Serious concerns with DOE’s proposed weakening of their student privacy regulations & how you can help!

Oct. 21, 2024

Check out the letter here  and below, sent today on behalf of Class Size Matters and the Parent Coalition for Student Privacy to the DOE’s chief privacy officer Dennis Doyle, copied to the Chancellor and the members of the Panel for Educational Policy, about the unacceptable way the DOE now proposes to revise the Chancellor’s regulation A-820 that pertains  to student privacy.  This regulation hasn’t been updated since 2009, long before the state student privacy law Ed Law 2D was passed in 2014. The revisions to these regulations will be voted at the Panel for Education Policy meeting Wednesday, October 30, 2024, at 6:00pm EST at M.S. 131 at 100 Hester Street in Manhattan.  The proposed regulations are posted here.

Yet instead of strengthening student privacy protections, these proposals would significantly weaken them, by authorizing the DOE to share student names, email addresses, phone numbers, home addresses, as well as additional, unspecified personal  information with basically any individual, company, or organization they like, by classifying these data points as Directory Information.  If enacted, these provisions would put at serious risk the health and safety of NYC students, with only an unreliable parental opt out process to be offered to prevent this from occurring.

The proposed regulations are  contrary to the language and intent of Ed Law 2D, as well as state guidance, and the caution expressed on DOE’s own website, in which they point out how sharing “home addresses, telephone numbers, and dates of birth” are data points too “sensitive in nature” to be treated in such an unrestrained manner.  The proposed regs also unacceptably exempt certain student health records kept by schools from the privacy protections of federal student privacy law and Ed Law 2D. Finally, they omit any mention of the most rigorous data security provisions of Ed Law 2D, and thus invite even more data breaches.

Please send your own letter to the Chancellor, the DOE Chief Privacy Officer Dennis Doyle, and the members of the PEP today, to urge them to postpone the vote on these critical regulations until they have been thoroughly rewritten to better protect student privacy and safety, and until the DOE officials in charge have had the opportunity to meet with parents and privacy advocates to hear their concerns directly.

Please also sign up for our special privacy briefing this Wed. Oct. 23 at 7 PM, co-sponsored by AQE,  by registering here to learn more about the irresponsible ways in which DOE has been sharing sensitive student information, and consider attending the PEP meeting on Oct. 30 to speak out about the need for more rigorous data privacy practices and policies .

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