Hi !
For some of you reading this newsletter, all the technical and legal jargon, may sometimes be frustrating. If you feel frustrated by how nerdy our legal approach is, you have a point. Privacy can sometimes be very alienating.
We have several members of our project team who are far more practical than the one who is the project manager and usually writes these newsletters. Two of us have taken over the newsletter this week and we want to speak to those of you who are most concerned with practical solutions when it comes to privacy in a school setting.
What can YOU gain from this DPIA?
What does the work with the national DPIA mean for those of us who actually work in and with the school?
For many of us in Norwegian municipalities, Google (and equivalent systems) has been introduced in recent years. The process before these systems were introduced, has been more, or less, thoughtful. We knew less then than we do now.
Since then, the digitalization process has increased, and what we started with initially is different from what we now have. The capabilities of each system have increased, along with integrations to other systems.
At the same time, expectations on how to handle privacy issues have increased, both from parents, organizations, and regulatory bodies. To be honest, there are good reasons for the heightened expectations. As previously mentioned, we know more now than we did initially.
Through our work with the national DPIA, those of us who use Google Workspace for Education, can get help understanding Google's compliance documentation and get help putting it in a Norwegian context.
Municipalities don't have to do all the work themselves and can instead base their understanding on more accessible information, both in terms of language and form. The project will offer various guides that can be of practical use to us. Incorporating this into the record of processing requires effort, and we have therefore created a draft that you can download in Norwegian here.
One strength, and a challenge, with Google is that new features are constantly being added; from tiny changes that can pass unnoticed to larger changes that require thorough evaluations. Therefore, a separate guide will be provided so that you, who work on the municipality side with making sure the day-to-day use of Google Workspace for Education works, can use to handle these changes.
We will also try to help determine when the rolling out of new features from Google mean you need to involve other resources, such as the nerdy lawyers. We want to underline that keeping up with such changes, is not something one person can fix alone.
It takes a crew to raise this system!
Do I need to understand all the legalities myself?
No, not everyone needs to understand all the legalities. Fortunately, we have different roles. Privacy jurists and experts on privacy and information security can help us here!
But everyone needs to understand a bit😊 It is important to know why it is so crucial that personal data from pupils we process and where it ends up being stored. All of us have experienced receiving questions from both students and guardians about privacy and processing of personal information. And when such questions arise, we need to be able to provide some answers.
If you (and those around you) have a basic understanding of privacy principles, you are well on your way! It will also help you understand the more cumbersome documentation that the experts handle. The privacy principles below are well known to some and perhaps new to others.
But everyone working in a school setting cares about privacy and confidentiality. It is a good starting point to understand the value of these principles!
- Principles of lawfulness, fairness, and transparency
❓ Do I know that we use the system legally and that we facilitate informing our users about the use? - The principle of purpose limitation
❓ Do I know that I use the system for its intended purpose?
- The principle of data minimization
❓ Have I reflected on whether the system collects more information than it actually needs? - The principle of accuracy
❓ Do I know how the system facilitates the use of the correct personal information, and that the correct data is stored? - The principle of storage limitations
❓ Do I know if there is a routine for deleting personal data that the data processor has collected on our behalf? -
The principle of integrity and confidentiality
❓ Do I know enough about how the system is secured in terms of data and privacy? - The principle of accountability
❓ Do I know that we, as a municipality, take the necessary responsibility to use this system?
We believe that if we understand these principles, we will have a good understanding of how to manage our systems, and we have an opportunity to understand when we need to "ask a friend" for help.
Perhaps we can see the national DPIA as this friend trying to clear up the compliance documentation and what is " difficult" for us, so that we get the opportunity to focus on what is most important to us; the actual use of systems as Google Workspace for Education. And what solutions we offer to our users, both students and teachers.
What are the practical implications of the DPIA?
For those of us involved in managing the actual use of the systems such as Google Workspace for Education, we are most concerned with the concrete questions we must address:
🤔 Should everyone be allowed to do everything?
🚀 How can I keep up with all the changes (features) being rolled out in Google Workspace for Education?
🌎 Should we turn on or off external file sharing?
🤬 Will there be an uproar if we turn off YouTube – is it right to do so?
🤯 What are the things that I should really keep in mind?
Through this project, we hope to assist those of you who are in charge of the admin panels and make the decisions on how Google Workspace for Education is used in your municipality. We hope to help you to see which issues you must consider. Sometimes we will give clear advice on which settings should be chosen.
Other times we will inform you about what is important to consider before you make the decision that suits you and your municipality best.
It is important to remember that no decision is "carved in stone." If teachers or students start using the services or the various functions in a different way, or if Google makes changes, the municipality must conduct new evaluations. This can lead to changes in the use of the services, either to a small or large extent.
One thing we are absolutely sure of is that the best advice we can give is to talk to others who also use the Google Workspace for Education. No one person has all the answers alone!
About the stress 😬
The process of completing the municipality's final DPIA can be stressful. Maybe you realize that you should turn off a service that has been available until now? Maybe the teacher in class 6A loses access to a resource they think is absolutely necessary in their teaching. Change is always uncomfortable, but it helps to know why we are doing it!
The project does not aim to restrict the use of Google Workspace for Education as much as possible; and even if we make a DPIA, there will be flexibility built into the DPIA so that you can make your assessments. But we must at least ensure that we can offer support in what needs to be assessed.
Finally, an important goal of conducting a DPIA is that we, as a municipality, should get a good overview of the system. We get an opportunity to make informed decisions about how we, as a municipality, can ensure that we actually have a functional digital system, and that we are using it in a way we can endorse.
Maybe the stress of not having that overview, and not having conducted the necessary assessments, is even greater than the stress of making changes?
We wish you a wonderful, privacy-friendly week-end!
Best regards,
Stine Randa and Leif Cato Larsen
On behalf of project manager Ida Thorsrud
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.