How is inBloom assuring that there is no unauthorized access to personallyidentifiable data? How is authorized data determined at vendor, state, district, andschool levels? What additional privacy limitations does inBloom plan to attach todata beyond the differing limitations applied by states and districts?
Each participating state or district will have its own protected data storage space,and will continue to own, manage and control access to its data, just as it alwayshas.
Since its inception, inBloom has been advised by some of the leading legal,digital privacy and security experts in the country to help keep the data stored bystates and districts secure. These include:
Shawn Henry, President of Services, CrowdStrike; Former Executive Assistant Director for cyber investigations at the FBI
Jay Pfeiffer, Senior Associate, MPR Associates, Inc.; Former DeputyCommissioner for Accountability, Research, and Measurement, FloridaDepartment of Education
Christopher Wolf, Director at Hogan Lovells LLP's Privacy andInformation Management Practice; Founder and Co-chair of the Future of Privacy Forum
Michael Gibbons, managing director with advisory firm Alvarez & Marsal,
who spent 15 years with the FBI’s Computer Investigations Unit
where heoversaw all cybercrime investigations.
inBloom continues to work closely with these advisors and continues to review itspolicies and procedures in order to maintain best in class security and privacysystems and practices.
inBloom does not and will not accept social security numbers (SSNs) as uniquestudent identifiers.
In the past,
policy has been to prohibit the storage and use of SSNs as a unique identifier unless the state or district applied for a waiver to that policy.
No such waivers were ever issued, and going forward inBloom willprohibit the use of SSNs under any circumstances and will not offer waivers.
Among dozens of pages of potential data fields are specific health and disabilitydata that, in other uses, would require specific parental consent for access under the HIPPA regulations. How is that being addressed?
inBloom does not facilitate the collection of any data not already collected by thestates and districts; it simply helps states and districts manage the data in a moresecure and cost-effective way to power learning applications that teachers need.
inBloom uses existing data standards that allow districts and states to manageinformation under their own local policies, in keeping with FERPA and the federal
Also of note, recent changes to FERPA did not affect the kind of servicesinBloom provides to states and districts, and inBloom will conform to whatever FERPA requires.