Privacy and the use of Google Apps for Education
Like many educational institutions in Alberta, Palliser Regional Schools utilizes services provided by Google Inc. through Google Apps for Education Services. Through its operations, Palliser uses Google Apps for services such as email and digital data storage.
These services are critical to Palliser in meeting its objective to provide the highest possible level of education to its students. Understandably, personal privacy is a very real concern for many people, including Palliser’s students and their parents. Palliser is committed to protecting the privacy of all of its students and we are confident that the use of Google Apps meets or exceeds all of our privacy obligations.
As a school board, Palliser is considered to be a public body that is governed by the Freedom of Information and Protection of Privacy Act. As a public body, Palliser has a general duty to protect personal information pursuant to the FOIP Act. Specifically, Palliser is required to protect personal information by making “reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure or destruction.” Where personal information collected by a public body, such as Palliser, is stored with a third party storage provider, the public body must ensure through contractual or other means that the information is stored in a manner consistent with the public body’s privacy obligations under the FOIP Act.
Palliser’s contract with Google contains several requirements that ensure that personal information remains protected:
- Ownership: All information stored with Google remains the property of Palliser Regional School Division. Our contract with Google specifically states that Google has no right to the information stored through Google Apps.
- Retrieval of Information: If Palliser were to discontinue its use of Google Apps, Google is required to permit Palliser to access and export any information remaining on Google Apps. Google is then required by contract to delete Palliser’s information from its systems. Also, Palliser may, at any time, require Google to destroy information that is stored on Google’s systems.
- Disclosure: Google is obligated to not disclose Palliser’s information except as required to do so by law. Moreover, unless Google is legally restricted from doing so, Google must provide notice to Palliser of any potential disclosure before Google discloses any of Palliser’s information and must allow Palliser an opportunity to respond and challenge any request disclosure. This means that Palliser retains control over handling requests for disclosure of Palliser’s information.
- Security: All facilities that are used by Google to store and process Palliser’s information must adhere to reasonable security standards. Google has, as a minimum, implemented industry standard systems and procedures to ensure the security of a user’s information. Google utilizes independent security audits to evaluate the adequacy of their security protocols. Google uses a Hypertext Transfer Protocol Secure (HTTPS) connection to encrypt emails sent via Google’s services. This provides a high level of protection against the risk that emails sent via Google will be intercepted en route to their recipient.
Unlike the legislation in British Columbia and Nova Scotia, the Alberta FOIP Act does not place any restrictions on where information may be stored by a public body. While the British Columbia and Nova Scotia statutes state that a public body may not store information outside Canada, no such restriction applies in Alberta. However, Palliser is currently working with Google to determine if all of Palliser’s information stored through Google Apps can be physically stored on servers that are located in Canada.
Parents and students of Palliser Regional School Division can be assured that we take our obligations on privacy and confidentiality seriously and have done our due diligence to ensure that we are meeting, if not exceeding, these statutory obligations in contracting with Google to utilize the valuable learning and education tools provided by Google Apps for Education. In regards to the sensitive information of our students, such as individual program plans and report cards, Palliser is committed to utilizing only the most stringent electronic computer programs to ensure that such information remains confidential and protected from any unauthorized use or disclosure; this includes, but is not limited to, encryption and necessary firewalls.
Palliser continually reviews and evaluates its operations and the technologies that are utilized in its schools to ensure that our students receive the best education and programming available. At this time, Palliser is confident that Google Apps for Education is at the forefront of technology and security. Should this change or should we become concerned about the protection of privacy of our students and staff, Palliser will immediately take steps to rectify the situation.
Please contact the FOIPP Co-ordinator at 1-403-328-4111 or toll-free 1-877-667-1234 if you have any questions or concerns regarding the protection of information by Palliser Regional Schools.