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CAR Created Videos
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CAR Created Resources for Schools
Contact Tracing "Lite"
Contact Tracing "Lite"
School health and safety might involve Contact Tracing by the Arizona Department of Health Services and/or Maricopa County Health Department. Should PV help facilitate said investigations, there are distinct guidelines related to FERPA, the Safety or Health Emergency Exception and student data privacy that should be understood and followed. CAR has researched these guidelines, abstracted the regulatory guidelines and applied our knowledge of Contact Tracing to produce this guidance, termed "Contact Tracing Lite".
School health and safety might involve Contact Tracing by the Arizona Department of Health Services and/or Maricopa County Health Department. Should PV help facilitate said investigations, there are distinct guidelines related to FERPA, the Safety or Health Emergency Exception and student data privacy that should be understood and followed. CAR has researched these guidelines, abstracted the regulatory guidelines and applied our knowledge of Contact Tracing to produce this guidance, termed "Contact Tracing Lite".
Isolation-"Condition in which a case is separated from others. Isolation occurs under conditions (for example, having a private bedroom and bathroom) that will prevent or limit the transmission of an infectious agent to those who are susceptible. Cases should be isolated for the entirety of their infectious period,"(John Hopkins University and Emily Gurley)
Quarantine-"Condition in which a contact’s activities are restricted. The contact is separated from others to prevent onward disease transmission to those who are susceptible. Contacts should be quarantined for the duration of their incubation period,"(John Hopkins University and Emily Gurley)
Contact Tracing- "the practice of identifying and monitoring individuals who may have had contact with an infectious person as a means of controlling the spread of a communicable disease,"(Merriam Webster's Dictionary)
Implications for School Health/Safety and Student Privacy
Implications for School Health/Safety and Student Privacy
Purpose
Purpose
The purpose of this document is to assist school officials in protecting student privacy in the context of COVID-19 as they consider the disclosure of personally identifiable information (PII) from student education records to individuals and entities who may not already have access to that information. PVSchools should work with the Arizona Department of Health Services and the Maricopa County Department of Public Health, while following guidelines from the Centers for Disease Control and Prevention in addressing this global pandemic. Understanding how, what, and when student information can be shared is a critical part of preparedness and in complying with FERPA (Family Educational and Privacy Act).
What is PII
What is PII
The term “PII” refers to a student’s name or identification number, as well as other information that can be used to distinguish or trace an individual’s identity either directly or indirectly through linkages with other information. 34 C.F.R. § 99.3, “Personally identifiable information.”
Why "Lite"
Why "Lite"
Formal Contact Tracing is a very specific, detailed and laborious process of investigation and reporting. In the context of this pandemic, Contact Tracing should only be performed by qualified and authorized providers, here Arizona Department of Health Services and Maricopa County Department of Public Health. However, schools can have a fiduciary responsibility to aid Contact Tracing via a "Lite" concept, balancing individual student privacy rights with the public's need to know. In a pandemic, speed is of essence in contacting, identifying, and isolating to containing potential outbreaks. In that light, arguments are provided for PV Schools to consider informally adopting a concept of Contact Tracing "Lite", being cognizant of public health and student privacy.
Recommendations
Recommendations
PV should consider obtaining parental permission before on premise school starts, should options for emergency notification of student name, phone, address and health information become necessary to public health officials, other parents, and select PV employees.
PV should consider consistent "assigned seating" for on premise students should facilitation of efficient/effective Contact Tracing become necessary.
PV should consider establishing contact relationship and communication protocola with ADHS/MCDPH before on premise school starts.
PV should consider establishing and articulating Contact Tracing "Lite" protocols to site leadership before on premise school starts; who, what, when, where, how and why, including adherence to student privacy safeguards.
PV should consider establishing criteria for classroom, grade and/or school closure(s), before on premise school starts.
Critical References
Critical References
U.S. Department of Education: Student Privacy Policy Office, "FERPA and Coronavirus Disease, 2009 (COVID-19), Frequently Asked Questions (FAWs), March, 2020" "FERPA and Coronavirus Disease 2019, (COVID-19) Frequently Asked Questions (FAQs)", March 2020
Centers for Disease Control and Prevention (CDC), "Interim Considerations for K-12 School Administrators for SARS-CoV-2 Testing", June 30, 2020
COVID -19 Contact Tracing, Johns Hopkins University, Coursera, 2020
PV Nurses - Consultation and Mentoring to WIT/CAR
Follow FERPA Health or Safety Emergency Exception
Follow FERPA Health or Safety Emergency Exception
FERPA prohibits educational agencies (e.g., school districts) and institutions (i.e., schools) from disclosing PII from students’ education record without the prior written consent of a parent or “eligible student,” unless an exception to FERPA’s general consent rule applies. 20 U.S.C. §§1232g(b)(1) and (b)(2); 34 C.F.R. §§ 99.30 and 99.31. For instance, pursuant to one such exception, the "health or safety emergency exception"; educational agencies and institutions may disclose to a public health agency PII from student education records, without prior written consent in connection with an emergency if the public health agency’s knowledge of the information is necessary to protect the health or safety of students or other individuals. 20 U.S.C. § 1232g(b)(1)(I); 34 C.F.R. §§ 99.31(a)(10) and 99.36.
1) Should we have parent permission before disclosing?
1) Should we have parent permission before disclosing?
"...educational agencies and institutions should prepare consent forms for parents and eligible students to sign to allow the potential sharing of this type of information if they create, or intend to create, a tracking or monitoring system to identify an outbreak before an emergency is recognized."
2) Schools can disclose PII to appropriate parties, but document...
2) Schools can disclose PII to appropriate parties, but document...
"If the educational agency or institution determines that there is an articulable and significant threat to the health or safety of the student or another individual and that certain parties need the PII from education records, to protect the health or safety of the student or another individual, it may disclose that information to such parties without consent." Appropriate parties are typically; "law enforcement officials, public health officials, trained medical personnel, and parents" (of sick student). "The record of each request for access to and each disclosure of PII from student education records must be maintained with the education records of each student as long as the records are maintained."
3) Can schools disclose PII of one student to the parents of another student?
3) Can schools disclose PII of one student to the parents of another student?
"There may be a rare situation during a health or safety emergency, however, in which schools may determine (in conjunction with health, law enforcement, or other such officials) that parents of students or eligible students are appropriate parties to whom to disclose identifiable information about a student with COVID-19. For example, school officials may determine that it is appropriate to disclose identifiable information about of a student with COVID-19 to parents of other students if parents need to know this information to take appropriate action to protect the health or safety of their children.
4) How do we disclose a COVID-19 student illness(es)?
4) How do we disclose a COVID-19 student illness(es)?
You can disclose the sickness in general, but not disclose PII about any particular student. "...we caution educational agencies or institutions to ensure that in releasing such facts, they do so in a manner that does not disclose other information that, alone or in combination, would allow a reasonable person in the school community to identify the students who are absent due to COVID-19 with reasonable certainty." Email and flyers/posters at drop off and egress locations are adequate notifications.
5) Can schools disclose student PII to the media?
5) Can schools disclose student PII to the media?
No!!!.
6) Nothing in FERPA prevents notifying students/parents about a teacher/employee sickness at school, but....follow HR guidelines as other rules/regulations may apply.
6) Nothing in FERPA prevents notifying students/parents about a teacher/employee sickness at school, but....follow HR guidelines as other rules/regulations may apply.
Vaccinations Outreach
Vaccinations Outreach
CAR created resources for schools, homes and communities.
CAR created resources for schools, homes and communities.
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