FERPA
Student Privacy
setup.slidesyearbook.com/ferpa
In all the excitement of student photos and memories, student privacy may fade into the background. At least temporarily. As educators, we educate and protect students.
G Suite for Education (formerly called Google Apps for Education) provides free services for schools without advertising or data collection for core apps. Google’s Privacy and Security article states that these apps include Gmail, Calendar, Classroom, Contacts, Drive, Docs, Forms, Groups, Sheets, Sites, Slides, Talk/Hangouts and Vault.
Did you notice that Google Photos is not listed as a core service? According to the same Privacy and Security article, “These [non-core] services are not governed by the Student Privacy Pledge or the G Suite agreement, so we may use information in these services in ways we would not for G Suite Core Services.” For example, services may have ads, but no student information is used to target students. To learn more, please read G Suite for Education Core and Additional services.
Google reassures the public that “Schools can use G Suite core services in compliance with COPPA and FERPA. G Suite core services contain no advertising and do not use information in those services for advertising purposes.”
Why is this important? Student records are protected under the Family Educational Rights and Privacy Act, also known as FERPA (20 U.S.C. § 1232g; 34 CFR Part 99). FERPA differentiates between student records and directory information. Student records are private and directory information, depending on the situation, can be public. However, even directory information can be withheld per parent request. According to the U.S. Department of Education, all schools must tell parents about the directory information on an annual basis. How the notification is handled is determined by the school. Schools have the ability to classify what is a record and what is a directory.
My district’s school board policy (BCSD Board Policy 0604.10) defines Directory information as “information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed” (emphasis added). The definition continues with a list of examples of student information. Yearbooks published within or outside of the district is number 12 on that list.
Each year our parents/guardians sign a Student Handbook that includes a Photo/Video Release form. Legally, this form only needs to be completed once a year; however, for events that are publicized, departments may ask for a second form to be completed as a reminder, “Hey, we are proud of your student’s work and would like to publicize her/his achievement.” Rarely do parents sign no because they seem to like us bragging about their kids.
That last sentence reinforces the appropriateness of the photograph or video. Any inappropriate picture must be removed. The importance of a positive digital footprint must be instilled in all parties involved - administrators, teachers, students and parents.
With this information in mind, you must decide how to properly store student yearbook photos. G Suite has three options - Google Photos, Google Drive or a combination of Photos, Drive and Classroom. I will explain the benefits and disadvantages of the first two. Then I urge you to have discussions with your students, administrators and parents to determine the best photo storage for your school. Please note that as of August 1, 2017, non-core apps like Google Photos will be turned off. Please talk to your district school domain administrator to have it manually turned on.
Google
Photos
Advantages
- Upload photos from a phone (automatically) or a computer.
- Edit Photos using color filters, basic adjustments and cropping. Save the new version as a copy and/or copy edits.
- Add photo descriptions and use facial recognition to find more pictures of the same person.
- Share Photo Album links with students via Google Classroom to save time.
Disadvantages
The first disadvantage of Google Photos is not a core service. Core services are in compliance with COPPA and FERPA. Because of this, ads will appear; however, student data will not be used to target those ads. Secondly, sharing is either turned on or off. The owner of the photo cannot prevent editors from downloading or resharing the image. Lastly, students must review the photos and add them to their library to insert them in a Google Slide or drag and drop them into Google Slides.
Google
Drive
Advantages
- Upload from phone (manually) or computer
- Can Prevent editors from changing access and adding new people to all items in the folder
- Can Disable options to download, print, and copy for commenters and viewers for individual photos
- Once students open the shared folder, they can insert images into Google Slides.
- Google Drive Is Scary-Smart at Searching Your Images
- How Google Drive works with Google Photos
Disadvantages
Unfortunately, work, school or other group accounts do not have the option to View & edit photos stored in Google Drive using Google Photos. Only limited Image editing options such as recoloring, filtering, cropping with specific sizes and masking exist in Drive. Furthermore, while it is possible to search images in Drive for object names such as red hat or water, there is no facial recognition option.
Conclusion
As is discussed in the post called Storing Images: Organization Structure for Images, the ideal solution is to demand that G Suite for Education make Google Photos a Core Service with school-level sharing permissions and no ads. This would calm the worries of yearbook advisors and admin who do worry about student privacy.
Make sure to discuss the advantages and disadvantages with your students and admin to determine which online yearbook image sharing is best for you. Talk to parents. Remember our job is to educate and protect students.
Published June 28, 2017.
Updated July 21, 2017.