be allowed to review and correct their data.
Does the vendor appropriately secure the data it collects?	YES	Vendors with secure products or services will specify use of encryption when storing or transmitting student information.
Does the vendor claim that it can change its privacy policy without notice at any time?	NO	Vendors may not make substantial changes to their privacy policies without notifying users and getting new consent for collection and use of user data.
Does the vendor state what happens to the data if the company is sold?	YES	Any sale or merger should require the new company to adhere to the same protections.
Do reviews or articles about the product or vendor raise any red flags that cause you concern?	NO	Searching for a product by name in combination with the phrase “student privacy” or “data breach” should not yield scary results.

Items in this section were adapted from "The Educator's Guide to Student Data Privacy" by Gallagher, Magid and Pruit licensed under CC BY 4.0

Canvas Tools

These Canvas tools can help you meet this standard and make your work easier:

Syllabus: Use the Syllabus page to prominently display important course information. For example, including a section addressing the privacy of course tools and technologies with links to vendor privacy policies.
Grades + SpeedGrader: Use the Canvas SpeedGrader and Gradebook to communicate grade information with students. For example, to securely grade student submissions, house student grades, and leave grading feedback for your students.
Modules + Pages: Use a Page added to your "Start" module to introduce each learning technology. For example, a page addressing the privacy of course tools and technologies with links to vendor privacy policies.
People: Use People to add enrollments to your course. For example, to add a guest speaker or observer to your online classroom.
Canvas Privacy Policy: Link to Instructure's Privacy Policy to provide students with privacy information about Canvas.

Examples of Standard 4.9

Want to see how other instructors have applied this Standard in their course? Check out these examples!

Example 1

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Example 2

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Example 3

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Example 4

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Example 5

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Ways to Apply Standard 4.9

Need some ideas for how to apply this standard to your course? Try one of these!

4.9.a - Linking to college's privacy policy

(4.9.a) Add a link to your campus’ privacy policy to your Syllabus or the Start Module in your course.

4.9.b - Linking to privacy policies for course technologies

(4.9.b) Add links to the privacy policies for all of the educational tools and technologies used in your course to your Syllabus or the Start Module in your course. To help get you started, here are the links to the privacy policies for Canvas, Panopto, and Zoom.
(4.9.b) Include a section in your Syllabus or a page in the Start Module in your course with information about the importance of student data privacy and links to the privacy policies for all of the educational tools and technologies used in your course.
(4.9.b) Include a brief explanation and link to the privacy policy for the tool or technology when introducing students to the educational tools and technologies used in your course.

4.9.c - Protecting against unauthorized disclosure

(4.9.c) Review the roles of observers, guest speakers and others added to your course to ensure that they do not have permissions to view or change student grades.
(4.9.c) Review the settings, policies, and overall structure of your course to ensure that non-directory student information is not being inappropriately shared in your course. Adjust your course settings, policies, and structure as needed to comply with federal FERPA laws.
(4.9.c) Plan ahead if your course needs to be merged in Canvas with another section. Contact your campus eLearning office to learn about course merging policies and be sure that students are notified in the course schedule that multiple sections of your course will be meeting together.
(4.9.c) Add information about how students can help protect their own privacy by not disclosing personally identifiable information during synchronous class sessions to the netiquette statement included in the Syllabus or Start module of your course.

4.9.d - Consent to use images of students

(4.9.d) Review the lecture videos in your course to ensure that recordings of synchronous class sessions containing identifiable student information are shared only with the course section in which they were recorded.
(4.9.d) Review the images used in your course to ensure that photos in which individual students are identifiable have not been used without the student’s permission. Remove any problematic images as needed or get written consent from the student(s) to use the image(s) using SBCTC’s photo release form or a photo release form provided by your college.

4.9.e - Limiting the number of student logins

(4.9.e) Review the number of EdTech tools used and external logins required for students taking your course to identify unnecessary account logins. Remove any unnecessary tools from your course.
(4.9.b) Ask students to give you feedback on the educational value of the EdTech tools used in your course and the number of external logins required. Make adjustments as needed to reflect student feedback.

4.9.f - Including information about the importance of data privacy

(4.9.f)

4.9.g - Meeting requirements for student privacy

(4.9.g) Ask your campus eLearning or IT office if they maintain a list of privacy vetted educational tools and technologies. If they do, compare the tools you’re using in your course to their list and make adjustments as needed.
(4.9.g) Work with your campus eLearning or IT office to investigate and vett the educational tools and technologies used in your course.
(4.9.g) Do an internet search of each educational tool or technology used in your course combined with the words student privacy or data breach. Evaluate the information you find and adjust the tools in your course as needed.
(4.9.g) Review the educational tools and technologies used in your course for privacy evaluation ratings earned through IMS Global’s TrustEd Apps Seal or Common Sense’s Privacy Program. If your tools have not been evaluated or have failed the evaluation process, consider vetting the tool yourself or looking for an alternative tool to replace it. Use the information you find to make adjustments to the tools and technologies in your course as needed.
(4.9.g) Practice vetting several EdTech tools and technologies for privacy by comparing your results with those from Common Sense Privacy Evaluations or IMS Global’s TrustEd App Rubric. When you feel confident in your skills, try vetting a tool used in your course.

Resources

Recommended Reading

Document: Protecting Student Privacy While Using Online Educational Services: Requirements and Best Practices by the U.S. Department of Education provides context for the protection of student data in relation to the use of 3rd party educational tools
Video and Slides: Student Privacy Training for Educators - Adopting EdTech: Privacy Vetting - by Student Privacy Compass overviews best practices for privacy vetting when adopting new course technologies from a K-12 perspective but the information applies for college faculty as well
Website & Netflix Original Documentary: The Social Dilemma from Exposure Labs features conversations with tech insiders, researchers, and activists discussing how technology has had unintended consequences for humanity and society

References

4.9.a - Linking to college’s privacy policies

Park, J., & Vance, A. (2021). Data Privacy in Higher Education: Yes, Students Care. Educause. Retrieved July 19, 2021, from https://er.educause.edu/articles/2021/2/data-privacy-in-higher-education-yes-students-care
U.S. Department of Education. (2014). Protecting Student Privacy While Using Online Educational Services: Requirements and Best Practices. Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/resources/protecting-student-privacy-while-using-online-educational-services-requirements-and-best

4.9.b - Linking to privacy policies for external tools and publisher content

Common Sense. (n.d.). Privacy Program. Common Sense. Retrieved July 16, 2021, from https://privacy.commonsense.org/
Evers, W. M., & Hofer, J. (2020). Remote Learning Companies Are Endangering Student Privacy. Real Clear Education. Retrieved July 16, 2021, from https://www.realcleareducation.com/articles/2020/12/23/remote_learning_companies_are_endangering_student_privacy_110523.html
Git Hub. (2020). commonsense-org / privacy-questions-output. Git Hub. Retrieved July 16, 2021, from https://github.com/commonsense-org/privacy-questions-output/blob/main/full-questions.md
IMS Global. (n.d.). Data Privacy Specification - Appendix A Details for the Rubric. IMS Global. Retrieved July 23, 2021, from http://www.imsglobal.org/spec/privacy/v1p0#details-for-the-rubric
Kelley, J. (2020). Students Are Pushing Back Against Proctoring Surveillance Apps. Electronic Frontier Foundation. Retrieved July 16, 2021, from https://www.eff.org/deeplinks/2020/09/students-are-pushing-back-against-proctoring-surveillance-apps
Kshetri, N. (2020). Remote education is rife with threats to student privacy. The Conversation. Retrieved July 16, 2021, from https://theconversation.com/remote-education-is-rife-with-threats-to-student-privacy-148955
Park, J., & Vance, A. (2021). Data Privacy in Higher Education: Yes, Students Care. Educause. Retrieved July 19, 2021, from https://er.educause.edu/articles/2021/2/data-privacy-in-higher-education-yes-students-care
Quality Matters. (2018). Higher Education Standards for Course Design - Standard 6.4 The course provides learners with information on protecting their data and privacy. (MaryLandOnline, 6th ed.) [Rubric Workbook]. https://www.qualitymatters.org/sites/default/files/PDFs/StandardsfromtheQMHigherEducationRubric.pdf
Student Privacy Compass. (n.d.). Educator’s Guide To Student Privacy. Student Privacy Compass. Retrieved July 16, 2021, from https://studentprivacycompass.org/audiences/educators/
Gallager, K., Magid, L., & Pruitt, K. (n.d.). Educator’s Guide To Student Privacy. Student Privacy Compass. Student Privacy Compass. Retrieved July 16, 2021, from https://studentprivacycompass.org/audiences/educators/
U.S. Department of Education. (2014). Protecting Student Privacy While Using Online Educational Services: Requirements and Best Practices. Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/resources/protecting-student-privacy-while-using-online-educational-services-requirements-and-best

4.9.c - Protecting against unauthorized disclosure of non-directory student information

Common Sense. (n.d.). Privacy Program. Common Sense. Retrieved July 16, 2021, from https://privacy.commonsense.org/ U.S. Department of Education. (2015). Data Security Checklist. Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/resources/data-security-checklist
U.S. Department of Education. (2020). Family Educational Rights and Privacy Act (FERPA). U.S. Department of Education. Retrieved July 15, 2021, from https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html
U.S. Department of Education. (n.d.). Student Privacy at the U.S. Department of Education. Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gU.S. Department of Education. (n.d.). What is an education record? Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/faq/what-education-recordov/
U.S. Department of Education. (n.d.). What is an education record? Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/faq/what-education-record
Washington State Board for Community & Technical Colleges. (2021). FERPA Directory Information. Washington State Board for Community & Technical Colleges. Retrieved July 15, 2021, from https://www.sbctc.edu/colleges-staff/commissions-councils/pic/pio-resource-manual/ferpa-pio.aspx
Washington State Board for Community & Technical Colleges. (2021). SBCTC Policy Manual Chapter 5: Enrollment Reporting and Tuition and Fees. Washington State Board for Community & Technical Colleges. Retrieved July 15, 2021, from https://www.sbctc.edu/colleges-staff/policies-rules/policy-manual/chapter-5.aspx
Washington State Legislature. (1998). Chapter 63.60 RCW Personality Rights. Washington State Legislature. Retrieved July 15, 2021, from https://app.leg.wa.gov/RCW/default.aspx?cite=63.60

4.9.d - Consent to use photos of students

U.S. Department of Education. (n.d.). FAQs on Photos and Videos under FERPA. Protecting Student Privacy. Retrieved July 13, 2021, from https://studentprivacy.ed.gov/faq/faqs-photos-and-videos-under-ferpa
Washington State Board for Community & Technical Colleges. (2021). FERPA Directory Information. Washington State Board for Community & Technical Colleges. Retrieved July 15, 2021, from https://www.sbctc.edu/colleges-staff/commissions-councils/pic/pio-resource-manual/ferpa-pio.aspx
Washington State Legislature. (1998). Chapter 63.60 RCW Personality Rights. Washington State Legislature. Retrieved July 15, 2021, from https://app.leg.wa.gov/RCW/default.aspx?cite=63.60

4.9.e - Limiting the number of external account creations

X
X

4.9.f - Including information about the importance of data privacy

X
X

4.9.g - Vetting tools for data privacy requirements

Student Privacy Compass. (n.d.). Best Privacy Practices for Using Apps in the Classroom. Student Privacy Compass. Retrieved July 16, 2021, from https://studentprivacycompass.org/audiences/educators/using-apps-in-the-classroom/
Student Privacy Compass. (n.d.). Student Privacy Training for Educators - Adopting EdTech: Privacy Vetting. Student Privacy Training for Educators. Retrieved July 21, 2021, from https://studentprivacycompass.org/resources/educatortraining/#edtechvetting
U.S. Department of Education. (2016). Protecting Student Privacy While Using Online Educational Services: Model Terms of Service. Protecting Student Privacy. Retrieved 7 16, 2021, from https://studentprivacy.ed.gov/resources/protecting-student-privacy-while-using-online-educational-services-model-terms-service
U.S. Department of Education. (2014). Protecting Student Privacy While Using Online Educational Services: Requirements and Best Practices. Protecting Student Privacy. Retrieved July 15, 2021, from https://studentprivacy.ed.gov/resources/protecting-student-privacy-while-using-online-educational-services-requirements-and-best

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