Boulder Valley takes methodical approach to student data privacy


About a year ago, officials at the Boulder Valley School District in Colorado were gearing up to pursue the Consortium for School Networking’s Trusted Learning Environment (TLE) seal, a mark of distinction that requires schools to have deployed student data privacy protections that meet a set of high standards developed by CoSN.

But meeting the TLE requirements is a demanding process, and Boulder Valley School District (BVSD) officials decided at the time that they just weren’t ready yet.

“The seal is not an easy thing to obtain,” said Andrew Moore, chief information officer for BVSD, a school district that comprises 55 schools and 31,000 students. “We tried to be ready to go last year but I put the brakes on because some of our policies — primarily in the security space, less in data privacy — were not where we needed them to be. So I said, ‘No need to try to kill ourselves to get this done. Let’s pull back and take the next year and do it right.’”

Moore then rallied his team to meet TLE’s high bar of requirements, and BVSD this month became the 13th school district nationwide to earn the seal. CoSN officials were especially impressed with the district’s “methodical” approach to student data privacy and meeting the requirements for earning the seal, according to Linnette Attai, director of the TLE program.

“One of the things we really noticed about Boulder Valley was how thoughtful they were about the program they’re building around data privacy and security governance,” she told EdScoop. “They paid a lot of attention to the various moving parts of privacy and security, putting policies in place and building transparency around those policies.”

Having the TLE seal gives BVSD, and other school districts that have received the designation, a signboard that officially confirms their commitment to student data privacy.

“The TLE seal helps with understanding that the steps we’ve taken to ensure student data are well thought out and have been implemented in a meaningful way,” Moore said.

Read more about Boulder Valley’s IT initiatives and its move to the cloud.

It is especially important that parents of students in the district know that the district has adopted policies and procedures to ensure that their children’s data is systematically protected, Moore told EdScoop.

“As a school district, we get questions from parents [about data privacy and security], so having the TLE seal and going through the arduous process to get it will help many parents understand that we are doing what we can at BVSD to ensure that data is protected,” he said.

However, the TLE process doesn’t end with earning the seal. As a seal recipient, Boulder Valley will be required to maintain its strong commitment to digital privacy and reapply for the seal every two years.

Boulder Valley received the seal for demonstrating effective student data privacy in five crucial areas:

  • Leadership: Managing and collaborating with stakeholders regarding the use and governance of student data to inform instruction.
  • Business: Establishing acquisition vetting processes and contracts that, at minimum, address applicable compliance with laws while supporting innovation.
  • Data security: Performing regular audits of data privacy and security practices and publicly detailing these measures.
  • Professional development: Requiring school staff to conduct privacy and security training and offering related resources to all stakeholders in the community.
  • Classroom: Implementing educational procedures and processes to ensure transparency while advancing curricular goals.

Attai said that CoSN was especially impressed with BVSD’s approach to employee training.

“I think they’re doing a really robust job on something that’s often overlooked — employee training on privacy,” she said. “It can be very challenging for a lot of districts to implement, but [BVSD officials] are being very comprehensive about their training program — implementing training in different ways, producing policy materials to keep people engaged and bringing in a variety of sources to craft their training.”

BVSD is planning to incorporate formal parental training on privacy into its program, Moore said. “We’ll be doing a pilot program this September with a group of about 30 parents,” he said.

Moore offered several tips for other school districts that decide to undertake the process of earning the TLE seal.

“Read through the materials before you get started and utilize CoSN resources that can help you understand what it means to get TLE-certified,” he said. “And reach out to those of us who went through the TLE process and learn from what we had to do to get through it.”