EGUSD Approval Process
The approval process for ensuring student data privacy begins with you and applies to BOTH free and fee-based online learning supplemental materials.
Before purchasing or downloading online learning supplemental resources for your classroom or department, please follow the steps below to initiate the EGUSD California AB 1584 compliance review process.
Step 1: Check The List
Check our EGUSD California AB 1584 Agreements Rider/List - If your software/service is not on the list or it is highlighted in yellow, proceed to Step 2. If your software/service has already been vetted and marked with appropriate approval, you may proceed with your purchase or download.
Step 2: Evaluate Privacy Policy
Evaluate the software/service to determine what their privacy policy is to the best of your ability. This would include visiting the privacy policy statement and terms of service/use of their company website or calling the company/vendor/service directly. If you feel that this is an appropriate supplemental instructional material, which is directly related to the course and is age appropriate, proceed to Step 3 to submit a Student Data Privacy Compliance Review Form for Online Learning Resources.
Step 3: Fill Out & Submit Compliance Form
Fill out the Student Data Privacy Compliance Review Form for Online Learning Resources and submit. Technology Services will make the final determination concerning whether the product or service is complaint with EGUSD District Policy (Board Policy 6161.11 and Administrative Regulation 6161.) and CA AB 1584. Please allow up to four weeks for this process - as in some cases vendors will need to sign and submit an agreement with EGUSD if language is not already included in their contract.
Student Data Privacy Compliance Review Form - Online Learning Resources (Note: This form is restricted to EGUSD staff only)
Where do I look for privacy POLICY information?
Visit the official company/product/service website. Typically, you will need to scroll to the bottom of the website (footer area) to locate links to a company's Privacy Policy. In the example below, we are using ESGI, a company that makes their privacy policy very clear. If you click on their Privacy Policy link, you will see that student data is addressed in multiple instances through FERPA and CA AB 1584. In other cases some companies might also include this type of information on their Terms of Use/Terms of Service pages.
After clicking on ESGI's Privacy Policy link, if you scroll down the privacy policy page, you will see that they clearly address CA AB 1584 - which makes it simple for you to evaluate. It will not always be this easy, you may need to contact the company directly through support, email or a phone call.
Be on the lookout for:
A statement that pupil records continue to be the property of and under the control of the school district
A description of the means by which pupils may retain possession and control of their own pupil-generated content, if applicable, including options by which a pupil may transfer pupil-generated content to a personal account
A prohibition against the third party using any information in the pupil record for any purpose other than those required or specifically permitted by the contract
A description of the procedures by which a parent, legal guardian, or eligible pupil may review personally identifiable information in the pupil's records and correct erroneous information
A description of the actions the third party will take—including the designation and training of responsible individuals—to ensure the security and confidentiality of pupil records
A description of the procedures for notifying the affected parent, legal guardian, or eligible pupil in the event of an unauthorized disclosure of the pupil's records
A certification that a pupil's records shall not be retained or available to the third party upon completion of the terms of the contract and a description of how that certification will be enforced (NOTE: This requirement does not apply to pupil-generated content if the pupil chooses to establish or maintain an account with the third party for the purpose of storing that content, either by retaining possession and control of their own pupil-generated content, or by transferring pupil-generated content to a personal account.)
A description of how the district and the third party will jointly ensure compliance with the federal Family Educational Rights and Privacy Act (FERPA)
A prohibition against the third party using personally identifiable information in pupil records to engage in targeted advertising.
Source: California Educational Technology Professionals Association (CETPA)
Google Search
Another way to search for a company's privacy policy is to enter the name of the product combined with privacy policy into Google's search field. This could eliminate the need to navigate to the link on the homepage of the company website.
Note: Some national companies might call out FERPA and COPPA in their privacy policies, but not list individual state laws such as CA AB 1584.
Common Sense Media - Evaluation Tool
As part of the Common Sense Privacy Evaluation Initiative, privacy evaluations break down complex privacy policies to help you make informed choices to protect student information online. As you can see in the examples below, ABCmouse.com is marked as "Use Responsibly, whereas ABCya is warning to "Use with Caution" - the reason behind the rating is listed below each evaluation, and includes a link to view the full evaluation.
If using the Common Sense Evaluation Tool, be sure to click on the "See full evaluation" link to see when Common Sense last updated their rating as the company may have more recently updated their policy.
Questions?
Are you an EGUSD employee with a question about the EGUSD approval process? If yes, all questions can be directed to the Technology Services Help Desk. Email: helpdesk@egusd.net