Privacy : G Suite - Google Apps for Education and Chromebooks.
Lompoc Unified School District utilizes Google Apps for Education or G Suite. These apps are the core services which are provided by each Chromebook and Chrome browser that is used within the school district. Every student has the chance to use these applications and services. There have been many concerns about privacy provided by Google and LUSD. In accordance with that effort, we are providing the following information about privacy. Please feel free to review the information provided below.
"The G Suite for Education (formerly called Google Apps for Education) core services are the heart of Google’s educational offering to schools. The core services are Gmail (including Inbox by Gmail), Calendar, Classroom, Contacts, Drive, Docs, Forms, Groups, Sheets, Sites, Slides, Talk/Hangouts and Vault. These services are provided under the G Suite agreement."
"Schools can use G Suite core services in compliance with COPPA and FERPA. G Suite core services contain no advertising and do not use student data for advertising purposes."
"More than 50 million students, teachers and administrators in almost every country in the world rely on G Suite to learn and work together. We are committed to protecting the privacy and security of all our users, including students."
"Hundreds of school districts throughout California and the rest of the country use a suite
of education products formerly called Google Applications for Education (“GAFE”) and
recently renamed G Suite for Education ("G Suite"). Questions have been raised as to
whether G Suite complies with the Family Educational Rights and Privacy Act
(“FERPA”) found in 20 U.S.C. 1232(g), and California Assembly Bill (“AB”) 1584
found in California Education Code section 49073.1. Both laws establish privacy
protections for pupil records stored or analyzed by digital education providers. These
protections include, but are not limited to:
(1) prohibitions against the unauthorized use of the records;
(2) requirements to allow a student or parent to access the records;
(3) disposal of the records at the end of the term of the agreement; and
(4) requirements to maintain adequate safeguards for the records, including
notification of unauthorized access to pupil records."
"One reason questions may have been raised about G Suite data privacy compliance is that
not all FERPA and AB 1584 required terms are found in the G Suite for Education
Online Agreement (“G-Suite Online Agreement”). Given the widespread use of G Suite
there was an urgent need to determine whether G Suite complies with FERPA and AB
1584. CETPA and its counsel, Fagen Friedman & Fulfrost, undertook an extensive
analysis of the G Suite privacy terms and conditions, including the G Suite Online
"The analysis found that central to determining privacy compliance is understanding that
the G Suite privacy terms and conditions consist of more than just the G Suite Online
Agreement. FERPA and AB 1584 requirements can be found in several additional G
Suite documents, including but not limited to: the G Suite Privacy Notice; the Additional
Terms for Use of Additional Services; and the Data Processing Amendment to G Suite
"When taken together, these documents show that G Suite likely complies with all
material portions of FERPA and AB 1584. In most cases, the elements of the data
privacy requirements are explicit in G Suite's privacy terms and conditions. However,
some aspects of FERPA and AB 1584 requirements are not referenced verbatim in
privacy terms and conditions. Some of those requirements require statutory interpretation
to conclude that G Suite has met a particular data privacy requirement."
"There are two factors of the data privacy compliance laws that require statutory interpretation to
conclude that G Suite has met its obligations under FERPA and AB 1584. The first requirement is to
provide students with the opportunity to establish a separate account for student-generated work and the
second is the right of a parent to access a pupil's record and correct any erroneous information.
Currently, the G Suite privacy terms and conditions state that G Suite will only take a ministerial role to
"The issue then is whether the federal and state laws require Google to actively manage these processes,
or whether Google’s role may be ministerial by implementing the directions of a school district. We
conclude that the creation of a separate account and the modification of pupil records is a power that AB
1584 and FERPA intended to leave to school districts and not to Google. Therefore, Google’s
ministerial role stated in the G Suite privacy terms and language on these two topics is consistent with
the intent of the statutes."
"CETPA’s finding that the G Suite data privacy terms and conditions comply with FERPA and AB 1584
is bolstered by recent findings of Ernst & Young, which held that G Suite privacy terms and conditions
were consistent with the privacy standards established by the International Standards Organization for
data privacy. These standards have many similarities to those found in FERPA and AB 1584.
We hope this guidance will provide reassurance to the many California school districts using or
contemplating the use of G Suite. Please note that student data privacy laws are relatively new and
subject to interpretation, and G Suite may amend its terms and conditions at any time, which could alter
the foregoing analysis and findings. CETPA has posted the underlying legal analysis supporting this
conclusion on http://cetpa.net Resources page."