Is Google violating privacy laws in its use of K-12 student data?

Originally published by Peter S. Vogel.

A recent letter sent to Google from a US Senator expressed concern about the “extent to which Google may be collecting K-12 students’ personal data and using that information for non-educational purposes without parents’ knowledge or consent.”  On January 13, 2016 Senator Al Franken sent a letter to Sundar Pichai (Google CEO) about Google’s foray into education technology (EdTech) which included these statements:

Given the sensitive nature of student data, all parties involved, including the school administrators, teachers, parents, and the students, should have a clear understanding about what data are shared by schools with EdTech vendors, what data are collected by those vendors, how long the data are stored, and how they use the data.

Students and their families should be empowered to make informed decisions about whether and with whom they share such sensitive information, and they must be assured that when the information is retained it will receive the utmost protection.

He went on to ask that Google respond to these questions by February 12:

When a student is signed in to their GAFE account but is not using one of the GAFE services, what kind of data does Google collect on an individual student?

When a student is using a Chromebook but is not using one of the GAFE services, what kind of data does Google collect on an individual student?

If Google does collect any individualized data on a student, such as browsing information or viewing habits, when a student is using a Chromebook or is logged in to their GAFE account but is not using one of GAFE services, please address the following questions:

a. For what purposes does Google collect this information?

b. s it necessary to collect all of this information for the provision of GAFE services or to deliver other valuable features that may be relevant for educational purposes?

c. Has Google ever used this kind of data to target ads to students in Google services, either in the GAFE services or other Google services, such as Google Search, Google News, Google Books, Google Maps, Blogger, or YouTube?

d. Has Google ever used this kind of data for its own business purposes, unrelated to the provision of Google’s educational offerings?

e. Is it possible to make this data collection opt-in?

f. Does Google share this information with additional parties?

Google has indicated that it compiles data aggregated from student users of Chrome Sync, anonymizes the data, and uses it to improve its services. Can you expand on how the aggregated information is treated? For example, does this include sharing the aggregated data with third parties for research purposes or otherwise?

Can you describe Google’s relationship with school districts and administrators that choose to use Google for Education products and services? Apart from publicly available privacy policies, does Google offer any explanation to parents, teachers, and education officials about how student information is collected and used? 

Can you describe all the contexts and ways in which both school administrators and parents of students using Google for Education products and services have control over what data is being collected and how the data are being used?

It will be interesting to see how Google responds.

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