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Strategic Objective
Privacy
Strategic Objective
Progress Update
Educational institutions rely on student data to improve decision-making, to personalize learning, and to target additional support to at-risk students, and the Department itself relies on student data for key administration initiatives. Increases in the collection and use of student data, however, have fueled public concern about student privacy, and important gains are at risk due to public concern. Throughout FY 2015, student privacy was an extremely hot topic and as a result the Department had to begin, to some degree, pulling away from our long term improvement plans to respond to immediate Family Educational Rights and Privacy Act (FERPA) and privacy issues providing substantial, recurring technical assistance to the Hill on dozens of proposed bills dealing with student privacy. In addition, the Department responded to public and congressional criticism over the privacy of students’ medical treatment records in the wake of a recent sexual assault case by issuing a draft Dear Colleague letter on the protection of student privacy in campus medical records. The Department was publicly commended for publishing the letter in draft format, to obtain public input before finalizing it in FY 2016.
While adjusting to these changing demands, there has been consistent, steady improvement in office metrics specific to privacy since we began tracking these numbers about two years ago. Our strategy has been to rely when appropriate on contractor resources, both within the office and from the contractors that staff the PTAC. These efforts in addressing the high degree of public interest in student privacy included the implementation of a new more user-friendly website, and the release of our Model Terms of Service guidance and teacher training video. Another strategy that continues to pay off is increased coordination with other Department offices engaged in privacy technical assistance as the Department expanded PTAC’s work to include early childhood programs, particularly through the creation of new online resource page that curates a vast array of technical assistance resources on the privacy and security of early childhood (EC) data from across the Department’s disparate EC technical assistance centers. Through PTAC and the Department’s Office of the Chief Privacy Officer (OCPO), the Department conducted a number of targeted technical assistance activities on early childhood issues, including a site visits, webinars, and workshops and provided extensive internal technical assistance on privacy issues relating to the Preschool Development Grants program. As a result of this focus on efficiencies and resource utilization, using metrics to improve performance and relying on a case tracking system that manages workload and content for both our contractor and federal staff, the average time to respond to cases was under 5 days, meeting the Department’s FY 2015 performance target of by having an average turnaround time of less than 8 days.