Hi !
You might be wondering what will happen to the national DPIA (Data Protection Impact Assessment) once we have completed it? Who will be responsible for its further follow-up?
This has not been clarified yet, but one possibility is the establishment of a support service for privacy, information security, and universal design in schools. The sector has long seen the need for such a support service, and the Privacy Commission highlighted this need in NOU 2022: 11 "Your Privacy – Our Shared Responsibility."
Now, the question of a support service is being investigated as part of the Strategy for Digital Competence and Infrastructure. The Directorate of Education has been tasked with deciding whether and how a support service can be established. The assignment was recently put out to tender, and the deadline for submitting the study is in November this year.
This DPIA project is part of the SkoleSec project, which is KS's initiative on information security and privacy in the school sector.
In connection with the investigation of the national support service, municipalities, suppliers, professional and interest organizations, and state authorities met at Gardermoen to discuss the needs of the sector.
The needs of the sector
The school sector has long pointed out that there is a great variation among municipalities regarding access to both privacy expertise and resources to make good assessments of privacy in digital learning resources. All school owners have the same obligations under the Personal Data Act, but they have different starting points for ensuring compliance with the requirements.
Many schools across the country use the same learning resources, and it is therefore also inefficient for a learning resource to be assessed in 357 different municipal instances and 15 counties. The sector has therefore highlighted the need to ensure better access to expertise and capacity across municipalities.
National guidelines, expertise and resources, and more sharing across the board are highlighted as important, while at the same time ensuring that each individual school owner's responsibility as a data controller is not fragmented.
How to succeed in collaboration on privacy, information security, and universal design?
An important prerequisite for successful collaboration on privacy, information security, and universal design is to establish secure sharing platforms among the various actors. This applies both at a national and a more regional level.
A national support service can ensure access to common assessments, expertise, and resources. At the same time, it is useful to facilitate good cooperation regionally – everyone benefits from having a "good neighbor" in the nearest municipality to call for discussion and collaboration.
The most important thing is that one does not remain isolated, but facilitates more collaboration and similar practices through clearer requirements and guidelines.
A more detailed summary of the extensive and thorough group work will be shared with you later, there is a lot to address!
What do we agree and disagree on?
At the meeting, several participants highlighted the need for competence development in the sector. There is too much waste of resources and time due to varied and insufficient competence development.
Supporting the work of SkoleSec, digitalization networks, and others can contribute to the continuation of the good work being done to raise competence in privacy and information security.
All participants largely agreed that the need for a national support service is great. At the same time, the support service must not become a crutch for the municipalities, but rather support the municipalities in the fulfillment of their responsibilities as school owners.
I wish you a wonderful, privacy-friendly week-end!
Best regards,
Ida Thorsrud
Project manager national DPIA
This newsletter was translated from Norwegian to English with assistance from ChatGPT by OpenAI. While it guided our translation, we made independent editorial choices. Any discrepancies result from this combined approach.
