PRAIRIE ELEMENTARY SCHOOL DISTRICT
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Policies

Prairie Elementary School District No. 191


Student Data Privacy and Security

The efficient collection, analysis, and storage of student information are essential to improve the education of our 
students.  As the use of student data has increased and technology has advanced, the need to exercise care in the 
handling of confidential student information has intensified. The privacy of students and the use of confidential student 
information is protected by federal and state laws, including the Family Educational Rights and Privacy Act (FERPA) and 
the Idaho Student Data Accessibility, Transparency, and Accountability Act of 2014 ( Idaho Data Accountability Act).

Student information is compiled and used to evaluate and improve Idaho’s educational system and improve transitions 
from elementary school to high school, and from high school to postsecondary education or the workforce.  The Data 
Management Council (DMC) was established by the Idaho State Board of Education to make recommendations on the 
proper collection, protection, storage and use of confidential student information stored within the Statewide Longitudinal 
Data System (SLDS).  The DMC included representatives from K-12, high education institutions and the Department of 
Labor.

This policy is required by the Idaho Data Accountability Act.  In order to ensure the proper protection of confidential 
student information, the District shall adopt, implement and electronically post this policy.  It is intended to provide 
guidance regarding the collection, access, security, and use of education data to protect student privacy.  This policy is 
consistent with the DMC’s policies regarding the access, security, and use of data maintained with in the SLDS.  Violation 
of the Idaho Data Accountability Act may result in civil penalties.

Definitions

Administrative Security consists of policies, procedures, and personnel controls including security policies, training, and 
audits, technical training, supervision, separation of duties, rotation of duties, recruiting and termination procedures, 
user access control, background checks, performance evaluations, and disaster recovery, contingency, and emergency 
plans.  These measures ensure that authorized users know and understand how to properly use the system in order to 
maintain security of data.

Aggregate Data is collected or reported at a group, cohort or institutional level and does not contain PII.

Data Breach is the unauthorized acquisition of PII.

Logical Security consists of software safeguards for an organization’s systems, including user identification and 
password access, authenticating, access rights and authority levels.  These measures ensure that only authorized users 
are able to perform actions or access information in a network or workstation.

Personally Identifiable Information (PII) includes: a student’s name; the names of a student’s family; the student’s 
address; the student’s social security number; a students education unique identification number or biometric record; or 
other indirect identifiers such as a student’s date of birth, place of birth or mother’s maiden name; and other information 
that alone or in a combination is linked or linkable to a specific student that would allow a reasonable person in the 
school community who does not have personal knowledge of the relevant circumstances, to identify the student.

Physical Security describes security measured designed to deny unauthorized access to facilities or equipment.

Student Data means data collected at the student level and included in a student’s educational records.

Unauthorized Data Disclosure is the intentional or unintentional release of PII to an unauthorized person or un-trusted 
environment.


Collection

The District shall follow applicable state and federal laws related to student privacy in the collection of student data.

Access

Unless prohibited by law or court order, the District shall provide parents, legal guardians, or eligible students, as 
applicable, the ability to review their child’s educational records.

The Superintendent or designee, is responsible for granting, removing, and reviewing user access to student data.  An 
annual review of existing access shall be performed.

Access to PII maintained by the District shall be restricted to:
1.        The authorized staff of the District who require access to perform their assigned duties and,
2.        authorized employees of the State Board of Education and the State Department of Education who require 
access to perform their assigned duties; and,
3.        vendors who require access to perform their assigned duties.




Security

The District shall have in place Administrative Security, Physical Security, and Logical Security controls to protect from a 
Data Breach or Unauthorized data Disclosure.  The District shall immediately notify the Executive Director of the Idaho 
State Board of Education and the State Superintendent of Public Instruction in the case of a confirmed Data Breach or 
confirmed Unauthorized Data Disclosure.  The District shall also notify in a timely manner affected individuals, students, 
and families if there is a confirmed Data Breach or confirmed unauthorized data Disclosure.


Use

Publicly released reports shall not include PII and shall use Aggregate Data in such a manner that re-identification of 
individual students is not possible.

District contracts with outside vendors involving student data, which govern databases, online services, assessments, 
special education or instructional supports, shall include the following provisions which are intended to safeguard student 
privacy and the security of the data:
1.        Requirement that the vendor agree to comply with all applicable state and federal law;
2.        Requirement that the vendor have in place Administrative Security, Physical Security, and Logical Security 
controls to protect from a Data Breach or Unauthorized data Disclosure;
3.        Requirement that the vendor restrict access to PII to the authorized staff of the vendor who require such access 
to perform their assigned duties;
4.        Prohibition against the vendor’s secondary use of PII including sales, marketing or advertising;
5.        Requirement for data destruction and associated timeframe; and
6.        Penalties for non-compliance with the above provisions.

The District shall clearly define what date is determined to be directory information.

If the District choose to publish directory information which includes PII, parents or legal guardians must be notified 
annually in writing and given an opportunity to opt out of the directory.  If a parent/legal guardian does not opt out, the 
release of the information as part of the directory in not a Data Breach or Unauthorized Data Disclosure.


Legal Reference:        20U.S.C. § 1232g        Family Education Rights and Privacy Act
                    34 C.F.R. 99                Family Education Rights and Privacy Act
                    I.C. § 33-133                Idaho Student Data Accessibility,                                                                 
Transparency, and Accountability Act

Policy Adopted  12/02/2014
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