SOUTH LEWIS CENTRAL SCHOOLS
Parents’ Bill of Rights for Data Privacy and Security
In accord with Education Law §2-d and the Family Educational Rights and Privacy Act (“FERPA”), the District hereby establishes and adopts the following Parents’ Bill of Rights for Data Privacy and Security:
- A student’s personally identifiable information (PII) cannot be sold or released by the District for any commercial or marketing purposes.
- Parents have the right to inspect and review the complete contents of their child's education record including any student data stored or maintained by the District. This right of inspection is consistent with the requirements of the Family Educational Rights and Privacy Act (FERPA) and Board Policy. In addition to the right of inspection of the student’s educational record, Education Law §2-d provides a specific right for parents to inspect or receive copies of any data in the student’s educational record.
- State and federal laws protect the confidentiality of PII, and safeguards associated with industry standards and best practices, including, but not limited to, encryption, firewalls, and password protection, must be in place when data is stored or transferred. The District is committed to implementing the aforementioned safeguards and adopting industry standards and best practices to insure the safety of the data it collects.
- The rights of parents and students under FERPA can be accessed at http://www2.ed.gov/policy/gen/guid/fpco/ferpa/lea-... In addition to review, these rights include how to challenge the accuracy of the content of a student’s educational record.
- A complete list of all student data elements collected by the State is available for public review at http://www.nysed.gov/data-privacy-security/student... or parents may obtain a copy of this list by writing to the Office of Information & Reporting Services, New York State Education Department, Room 865 EBA, 89 Washington Avenue, Albany, NY 12234.
- Parents have the right to file complaints with the District or with NYSED about possible privacy breaches of student data by the District’s third-party contractors or their employees, officers, or assignees.
Complaints regarding student data breaches filed with the District should be directed to Deborah J. Domagala, District Data Protection Officer, South Lewis Central School District, 4264 East Road, Turin, NY 13473, 315-348-2500. The District has established the following procedures for parents, eligible students, teachers, principals, and other District staff to file complaints with the District about breaches or unauthorized releases of student data and/or teacher or principal data:
- a) All complaints must be submitted to the District's Data Protection Officer in writing.
- b) Upon receipt of a complaint, the District will promptly acknowledge receipt of the complaint, commence an investigation, and take the necessary precautions to protect PII.
- c) Following the investigation of a submitted complaint, the District will provide the individual who filed the complaint with its findings. This will be completed within a reasonable period of time, but no more than 60 calendar days from the receipt of the complaint by the District.
- d) If the District requires additional time, or where the response may compromise security or impede a law enforcement investigation, the District will provide the individual who filed the complaint with a written explanation that includes the approximate date when the District anticipates that it will respond to the complaint.
- e) The District will maintain a record of all complaints of breaches or unauthorized releases of student data and their disposition in accordance with applicable data retention policies, including the Records Retention and Disposition Schedule ED-1 (1988; rev. 2004).
Complaints to NYSED should be directed in writing to Privacy Complaint, Chief Privacy Officer, New York State Education Department, 89 Washington Avenue, Albany NY 12234. Complaints may also be submitted using the form available at the following website http://www.nysed.gov/data-privacy-security/report-...
For purposes of further ensuring confidentiality and security of student data, as well as the security of personally-identifiable teacher or principal data, this Parents’ Bill of Rights and the following supplemental information shall be included in each contract that the District enters into with a third-party contractor with access to this information:
a) the exclusive purposes for which the student data or teacher or principal data will be used by the third-party contractor, as defined in the contract;
b) how the third-party contractor will ensure that the subcontractors, or other authorized persons or entities to whom the third-party contractor will disclose the student data or teacher or principal data, if any, will abide by all applicable data protection and security requirements, including but not limited to those outlined in applicable laws and regulations (e.g., FERPA; Education Law Section 2-d);
c) the duration of the contract, including the contract's expiration date, and a description of what will happen to the student data or teacher or principal data upon expiration of the contract or other written agreement (e.g., whether, when, and in what format it will be returned to the District, and/or whether, when, and how the data will be destroyed);
d) if and how a parent, student, eligible student, teacher, or principal may challenge the accuracy of the student data or teacher or principal data that is collected;
e) where the student data or teacher or principal data will be stored, described in a manner as to protect data security, and the security protections taken to ensure the data will be protected and data privacy and security risks mitigated; and
f) address how the data will be protected using encryption while in motion and at rest.
- A parent, student, eligible student, teacher or principal may challenge the accuracy of the student’s data or principal or teacher data collected by the District by filing a written request with the Superintendent of Schools at the address noted above.
- Where applicable... The District has entered into contracts with certain third party contractors who have been provided data regarding students, teachers, and/or principals. The information mandated by law about such contractors appears in an attachment to this Parents Bill of Rights.
- This Bill of Rights is subject to change based on Regulations to be promulgated by the Commissioner of Education and/or the State Education Department’s Chief Privacy Officer.
The South Lewis Central School District maintains an inventory of all software and services utilized within the district that collect, store, or process student information. In order to make this information as easily accessible as possible to our community and comply with requirements outlined in law and regulation, we have posted our inventory and supplemental information related to the contracts for those products and services on our website. We will update the inventory periodically to reflect any changes in product or service usage. The information can be accessed at:
If you would like more information, please contact: Douglas Premo, Superintendent of Schools, South Lewis Central School District, 4264 East Road, Turin, NY 13473, 315-348- 2500, firstname.lastname@example.org.
Ref: Education Law §2-d 20 U.S.C. §1232 g