G Suite for Education (formerly called Google Apps for Education) provides free services for schools without advertising or data collection for core apps. Google’s Privacy and Security article states that these apps include Gmail, Calendar, Classroom, Contacts, Drive, Docs, Forms, Groups, Sheets, Sites, Slides, Talk/Hangouts and Vault.
Google reassures the public that “Schools can use G Suite core services in compliance with COPPA and FERPA. G Suite core services contain no advertising and do not use information in those services for advertising purposes.”
Why is this important? Student records are protected under the Family Educational Rights and Privacy Act, also known as FERPA (20 U.S.C. § 1232g; 34 CFR Part 99). FERPA differentiates between student records and directory information. Student records are private and directory information, depending on the situation, can be public. However, even directory information can be withheld per parent request. According to the U.S. Department of Education, all schools must tell parents about the directory information on an annual basis. How the notification is handled is determined by the school. Schools have the ability to classify what is a record and what is a directory.
My district’s school board policy (BCSD Board Policy 0604.10) defines Directory information as “information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed” (emphasis added). The definition continues with a list of examples of student information. Yearbooks published within or outside of the district is number 12 on that list. Make sure to check your school district policies regarding yearbooks and directory information
Each year our parents/guardians sign a Student Handbook that includes a Photo/Video Release form. Legally, this form only needs to be completed once a year; however, for events that are publicized, departments may ask for a second form to be completed as a reminder, “Hey, we are proud of your student’s work and would like to publicize her/his achievement.” Rarely do parents sign no because they seem to like us bragging about their kids.
That last sentence reinforces the appropriateness of the photograph or video. Any inappropriate picture must be removed. The importance of a positive digital footprint must be instilled in all parties involved - administrators, teachers, students, and parents.
Google Photos is not a G Suite Core Service. According to the same Privacy and Security article, “These [non-core] services are not governed by the Student Privacy Pledge or the G Suite agreement, so we may use information in these services in ways we would not for G Suite Core Services.” For example, services may have ads, but no student information is used to target students. To learn more, please read G Suite for Education Core and Additional services.
With this information in mind, you must decide how to properly store student yearbook photos. G Suite has two options - Google Photos or Google Drive. I compare the two apps on the Photos or Drive section.
Please note that as of August 1, 2017, non-core apps like Google Photos were turned off for students under 13 years of age. I urge you to have discussions with your students, administrators and parents to determine the best photo storage for your school.
My K-8 school district opted to keep Google Photos turned off for our 30,000+ students. Only teachers have access to the app. If this is your case too, no worries. With proper permissions, the teacher and a few trusted student editors can have access to the app. I emphasize proper parental and admin permission.
As is discussed in Sharing Photos, the ideal solution is to demand that G Suite for Education make Google Photos a Core Service with school-level sharing permissions and no ads. This would calm the worries of yearbook advisors and admin who do prioritize student privacy.
As a reminder, make sure to discuss the advantages and disadvantages with your students and admin to determine which online yearbook image sharing is best for you. Talk to parents. Remember our job is to educate and protect students.