Beyond the laws: Building a student data privacy compliance program


Protecting the privacy of student data is a critical responsibility for every school system. However, building a data privacy compliance program is a significant undertaking, encompassing every corner of the organization. It takes time, effort, knowledge and persistence to do it right, but even after putting in the energy and effort, some still don’t see the desired results. How do you build a culture of compliance in your organization and bring the program to life so that it becomes part of the fabric of the school system operations?

To be successful, start by stripping away the complexity and rallying around your existing school system mission.

The laws certainly create a compelling reason to get started with a compliance program. They are complex, and the penalties for noncompliance are high. We also don’t need to look any further than the daily headlines to see that data security incidents are a very real danger, with repercussions that include legal, financial and reputational harm.

However, while taking a hard look at risks and repercussions can motivate us to build or improve a compliance program, that type of motivation wanes over time. It’s also not exactly great subject matter for inspirational speeches to the team. It’s challenging to energize around a “follow the rules” framework, and in an effort to consistently reduce risk, many school district CTOs find themselves in the unenviable and unpopular position of being the ever-present messenger of potential doom and gloom throughout the school system.

The first step in changing that conversation and creating the proper framework for a data privacy compliance program is to understand that in the modern classroom, the required standard of care that school systems have for their students extends to protecting student data.

Parents drop their children off at school every day with a trust and belief that the school system is doing right by their children. Establishing and maintaining that trust requires that employees embrace a high standard of care surrounding their collection, use, handling and sharing of student data, just as they do in their other dealings with students.

Next, consider how that standard of care comes to life within your school system. What is the ethical, mission-driven backbone that inspires teams to attend to their responsibilities day in and day out? Take your school system mission statement, and consider:

  • In what ways does our collection, use and sharing of student data help us fulfill our mission?
  • How does our data protection program reflect our commitment to our mission?
  • How will our mission inform our use and protection of student data in the future?

The answers become the building blocks for the charter policies in a successful compliance program. They combine to form the positive and inspiring lens through which all employees can understand the larger meaning in data privacy compliance requirements.

On top of that, you need to build the policies and procedures that inform compliance with the laws and district requirements, but be sure you can tie each policy back to the mission. That is what drives meaning, which in turn helps inform consistent and compliant decisions about data.

Building a program in this manner gives everyone in the school system a framework they can understand and rally around when implementing the policies and procedures you’ll put in place. The “why” comes to life in a way that speaks to not only the laws, but also the community in which you operate and the vision employees bring to their work every day.

It turns compliance from “what we can’t do with data” to “what we should do to protect our students.” That is a much more positive rallying cry for any school system leader to work with.

Linnette Attai is the founder of PlayWell, LLC, through which she advises private and public companies, schools and districts, trade organizations, lawmakers and policy influencers. Attai has been helping clients navigate data privacy matters for over 25 years. She is the author of “Student Data Privacy: Building a School Compliance Program.”