Flexibility on SLDS Funding Can Help Ensure Student Data Privacy

April 21, 2016

CC: Chairman Cole, Ranking Member DeLauro, Chairman Blunt, Ranking Member Murray

Dear Senator Cochran, Senator Mikulski, Representative Rogers, and Representative Lowey:

Ensuring students’ privacy and confidentiality at school is a priority for families across the United States. Responding to community concerns, many States and school districts took steps to better protect student data, while also promoting greater public understanding about how schools use data to promote student success and continually improve educational policy and practice. These developments vastly improved school systems’ abilities to ensure personally identifiable student data are secure and used for only educationally legitimate purposes.

Our organizations collectively work to promote effective education data use and protect student privacy. Through this work, we observed an important challenge facing States that, if addressed, could help facilitate the privacy policy improvements described above by ensuring they are well implemented. Many States now recognize the importance of designating an official or senior staff person to oversee implementation of student data privacy policies. Unfortunately, filling such positions with well-qualified privacy professionals can be very difficult because of significant salary disparities between public and private privacy positions. As a result, states are often left without a single dedicated position devoted to leading the state’s education data privacy efforts.

Congress could help address this need, by permitting States that require assistance to use existing funding within the State Longitudinal Data Systems program for hiring a student data privacy professional. We strongly support the program’s current set aside for “data coordination, quality, and use…” but believe it would be strengthened by adding “privacy protection” among these enumerated activities. This new use would be optional and permit States to continue allocating the funds to other existing purposes, but would also help jurisdictions that require additional support to higher the top-notch privacy leadership required to implement and support privacy protections for students and their families.

Thank you for considering our request. We appreciate your leadership for the nation’s schools and look forward to answering any questions you or your staff might have about this issue.

Sincerely,
Paige Kowalski
Vice President, Policy and Advocacy Data Quality Campaign

With support from:

• Access 4 Learning (A4L) Community (previously the SIF Association)
• Alliance For Excellent Education
• American Association of Colleges for Teacher Education (AACTE)
• CoSN – the Consortium for School Networking
• Council of Chief State School Officers (CCSSO)
• Educators 4 Excellence (E4E)
• Foundation for Excellence in Education
• Future of Privacy Forum
• iKeepSafe
• Institute for Higher Education Policy (IHEP)
• International Association for K-12 Online Learning (iNacol)
• International Society for Technology in Education (ISTE)
• National Association of Elementary School Principals (NAESP)
• National Association of Secondary School Principals (NASSP)
• National Association of State Boards of Education (NASBE)
• National PTA
• National Student Clearinghouse
• The State Educational Technology Directors Association (SETDA)
• The State Higher Education Executive Officers (SHEEO)
• StriveTogether
• StudentsFirst