Hi !
The DPIA has been postponed. In this newsletter, we will touch a bit on why, without going into too much detail.
The current debate in Norway largely revolves around screen usage and content restrictions, both during leisure time and in schools. These debates complicate discussions about privacy as it often gets drawn into the debate in unclear and imprecise ways.
While screen usage and harmful content are important issues, they are distinct from privacy concerns. There are subtle differences that we struggle to communicate clearly to the public.
Yes, this newsletter is about something as complex as these nuances!
Processing of personal data for your own purposes
One of the major issues that limit the solutions you, as a school owner (and data controller), can implement is the question of what personal data your provider processes for its own purposes.
Many providers use metadata â information on how students and teachers use the service to further develop it or even to create new commercial services.
These are the personal data that indirectly identify students and teachers, such as which version of a browser is used, when users log in, and which services are utilized.
The problem arises when these personal data are further processed for purposes that fall outside the scope of the Education Law. This would be the case when personal data are used specifically to develop new commercial services.
The Education Law is clear in its purpose: to provide education to students, not to use student data for commercial purposes.
This challenge is particularly daunting given the digital infrastructure we all participate in, including search engines and browsers, is designed to collect as much personal data about us as possible.
There is no quick fix to this problem. It not only affects school students but all of us who, over decades, have grown accustomed to using browsers, search engines, language models, and other "free" digital services where personal data serve as the currency.
Fortunately, there is ongoing international work at the EU level, such as the Digital Service Act, which aims to tighten regulations in this area.
Privacy vs. content restriction
One scenario we foresee in the DPIA is that we might recommend not logging in as a user for certain services. These could be services that others wish to close off due to the content students are able to access. The rationale for our recommendation will be quite different.
If some of our recommendations lean this way, we will face a communication challenge: Our recommendations may appear similar â to limit the use of the solution â but the underlying reasons are significantly different.
From a privacy perspective, it's about data control and further processing of personal data. From a content restriction perspective, it's about limiting access to harmful or perhaps unwanted content and non-academic use.
Your feedback
Okay. That was an attempt to explain the difference.
For this newsletter, we want your feedback: Did you understand it? What didnât you understand? What was difficult to grasp? How can we state this differently? Is it completely incomprehensible, and should we just give up?
All feedback is welcome! We genuinely want your input as we struggle with how to communicate this effectively.
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.