What is The Preschool to 20 Workforce Information Network, otherwise known as P20-WIN?
Most legislators and parents have never heard of P20-WIN nor all of the information on our children that it collects and then allows for others to access. In simplest terms P20-WIN is a database in Connecticut. A database similar to others in all 50 states because they are built upon a National Model provided by The National Center for Education Statistics (NCES) which is the primary federal entity for collecting and analyzing data related to education in the U.S. and other nations. NCES is located within the U.S. Department of Education and the Institute of Education Sciences. While most of us have heard of our new education standards as well as our new assessment instrument for grades 3-8 and 11, known as SBAC, very few have heard of the statewide longitudinal data system (SLDS) that was also a contingency for our state to adopt in order to compete for Race to the Top federal funding and apply for a No Child Left Behind (NCLB) waiver. Connecticut has the waiver. We received 4.5 million for the data base. We did not receive any Race to the Top funding, yet we proceed.
P20-WIN collects information on students starting in preschool (and earlier), through k-12, the state university system and into the workforce and beyond from several existing databases which are housed at the State Department of Education, the Board of Regents and the Department of Labor. For now those are the three participating agencies whose data flows into P20-WIN. The national model for our database contains over 400 data points on k-12 students alone in addition to more for their teachers and parents. Those elements can be found here. You can also find the additional data elements for parents, college students, teachers and children under 5 there as well. The language that exists within the P20 policies excitedly beckons for the addition of other state agencies to come on board, such as The Office of Early Childhood, and basically any other state agency the P20 governing entities like, currently the P20-WIN Council, Executive Board, Governing Board, and Data Steward Committee self-govern without any Independent Ethical or Technical oversight as to what they are doing and without any regulation in law as to their activities. As we add agencies, we add data elements and we pay for the additional elements as per our state contract. The 4.5 million didn't even cover the cost of the original warehousing contract.
Last year 36 states proposed 110 bills in response to the data collection required of them via the federal funding to protect their children and college students from this massive invasion of privacy. Connecticut’s contribution to that collective representation of measures thus far had been zero. Today, in CT many proposed bills have been put forth related to protecting student data and information. We thank those representatives tremendously for listening to the facts and realizing that it is time for Connecticut to engage in this national conversation and take strides to restore the balance and protection that is remiss within our borders. To read the proposed bills you may visit here.
The Family Educational Rights and Privacy Act (FERPA) was stripped of any protection at the end of 2011, enacted January 3, 2012 when it was amended to include the words “without consent” to describe various conditions whereby a school may share personally identifiable information about students through their education records without the consent of a parent or guardian or a college student. This includes but is not limited to, their demographics, name, date of birth, address, student id number, BIOMETRIC record (facial scan, iris scan, fingerprint, etc.), mother’s maiden name, test scores, IEP information, on and on and on., as long as they use the correct terminology such as “audit and evaluation”, or “educational interest”. Health records, including physical and mental components are also included. While FERPA states that a school may share student information we ask the legislature to say they may not, beyond what is mandated to report. Federal legislation has been proposed to update FERPA to address some of its loopholes, enacted in 1974 prior to the digital age.
Why was this done? Besides the mandate to do so to compete for federal funding, there is “value” in the data. The “untapped educational market” worth billions in sales each year, compelling all those companies to sign “pledges of privacy”, spending big money lobbying against privacy legislation that would hinder their access to individual level information and thereby their sales is immense. The Software & Information Industry Association (SIIA) just released their report of 2.5 billion in assessment and testing sales fiscal year 2013 alone. The total k-12 market is valued at approximately 8 billion and growing thanks to the “online” school work of children and their ability to access that data behind the scenes of their use and through the 50 interlinking data systems. They look to much more revenue generated from testing and more "screen time" at school using children as free labor and product developers while we pay for it in increased costs for technology in our districts.
“Pledges” of privacy security and the employees “statements of non-disclosure” constituting little more than a pinky swear are of little comfort, especially given the details within the policy manuals themselves that are full of guidelines but lacking in enforcement protocol and liability in law. Those manuals require a review by an independent committee for there are holes within them that present admitted risks to children's safety. Binding legislation is warranted given the magnitude of the number of children involved, including a ban on biometric data and linking and newborn DNA linking. A guideline is not law. A confidentiality agreement without notice of breach is meaningless in effect.
A moratorium on the active functioning of P20-WIN is called for until our legislators have taken pause to review its policies and procedures with people outside of those serving on its various bodies , privacy legislation is enacted into law, an independent oversight committee is convened to watch over the governing entities of P20-WIN and every parent in the State of Connecticut is henceforth notified in their native language that their children are being put into an involuntary database without their consent for research purposes of which they have no control over, that was created via executive order in our state. The risks of misuse, breach and unintended applications are real. We simply must restore some balance to the all take no give situation we have allowed ourselves to succumb to. Its existence must be held to its original intent and not ever be allowed to evolve into another purpose for citizen monitoring that determines decisions regarding those lives within it in regards to their “human capital” worth, their character, their desire to seek higher education or their employability. As we know things piece by piece evolve into other uses. P20-WIN must not be allowed to do so.
We seal the records of our youth at 18 for a reason, so that if mistakes are made that they may fall down, get back up, realize their errors and move on without it negatively affecting the entirety of their lives. We must do the same for their education records and digital footprint. While I act to protect my own and the children of my town, I worry more so for those unknown to myself and every child in our nation who will make mistakes, who are indeed struggling, who may get into trouble along the way when they are just children. How will this information forever recorded to follow overhead into their future impact their ability to lead a successful and fulfilled life, unhindered by a childhood of surveillance?
My last question is simply this, what happens to all of this data when a child reaches the age of 20? I didn’t find the answer to that question in any of the manuals. The state of Connecticut in June of 2014 was one of only six states to receive a separate grant from the U.S. Department of Labor for $806,000 and change to build another data base. The purpose of that one is the same as the one for students, to collect “individual level” education and workforce information. For information on that you can visit here. Remember that the Connecticut Department of Labor is already a participating agency whose information flows into P20-WIN and is then “accessible” by outside parties and Washington. Nothing happens at 20, it simply continues on. That fact is why asking our state representatives and senators to regulate the information that is permissible to collect in law, banning certain information from being collected and implementing independent oversight becomes such an important mission for everyone.
When you have to take executive action, by-passing congressional and legislative approval, as a result by-stepping the democratic process, use money and punishment as a coercive means for states to adopt mandates and strip federal acts of protection to allow it, we have issues.
State agencies applying for federal grants that bind our state, its citizens and our fiscal resources beyond the grant period to policy, without prior legislative approval, is an area all states should address at as it causes the legislative branch to then have to play defense and for the People to have to ask why they were not represented in said grant stipulations prior to its application that they may not want in their state. This method is how the “reform” package was accomplished and why the nation is now in conflict. We can't afford to apply for federal grants. They simply do not cover the cost of the stipulations, otherwise known as an unfunded mandate. These grants undermine state sovereignty, public scrutiny and our legislators’ authority.
It is time we face P20-WIN and remove as much of it’s danger as possible by instituting oversight, enacting privacy protection laws for children and college students, including third party online vendor regulations for schools to follow in their contracts, providing parents with disclosures, vendors' privacy policies and access to P20-WIN. These measures have all been enacted into law around the country with one vision in mind, to protect the children of their states and to safeguard parental rights. This legislative session becomes Connecticut’s time to act in kind. I urge all parents to write to their own town or city legislators and to the general assembly education committee in support of them. For more information and CT Education Committee email addresses you may visit our website here. You may also find your own legislators there as well. They need to hear what you think.
For an introduction to the documents of P20-WIN you may visit here.
Many feel P20-WIN should be unfunded and unplugged. I agree with their sentiment. Absent of that choice we can work together to make it safer.
Sincerely,
Jennifer Jacobsen, M.Ed.
Connecticut Unites for Student Privacy
For additional Reading here are a few links to articles that describe what other state laws have been enacted and proposed federal legislation:
Most legislators and parents have never heard of P20-WIN nor all of the information on our children that it collects and then allows for others to access. In simplest terms P20-WIN is a database in Connecticut. A database similar to others in all 50 states because they are built upon a National Model provided by The National Center for Education Statistics (NCES) which is the primary federal entity for collecting and analyzing data related to education in the U.S. and other nations. NCES is located within the U.S. Department of Education and the Institute of Education Sciences. While most of us have heard of our new education standards as well as our new assessment instrument for grades 3-8 and 11, known as SBAC, very few have heard of the statewide longitudinal data system (SLDS) that was also a contingency for our state to adopt in order to compete for Race to the Top federal funding and apply for a No Child Left Behind (NCLB) waiver. Connecticut has the waiver. We received 4.5 million for the data base. We did not receive any Race to the Top funding, yet we proceed.
P20-WIN collects information on students starting in preschool (and earlier), through k-12, the state university system and into the workforce and beyond from several existing databases which are housed at the State Department of Education, the Board of Regents and the Department of Labor. For now those are the three participating agencies whose data flows into P20-WIN. The national model for our database contains over 400 data points on k-12 students alone in addition to more for their teachers and parents. Those elements can be found here. You can also find the additional data elements for parents, college students, teachers and children under 5 there as well. The language that exists within the P20 policies excitedly beckons for the addition of other state agencies to come on board, such as The Office of Early Childhood, and basically any other state agency the P20 governing entities like, currently the P20-WIN Council, Executive Board, Governing Board, and Data Steward Committee self-govern without any Independent Ethical or Technical oversight as to what they are doing and without any regulation in law as to their activities. As we add agencies, we add data elements and we pay for the additional elements as per our state contract. The 4.5 million didn't even cover the cost of the original warehousing contract.
Last year 36 states proposed 110 bills in response to the data collection required of them via the federal funding to protect their children and college students from this massive invasion of privacy. Connecticut’s contribution to that collective representation of measures thus far had been zero. Today, in CT many proposed bills have been put forth related to protecting student data and information. We thank those representatives tremendously for listening to the facts and realizing that it is time for Connecticut to engage in this national conversation and take strides to restore the balance and protection that is remiss within our borders. To read the proposed bills you may visit here.
The Family Educational Rights and Privacy Act (FERPA) was stripped of any protection at the end of 2011, enacted January 3, 2012 when it was amended to include the words “without consent” to describe various conditions whereby a school may share personally identifiable information about students through their education records without the consent of a parent or guardian or a college student. This includes but is not limited to, their demographics, name, date of birth, address, student id number, BIOMETRIC record (facial scan, iris scan, fingerprint, etc.), mother’s maiden name, test scores, IEP information, on and on and on., as long as they use the correct terminology such as “audit and evaluation”, or “educational interest”. Health records, including physical and mental components are also included. While FERPA states that a school may share student information we ask the legislature to say they may not, beyond what is mandated to report. Federal legislation has been proposed to update FERPA to address some of its loopholes, enacted in 1974 prior to the digital age.
Why was this done? Besides the mandate to do so to compete for federal funding, there is “value” in the data. The “untapped educational market” worth billions in sales each year, compelling all those companies to sign “pledges of privacy”, spending big money lobbying against privacy legislation that would hinder their access to individual level information and thereby their sales is immense. The Software & Information Industry Association (SIIA) just released their report of 2.5 billion in assessment and testing sales fiscal year 2013 alone. The total k-12 market is valued at approximately 8 billion and growing thanks to the “online” school work of children and their ability to access that data behind the scenes of their use and through the 50 interlinking data systems. They look to much more revenue generated from testing and more "screen time" at school using children as free labor and product developers while we pay for it in increased costs for technology in our districts.
“Pledges” of privacy security and the employees “statements of non-disclosure” constituting little more than a pinky swear are of little comfort, especially given the details within the policy manuals themselves that are full of guidelines but lacking in enforcement protocol and liability in law. Those manuals require a review by an independent committee for there are holes within them that present admitted risks to children's safety. Binding legislation is warranted given the magnitude of the number of children involved, including a ban on biometric data and linking and newborn DNA linking. A guideline is not law. A confidentiality agreement without notice of breach is meaningless in effect.
A moratorium on the active functioning of P20-WIN is called for until our legislators have taken pause to review its policies and procedures with people outside of those serving on its various bodies , privacy legislation is enacted into law, an independent oversight committee is convened to watch over the governing entities of P20-WIN and every parent in the State of Connecticut is henceforth notified in their native language that their children are being put into an involuntary database without their consent for research purposes of which they have no control over, that was created via executive order in our state. The risks of misuse, breach and unintended applications are real. We simply must restore some balance to the all take no give situation we have allowed ourselves to succumb to. Its existence must be held to its original intent and not ever be allowed to evolve into another purpose for citizen monitoring that determines decisions regarding those lives within it in regards to their “human capital” worth, their character, their desire to seek higher education or their employability. As we know things piece by piece evolve into other uses. P20-WIN must not be allowed to do so.
We seal the records of our youth at 18 for a reason, so that if mistakes are made that they may fall down, get back up, realize their errors and move on without it negatively affecting the entirety of their lives. We must do the same for their education records and digital footprint. While I act to protect my own and the children of my town, I worry more so for those unknown to myself and every child in our nation who will make mistakes, who are indeed struggling, who may get into trouble along the way when they are just children. How will this information forever recorded to follow overhead into their future impact their ability to lead a successful and fulfilled life, unhindered by a childhood of surveillance?
My last question is simply this, what happens to all of this data when a child reaches the age of 20? I didn’t find the answer to that question in any of the manuals. The state of Connecticut in June of 2014 was one of only six states to receive a separate grant from the U.S. Department of Labor for $806,000 and change to build another data base. The purpose of that one is the same as the one for students, to collect “individual level” education and workforce information. For information on that you can visit here. Remember that the Connecticut Department of Labor is already a participating agency whose information flows into P20-WIN and is then “accessible” by outside parties and Washington. Nothing happens at 20, it simply continues on. That fact is why asking our state representatives and senators to regulate the information that is permissible to collect in law, banning certain information from being collected and implementing independent oversight becomes such an important mission for everyone.
When you have to take executive action, by-passing congressional and legislative approval, as a result by-stepping the democratic process, use money and punishment as a coercive means for states to adopt mandates and strip federal acts of protection to allow it, we have issues.
State agencies applying for federal grants that bind our state, its citizens and our fiscal resources beyond the grant period to policy, without prior legislative approval, is an area all states should address at as it causes the legislative branch to then have to play defense and for the People to have to ask why they were not represented in said grant stipulations prior to its application that they may not want in their state. This method is how the “reform” package was accomplished and why the nation is now in conflict. We can't afford to apply for federal grants. They simply do not cover the cost of the stipulations, otherwise known as an unfunded mandate. These grants undermine state sovereignty, public scrutiny and our legislators’ authority.
It is time we face P20-WIN and remove as much of it’s danger as possible by instituting oversight, enacting privacy protection laws for children and college students, including third party online vendor regulations for schools to follow in their contracts, providing parents with disclosures, vendors' privacy policies and access to P20-WIN. These measures have all been enacted into law around the country with one vision in mind, to protect the children of their states and to safeguard parental rights. This legislative session becomes Connecticut’s time to act in kind. I urge all parents to write to their own town or city legislators and to the general assembly education committee in support of them. For more information and CT Education Committee email addresses you may visit our website here. You may also find your own legislators there as well. They need to hear what you think.
For an introduction to the documents of P20-WIN you may visit here.
Many feel P20-WIN should be unfunded and unplugged. I agree with their sentiment. Absent of that choice we can work together to make it safer.
Sincerely,
Jennifer Jacobsen, M.Ed.
Connecticut Unites for Student Privacy
For additional Reading here are a few links to articles that describe what other state laws have been enacted and proposed federal legislation:
- http://bits.blogs.nytimes.com/2014/05/14/senators-intend-to-amend-federal-student-privacy-law/?_r=0
- http://www.marketplace.org/topics/education/learningcurve/keeping-student-data-safe-marketing-machine
- http://www.jdsupra.com/legalnews/new-student-data-privacy-laws-top-point-53758/
- http://www.politico.com/story/2014/05/data-mining-your-children-106676.html
- Video; Datapalooza at the White House with Knewton: http://news.heartland.org/newspaper-article/2014/03/19/video-we-have-more-data-about-our-students-any-company-has-about-anythi