Data Collection Frequently Asked Questions

For what purposes does Clear Creek ISD collect student information 

Clear Creek ISD collects student information solely for its own pedagogical purposes and for making decisions in the best interest of the District’s students. As a public school district, Clear Creek ISD provides various educational services and other assistance to students. For example, in addition to providing instruction, the District may provide transportation, meals, and special education services, administer extracurricular activities, advise students regarding college and career readiness, and provide health and wellness services.  In order to provide these and other services and to comply with state and federal law regarding curriculum, graduation, assessment, accountability, and other mandates, the District must collect, use, and disclose certain student information. 

What types of student information does Clear Creek ISD collect?
 

Upon enrollment and registration, Clear Creek ISD collects several types of student information, including, but not limited to: First Name; Middle Name; Last Name; Address; Home Telephone Number; Primary Guardian; Emergency Contact; Date of Birth; Gender; Race/Ethnicity; E-mail Address; Class/Year; Education/Course History; Proposed Graduation Date; Social Security Number; Medical Information, including Allergies, Illnesses, Medications, and Immunizations; Place of Birth; Primary Language; Transportation Needs; Household Information, including Financial Information; Disciplinary History; Special Education Status; Section 504 Status; Gifted/Talented Status; and Career/Technical Education Status. 

Clear Creek ISD may collect additional student information throughout a student’s enrollment in the District, such as attendance records, course history, grades, counseling records, health and immunization information, awards and accomplishments, disciplinary history, and test scores. 

How does Clear Creek ISD prevent unauthorized access to student information maintained on District systems?

Although no data security measures are guaranteed to be 100% effective, Clear Creek ISD employs a variety of data security technologies to protect student information from unauthorized access. In order to provide the highest level of protection to student information, Clear Creek ISD blocks all access to student information maintained on District systems and requires users to enter valid Clear Creek ISD credentials, including a username and password, to gain access.  Clear Creek ISD further restricts access to student information by issuing credentials to District users on an individualized, need-to-know basis, customized by student information data field.  For example, Clear Creek ISD may issue credentials to District nursing staff that enable them to access students’ protected health information, while teachers’ credentials do not allow access to students’ protected health information.

Sign-ins by Clear Creek ISD users authorized to access student information maintained on District systems are logged and monitored for sign-in failures. The District also uses internal firewalls to ensure that student information maintained on District systems is not accessible using the District’s guest network and utilizes intrusion detection technology to identify potential issues. 

When transmitting student information third-party systems, Clear Creek ISD encrypts student information in transmission using secure FTP/HTTPS and may engage the services of an intermediary to provide special technology to ensure that the District’s connection to the third-party system is secure and allow the District to delete information previously provided on a data-field basis.

In an effort to protect student information stored on District-issued technology devices, such as student computers, Clear Creek ISD personnel perform the majority of maintenance and repairs on District devices.  If the District is required to send a student’s computer to a service provider for maintenance or repairs, the District’s practice is to delete any confidential student information on the device prior to sending it out for service.  Clear Creek ISD also encourages students to store confidential information on designated District network drives and not on District-issued computers. 

Is the student information Clear Creek ISD collects confidential?

Yes, with some exceptions. Certain categories of student information collected by Clear Creek ISD are made confidential by law, including, but not limited to, the Family Educational Rights and Privacy ACT (FERPA), the Individuals with Disabilities Education Act (IDEA), the Health Insurance Portability and Accountability Act (HIPAA), the Protection of Pupil Rights Amendment (PPRA), and the Children’s Online Privacy Protection Act (COPPA).  Generally, these laws protect “personally” or “individually” identifiable information and provide that such information is confidential and may be accessed, used, and disclosed only under specified conditions. 

De-identified information is not confidential and may be accessed, used, and disclosed in the District’s discretion. Information is “de-identified” when all direct and indirect personal identifiers, such as name, ID numbers, date of birth, demographic information, location information, and school ID, have been removed.  Examples of de-identified information include statistical data and metadata. 

These FAQ are primarily intended to address Clear Creek ISD’s policies regarding the collection, use, and disclosure of
personally or individually identifiable student information. 

What is “Directory Information” and how is it used?

Federal law permits the release of student directory information to third parties; however, Clear Creek ISD has taken additional steps to restrict certain information from general public release. Clear Creek ISD has designated the following categories of information as “Directory Information”: student name; address; telephone listing; electronic mail address; photograph; date and place of birth; major field of study; degrees, honors, and awards received; dates of attendance; grade level; most recent educational institution attended; participation in officially recognized activities and sports; weight and height of members of athletic teams.

District policy allows for use and disclosure of Directory Information for school-related activities and publicity, such as athletic and fine arts events, graduation, honors and awards banquets, and other campus or District events recognizing student accomplishments. While federal law may permit the District to disclose Directory Information to third parties for even non-District purposes, Clear Creek ISD does not generally allow disclosure of Directory Information to third parties.  Federal law may, however, require the District to release limited Directory Information, such as name, address, and telephone listing, to military recruiters and accredited institutions of higher education. 

Parents may indicate their preferences regarding the District’s use and disclosure of Directory Information on the parent acknowledgement signature page of the student handbook.

Is student medical information protected?

Student medical information collected and maintained by Clear Creek ISD is protected by the Health Insurance Portability and Accountability Act (HIPAA). District policy requires compliance with HIPAA’s Privacy Rule, which provides that only certain individuals within Clear Creek ISD may access, use, and disclose students’ protected health information and only for purposes of treatment, payment, or health care operations. As such, the District restricts access to students’ protected health information and authorizes District personnel to access, use, and disclose such information only as permitted under HIPAA’s Privacy Rule.

For example, under HIPAA’s Privacy Rule, a school nurse may access, use, and disclose a student’s protected health information as necessary to treat the student.  The nurse may disclose the student’s protected health information to other school officials, such as the student’s teacher, provided that the nurse discloses only the minimum necessary information and only to those individuals with a justifiable need to know.  Further, the nurse may collaborate with the student’s other health care providers, such as the student’s doctor, and disclose the student’s protected health information to those health care providers as necessary for treatment of the student.  The District may also allow disclosure of the student’s protected health information as necessary to process payments and benefits as a Medicaid provider.  Under certain circumstances, Clear Creek ISD may be required to provide notice to parents or obtain parent authorization regarding disclosure of a student’s protected health information.

Why does Clear Creek ISD collect students’ social security numbers?

Clear Creek ISD collects and uses students’ social security numbers as necessary for identification and verification purposes related to the District’s educational functions.  For example, Clear Creek ISD may use students’ social security numbers as a means of verifying students’ identities in the Public Education Information Management System (PEIMS), which manages all information requested and received by the Texas Education Agency about public education, including student information.  Clear Creek ISD may also use students’ social security numbers to associate records among state and federal governmental entities providing educational services to the District’s students and for higher education purposes, such as providing transcripts to colleges and universities and providing information to financial aid programs.  When third-party services are utilized in connection with these functions, the District may allow disclosure of students’ social security numbers to a third-party service provider solely for the purpose of identifying students’ individual records within the third-party service provider’s system.

While providing a student’s social security number to Clear Creek ISD is voluntary and is not required, failure to do so may hinder the District’s ability to provide certain services and benefits to the student. If a parent chooses not to provide a student’s social security number to the District, the State of Texas will issue a unique ID number to the student for educational purposes. 

How does Clear Creek ISD use photographs or other electronic images of students?

Clear Creek ISD may use photographs and other electronic images of students for limited District purposes, such as publicizing District events and school news through the District’s website, third-party websites and social media sites that Clear Creek ISD uses for communications, newspapers, marketing brochures, publications, newsletters, or District promotional videos formally prepared for use both inside and outside the District.  Parents may indicate their preferences regarding the District’s use of their child’s photograph or other electronic image for such purposes on the parent acknowledgement signature page of the student handbook.

Are students’ electronic communications and activities through the District’s network and other technology resources confidential?

No, students’ electronic communications and activities through the District’s network and other technology resources should not be considered private or confidential. In order to ensure appropriate use of the District’s technology resources and protect students from inappropriate content and communications, Clear Creek ISD employs both filtering and monitoring technologies.  The District may filter or restrict access to certain content, and designated Clear Creek ISD staff may monitor students’ electronic communications and other use of the District’s technology resources, including District-issued technology devices and software. 

It is important to note, however, that the District’s filtering and monitoring technologies may not be 100% effective and that Clear Creek ISD cannot prevent students from disclosing confidential information in electronic communications or on the Internet through the District’s technology resources. In an effort to educate students regarding responsible use of electronic communications and the Internet, the District may provide guidance to students concerning the importance of maintaining the confidentiality of their own student information.  Parents may also decline permission for a student to access third-party Internet resources through District technology resources, in which case, the student will be permitted to access only District-provided systems.

How does Clear Creek ISD store the student information it collects?

Clear Creek ISD may store student information on District systems located at District facilities.  Clear Creek ISD may also store student information on third-party systems used to provide services to the District and its students or on third-party systems used to host District data in the cloud, or both. 

Who has access to student information collected by Clear Creek ISD?

Clear Creek ISD policy allows access to student information only as permitted or required by law.  As a general rule, parents of minor students may access their child’s student information, and adult students may access their own student information upon request.

By law, Clear Creek ISD may allow other individuals or parties to access student information under specified conditions.  For example, the District may authorize certain school officials to access student information. School officials include District employees, such as teachers, counselors, nurses, and administrators, and Clear Creek ISD Board members. School officials may also include third parties acting as agents of Clear Creek ISD or providing services to the District, such as contractors, consultants, volunteers, or other parties to whom the District has outsourced institutional services or functions.  All school officials must have a legitimate educational interest in the particular student information accessed, must remain under the District’s direct control with respect to the use and maintenance of the information, and may re-disclose the information only as permitted by law.  In sum, school officials may access student information only on a need-to-know basis. 

Clear Creek ISD does not allow non-District staff, such as booster club representatives and volunteers, to access student information unless they qualify as school officials with a legitimate educational interest in the particular student information accessed. While students may also lawfully act as school officials under limited circumstances, Clear Creek ISD generally does not permit students to participate in any activities that would require access to the student information of other students.

Clear Creek ISD may also authorize disclosure of student information to other individuals or parties as permitted by law.  For example, the District may allow the release of student information to officials of another school, school system, or institution of postsecondary education where the student seeks or intends to enroll, to certain governmental authorities, to accrediting organizations, and in connection with financial aid for which the student has applied or which the student has received.

Are third-party technology service providers permitted to access student information as school officials? 

Yes, as permitted by law, Clear Creek ISD may allow certain third-party technology service providers to access student information to the extent that they qualify as school officials with a legitimate educational interest in the information accessed.  The District uses various online educational services and apps to support learning both inside and outside the classroom.  For example, the District provides a student information system for District, student, and parent access to information such as grades, assignments, absences, and courses, a learning management platform for student access to coursework and textbooks, and a student e-mail account system.  These services may be required or sponsored by the State of Texas, provided at the initiative of Clear Creek ISD, or implemented at the request of teachers or other District employees. 

Third-party technology services are typically characterized as software as a service (SaaS), where the District accesses a third-party service provider’s software through a web-based interface for purposes of processing student information, or hosting/cloud services, where the District transmits student information to a third-party service provider through a web-based interface for purposes of storing student information.  In using these services, Clear Creek ISD may authorize disclosure of student information to third-party technology service providers for use in accomplishing District or student purposes, such as setting up student accounts.  Students and parents may also access certain services directly to create accounts, enter information, and participate in service offerings.

Like all school officials, third-party technology service providers may access student information solely to the extent necessary to accomplish the educational purpose for which the disclosure is made, but may use de-identified information and metadata for other purposes. Similarly, third-party technology service providers may allow their employees to access student information only to the extent required to provide contracted services to the District and its students.  For example, service provider personnel may view student information if necessary to provide customer support or perform consulting services for the District, provided that they protect the confidentiality of the information accessed.    

In order to limit the disclosure of student information to third-party technology service providers, Clear Creek ISD policies prohibit teachers and other District personnel from using any third-party software or apps without the District’s prior approval.  In many cases, Clear Creek ISD’s Technology Department may also participate in the implementation of third-party software, apps, and other technology services and oversee the transmission of student information to third-party technology service providers.  

How does Clear Creek ISD ensure that District employees comply with the District’s policies and applicable legal requirements regarding the collection, use, and disclosure of student information?

Both Clear Creek ISD Board Policy and District employment contracts require that employees comply with District policies and applicable legal requirements regarding student information.  District policies and applicable legal requirements are also addressed in the District’s Employee Handbook, Responsible Use Guidelines, and employee development activities, including regular training provided to employees regarding their confidentiality obligations with respect to student information and related best practices. 

Clear Creek ISD may also require certain front office staff and Human Resources personnel to sign a confidentiality agreement each school year regarding access to and disclosure of confidential information, including student information.  Among other things, the confidentiality agreement provides that these employees may access and use student information only to the extent that they “need to know” the information in order to perform their job responsibilities,  may not discuss student information in public areas, hallways, and gathering spaces, may not share student information with co-workers unless the co-worker also has a need to know the information in order to perform his or her job responsibilities, and may not discuss student information with third parties, whether at work, home, or in the community.

The confidentiality agreement emphasizes that unauthorized disclosure, copying, and/or misuse of student information may result in disciplinary action, up to and including termination of employment, and that the employee’s legal obligations regarding student information extend beyond his or her employment or association with the District.

How long does Clear Creek ISD retain student information?

Clear Creek ISD retains student information as long as necessary for student and District purposes. For example, the District may retain certain student information to track postsecondary matriculation rates.  When student information is no longer needed for student and District purposes, the District may continue to retain the information as required by law.  State law requires that Clear Creek ISD retain local government records, which may include student information, in accordance with the records retention schedules established by the Texas State Library and Archives Commission (TSLAC). The TSLAC records retention schedules are available at
www.tsl.state.tx.us/slrm/recordspubs/localretention.html.

Where can I find additional information regarding Clear Creek ISD’s policies related to student data privacy?

Clear Creek ISD’s Board Policies, which may be found at
http://pol.tasb.org/Home/Index/505, contain detailed information regarding the District’s policies, practices, and legal obligations related to the collection, use, and disclosure of student information.  Relevant Board Policies include, but are not limited to

Board Policy FL (Student Records) 
Board Policy CQ (Technology Resources)
Board Policy CPC (Office Management – Records Management)
Board Policy DH (Employee Standards of Conduct)
Board Policy EF (Instructional Resources)
Board Policy EKB (Testing Programs – State Assessment)
Board Policy FFA (Student Welfare – Wellness and Health Services)
Board Policy FFAA (Wellness and Health Services – Physical Examinations)
Board Policy FNF (Student Rights and Responsibilities – Interrogations and Searches)
Board Policy GB (Public Information Program)
Board Policy GBA (Public Information Program – Access to Public Information)
Board Policy GBAA (Information Access – Requests for Information)
Board Policy GBBA (School Communications Program – News Media Relations)
Board Policy GRAC (State and Local Governmental Authorities – Juvenile Service Providers) 

What should I do if I have a complaint regarding Clear Creek ISD’s data privacy practices?

Clear Creek ISD encourages parents and students to informally discuss their concerns
as soon as possible with the appropriate teacher, principal, or other campus administrator who has the authority to address the concerns in order to allow early resolution at the lowest possible administrative level.  Parents and students may initiate a formal complaint process under the District’s grievance policy set forth in Clear Creek ISD Board Policy FNG.  Parents and students also have the right to file a complaint with the U.S. Department of Education if they believe the District is not in compliance with the law regarding student records.

Who should I contact if I have questions or concerns regarding Clear Creek ISD’s data privacy practices?

Clear Creek ISD is committed to providing transparency and open communication with parents regarding student data privacy. If you have any questions or concerns regarding the District’s student data privacy practices, please contact Clear Creek ISD’s Office of Policy and Legal Affairs by telephone at 281.284.0013 or by mail to P.O. Box 799, League City, Texas 77574.

 

©2018 CLEAR CREEK INDEPENDENT SCHOOL DISTRICT | Powered by: SchoolMessenger | Privacy Policy | Site Map | Login