The West Irondequoit Central School District is committed to protecting the privacy and security of student data and teacher and principal data. In accordance with New York Education Law Section 2-d and its implementing regulations, the District informs the school community that parents and eligible students1 can expect the following:
1. A student's personally identifiable information (PII)2 cannot be sold or released for any commercial purpose.
2. The right to inspect and review the complete contents of their student's education record stored or maintained by an educational agency.
3. State and federal laws,3 such as NYS Education Law §2-d and the Family Educational Rights and Privacy Act, that protect the confidentiality of a student’s 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.
4. A complete list of all student data elements collected by NYSED is available for public review at www.nysed.gov/data-privacy-security, and by writing to: Chief Privacy Officer, New York State Education Department, 89 Washington Avenue, Albany, NY 12234.
5. The right to have complaints about possible breaches and unauthorized disclosures of student data addressed. Complaints may be submitted to NYSED online at www.nysed.gov/data-privacy-security, by mail to: Chief Privacy Officer, New York State Education Department, 89 Washington Avenue, Albany, New York 12234, by e-mail to firstname.lastname@example.org, or by telephone at 518-474-0937.
6. To be notified in accordance with applicable laws and regulations if a breach or unauthorized release of their student’s PII occurs.
7. Educational agency workers that handle PII will receive training on applicable state and federal laws, the educational agency’s policies, and safeguards associated with industry standards and best practices that protect PII.
8. Educational agency contracts with vendors that receive PII will address statutory and regulatory data privacy and security requirements.
1 “Parent” means a parent, legal guardian, or person in parental relation to a student. These rights may not apply to parents of eligible students defined as a student eighteen years or old. “Eligible Student” means a student 18 years and older.
2 “Personally identifiable information,” as applied to student data, means personally identifiable information as defined in section 99.3 of title thirty-four of the code of federal regulations implementing the family educational rights and privacy act, section twelve hundred thirty-two-g of title twenty of the United States code, and, as applied to teacher or principal data, means “personally identifying information” as such term is used in subdivision ten of section three thousand twelve-c of this chapter.
3 Information about other state and federal laws that protect student data such as the Children’s Online Privacy Protection Act, the Protection of Pupil Rights Amendment, and NY’s Personal Privacy Protection Law can be found at www.nysed.gov/data-privacy-security.
Supplemental Information Regarding Third-Party Contractors
In the course of complying with its obligations under the law and providing educational services to District residents, the Wests Irondequoit Central School District has entered into agreements with certain third-party contractors. Pursuant to these agreements, third-party contractors may have access to "student data" and/or "teacher or principal data," as those terms are defined by law and regulation.
For each contract or other written agreement that the District enters into with a third-party contractor where the third-party contractor receives student data or teacher or principal data from the District, the following supplemental information will be included with this Bill of Rights:
1. 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;
2. 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);
3. 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);
4. 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;
5. 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
6. Address how the data will be protected using encryption while in motion and at rest.
This Bill of Rights is subject to change based on regulations of the Commissioner of Education and the NYSED Chief Privacy Officer. Changes/Additions are also anticipated as NYSED releases further guidance documents.
Supplemental information describing third-party vendors engaged in data sharing and confidentiality agreements with West Irondequoit Central School District can be found at: https://dpit.riconedpss.org/billofrights/02d9d2af98c045c501f3.
Current Revision: 06-12-20
Previously Revised: 01-09-15, 10-02-15, 11-01-17, 02-01-19, 02-18-20, 05-19-20