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Data Privacy & Security


In January 2020, the NYSED Board of Regents adopted Part 121 of the Commissioner’s Regulations for the Strengthening of Data Privacy & Security in NYS Educational Agencies to Protect Personally Identifiable Information (PII) pursuant to Education Law sections 2-d, 101, 207, and 305. The district policies were last revised on May 12, 2020.

District policies detail specific privacy protections that ensure:

  1. Every use and disclosure of personally identifiable information (PII) by Cambridge CSD shall benefit students and the Cambridge CSD, such as improve academic achievement; advance efficient and effective school operations; empower families and students with information;
  2. Personally identifiable information (PII) shall not be included in public reports or documents;
  3. Parents, legal guardians and eligible students (students who are age 18 or older) are afforded all the protections, where applicable, under the Family Education Rights Privacy Act (FERPA) and the Individuals with Disabilities Act (IDEA) and the federal regulations for implementing those statutes;
  4. Alignment with the National Institute for Standards & Technology (NIST) Cybersecurity Framework.
  5. Annual training and notification for employees that handle student, teacher and/or principal PII.
  6. Publication of the Cambridge CSD data security and privacy policy on its website for its community of stakeholders.

Parents’ Bill of Rights

The purpose of the Parents’ Bill of Rights is to provide information to parents, legal guardians, those in parental relation to students and eligible students (age 18 and older) about certain legal requirements that protect personally identifiable (PII) information pursuant to state and federal laws.

Complaint Procedures for Unauthorized Data Disclosure/Data Breach

Parents, legal guardians, eligible students (students who are at least 18 years of age or attending a post-secondary institution at any age), principals, teachers and employees may file a complaint about a possible data breach or improper disclosure of student data and/or protected teacher or principal data.

To submit a complaint, please follow the steps below:

  1. Email the Data Protection Officer, Chris Crucetti, at chris.crucetti@cambridgecsd.org
  2. Mr. Crucetti, or assigned designee, will contact the complainant by phone or email to review the complaint and initiate an investigation.
  3. Investigations will be completed and finalized in a reasonable amount of time, typically within 60 calendar days from the receipt of the complaint. In the event the investigation needs to extend beyond 60 days due to extenuating circumstances, the complainant will be contacted to inform them of the delay and the expected timeline for completion.
  4. Cambridge CSD will maintain a record of all complaints of data breaches or unauthorized releases of student/staff data & their disposition in accordance with applicable data retention policies, and report complaint reports & investigations as directed by NYS Ed Law 2d/Part 121 Regulations to the NYSED Chief Privacy Officer.

Ed Law 2-d Vendor Contracts and Agreements

Cambridge CSD may utilize vendors through paid contracted services and/or free services activated through individual user terms of service agreements for technology services in the provision of its educational services. These include software, mobile or web applications and/or web-based services.

Protection of Pupil Rights Amendment

The Protection of Pupil Rights Amendment provides parents/guardians with certain rights regarding
the conduct of surveys, collection and use of information for marketing purposes and certain physical
exams. In particular, if a survey is funded in whole or part by the U.S. Department of Education,
parents/guardians have the right to consent before students are required to complete a survey that asks
about any of the following protected areas:

  • Political affiliations or beliefs of the student or student’s parents/guardians;
  • Mental or psychological problems of the student or student’s family;
  • Sexual behavior or attitudes;
  • Illegal, anti-social, self-incriminating or demeaning behavior;
  • Critical appraisals of others with whom respondents have close family relationships;
  • Legally recognized privileged relationships, such as with lawyers, doctors or ministers;
  • Religious practices, affiliations or beliefs of the student or student’s parent/guardian; or
  • Income, other than as required by law to determine program eligibility. 

Parents/guardians will also receive a notice and an opportunity to opt students out of the following:

  • Any other survey that asks about the above protected areas;
  • Any non-emergency, invasive physical exam or screening required as a condition of attending school or school functions, with the exception of physical exams or screenings required or permitted by state law (e.g. hearing, vision or scoliosis); and
  • Activities involving collection, disclosure or use of personal information collected from students for marketing or to sell or otherwise distribute the information to others. 

Parents/guardians have the right to inspect any surveys that ask about the above protected areas, as well as surveys created by third parties that are used to collect personal information from students for marketing purposes and instructional materials used as part of the curriculum.

The school district will directly notify parents/guardians of its student privacy policy at the start of each school year and after any substantive changes. Parents/guardians will also be provided with reasonable notification of specific activities or surveys covered by this policy and the ability to opt their child out of such activities.

These rights transfer from the parents/guardians to their child who is at least 18 years old or an emancipated minor.

Anyone who believes their rights have been violated may file a complaint with: Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue, SW, Washington, D.C. 20202.

Student Data Collected by NYSED

As required by New York State Education law 2-d, the New York State Education Department (NYSED) publishes a list of the data elements that it collects from NYS school districts.

Contact

Chris Crucetti
Data Protection Officer
chris.crucetti@cambridgecsd.org
518-677- 8527, ext. 1453