Government Policies for K–12 Data Governance
Washington, D.C.’s Office of the State Superintendent of Education breaks up its data governance policies, grouping them around responsibilities under federal privacy laws, student privacy and data suppression, educational workforce privacy and data suppression, data incident response, and secure data transfer. D.C.’s student privacy policy states that OSSE has a responsibility to suppress and remove information that could identify students.
Meanwhile, Washington State’s data governance policy states, “An effective data governance strategy clearly defines the roles, responsibilities, authority and associated activities of individuals and groups that come in contact with K–12 data.”
With this data governance document, Washington State aims to create a “culture of data quality” to integrate data use throughout the organization and ensure that proper data use and management are priorities.
At the Nebraska Department of Education, key governance activities include maintaining confidentiality of all school records, storing data securely, developing Memoranda of Understanding around data sharing and reviewing the MOUs quarterly.
Data Governance vs. Data Stewardship in Education
While data governance involves making rules about data, data stewardship involves defining and interpreting those rules and creating accountability for working with the data.
“Within K–12, a data owner would play a large role in establishing a data governance framework, and a data steward would be concerned with the day-to-day care and management of data assets,” Ibeck says.
Whenever an organization such as a school migrates data to a new environment like the cloud, that involves new governance rules and stewardship responsibilities, Thomas says.
DISCOVER: Ask these three questions before migrating data to the cloud.
Ibeck explains that a data governance framework should establish roles and responsibilities for managing data throughout a school district. These roles include data owner and data steward.
At Jeffco Public Schools, data stewards decide how the school district gets access to data, who can access it, how to keep data clean and who has literacy around data, according to Ibeck.
“We’re attempting to formalize that with roles and responsibilities across the board,” she says.
K–12 Data Governance Best Practices
Technologists must translate the lingo of data governance policies to school staff and administrators in plain language. Data governance teams are “universal translators between the teams that use data and steward data,” Thomas says. “Educators should not be expected to be technicians.”
She explains that communication is 80 percent of a data governance team’s work.
As schools continue to develop and refine data governance strategies, they should consider decision rights, which dictate who can interpret, override and ignore rules, Thomas says. “Schools need a clear understanding of who is empowered to make decisions about data.”
READ MORE: Student data privacy pioneer says K–12 schools must do better.
When a school nurse must consult the school’s database to determine who can pick up a student, for example, data governance dictates who has the right to make decisions on who can pick up a child, Thomas says.
“Maybe you have a process in place with a type of control that says you can propose an override, but someone else from administration has to sign off on it,” she says.
If a request comes in to change a student’s grade, schools must be able to justify their actions to protect their credibility, Thomas says.
How Can Schools Manage Data Governance Policies?
K–12 data privacy policy is more complex than in higher education because some K–12 students are too young to articulate how they feel about their privacy, Ibeck explains. She suggests that schools prioritize a review cycle for data governance policies and procedures that concern data. They must also seek buy-in from the superintendent and senior executives. Stakeholders such as the board of education and external community representatives should be in a “consult and inform role,” Ibeck says.
Jeffco Public Schools aims to have a full-time program manager of data governance, which Ibeck says school districts should budget for. In addition, she says, schools must have support from senior leadership for data governance programs.
As school districts develop their data governance programs, they should continue to tweak and improve them.
“It’s like a muscle that you work out every day,” Ibeck says. “It’s not something that we set up, call it done and watch it run right from afar. It has to continue to mature with things that change in the policy, data privacy and information security space. It’s going to be crucial for school districts to have that commitment.”
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