Privacy Impact Assessment
A privacy impact assessment (PIA) is a tool for identifying and assessing privacy risks throughout the life cycyel of a program or system. Greater Victoria School District (61) and Saanich School District (63) co-wrote a PIA for G-Suite in 2016.
These two School Districts worked in collaboration with a number of other BC school districts on the privacy implications of G-Suite. Delta School District, Kamloops School District, Kelowna School District, Campbell River School District, Sooke School District, Vernon School District, Nanaimo School District, have all used this framework to continue to develop their local Privacy Impact Agreements and sites to support using G0Suite for Education in the classroom.
G-Suite for Education versus Public Google Accounts
While G-Suite for Education provides staff and students with access to the same tools as a ‘public’ Google account, there are important differences between the two. The school district provides access to and manages G-Suite for Education accounts for consenting staff and students in schools. These applications block advertisements and block 3rd party scanning of student or staff information for advertising, and allow for more strict filtering and application control by school district system administrators.
Freedom of Information and Protection of Privacy Act
Student account information (student first and last name, grade level, and last 4 digits of SD61 identification number), as well as any documents uploaded onto the Google Apps platform will be stored on secure Google servers located beyond Canada, and may be subject to the laws of foreign jurisdictions. The use of student information for G-Suite for Education is subject to the Freedom of Information and Protection of Privacy Act (FIPPA) .
Access to SD61 G Suite by SD61 System Administrators
SD61 system administrators have full access to content stored within SD61 G Suite however they will only access content from SD61 users’ G Suite email or documents in the event of suspected violations to the terms and conditions outlined in Policy 1300 “Acceptable Use of Technology”, Regulation 1300.3 “Student Acceptable Use of Digital Technology”, and in Regulation 1300.2 “Employee Acceptable Use of Digital Technology”.
Access to SD61 G-Suite by Google Administrators
As per the G-Suite terms of service and privacy documents, all information and any content created or uploaded into the SD61 G-Suite platform is not owned by Google. However, as outlined in the Google Apps for Education Privacy Website , Google does maintain the ability to access and share any personal or content data on the SD61 G-Suite platform under the following circumstances:
- If Google has obtained additional consent from the user to share personal information; or
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms of Service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Google, our users or the public as required or permitted by law.
Designated Google employees will only access account data when a SD61 system administrator grants Google explicit permission to do so for troubleshooting purposes. During the course of troubleshooting an issue or other investigation, the Google Support team may ask for the creation of a test administrator account, solely to be used to resolve the particular issue at hand. Google employees or automated systems may also take down any content that violates the Terms of Service.