Policy Code: C8

(Required) [1}

First Reading: March 8, 2022
Adopted: March 22, 2022

Related: See C8 Procedure: Security Camera Surveillance Monitoring

Policy

It is the intent of the Essex Westford Educational Community Unified Union School District (EWECUUSD) to comply with the provisions of the federal Pupil Privacy Rights Amendment (PPRA)[2] and Vermont State Board of Education Rules[3] governing the administration of certain student surveys, analyses or evaluations[4].

Administrative Responsibilities
The superintendent or designee shall develop administrative procedures to ensure school district compliance with applicable federal and state laws related to pupil privacy and parents’ access to information regarding the conduct of surveys, collection and use of information for marketing purposes, and certain physical exams.  The administrative procedures shall include provisions related to the following legal requirements.[5]

1. 1. The right of parents of a student to inspect, upon request, surveys created by third parties before the administration of the surveys to student.;
   2. Any applicable procedures for granting a request by a parent for access to such survey within reasonable time after a request is received.;
   3. Arrangements to protect student privacy in the event of the administration or distribution of a survey to a student containing one or more of the items listed in the federal PPRA.[6]  
   4. The right of a parent to inspect, upon request, any instructional material used as part of the educational curriculum for the parent’s child, and any applicable procedures for granting access to such material within a reasonable time after the request is received.[7]
   5. The administration of physical examinations or screenings that the school district may administer to a student.[8]
   6. The collection, disclosure or use of personal information collected from students for the purpose of marketing or for selling that information (or otherwise providing that information to others for that purpose), including arrangements to protect student privacy in the event of such collection, disclosure or use.[9]
   7. The right of a parent of a student to inspect, upon request, any instrument used in the collection of personal information under subparagraph (6) above, before the instrument is administered to a student, and any applicable procedures for granting a request for such inspection within a reasonable time after receiving the request.[10]
   8. Provisions to ensure that parents are notified of the school district policies and procedures adopted to comply with federal and state laws and regulations governing pupil privacy, including, but not limited to, annual notice of such policies and procedures;  notification and an opportunity for the parent to opt the student out of participation in activities involving the collection, disclosure, or use of personal information collected from students for the purpose of marketing or selling that information (or otherwise providing that information to others for that purpose); notification and an opportunity for the parent to opt the student out of participation in the administration of surveys containing items specifically listed in the Pupil Privacy Rights Amendment; and notification and an opportunity for the parent to opt the student out of participation in any nonemergency, invasive physical examination or screening that is (1) required as a condition of attendance; (2) administered by the school and scheduled by the school in advance; and (3) not necessary to protect the immediate health and safety of the student, or of other students.[11]    
   9. The rights of a parent under the PPRA transfer to a student who is 18 years old or an emancipated minor under state law.