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The Ministry of Education has updated the frequently asked questions section in collaboration with the Guarantor for the Protection of Personal Data.
Can the educational institution create an account for the registration of the student or teacher to the integrated digital teaching platforms? (publication date 01/12/2020)
When the creation of a personal account is necessary for the use of platforms for integrated digital teaching, the processing of personal data, attributable to the functions institutionally assigned to the educational institution, is allowed, provided that only the services are activated by default. strictly necessary for the development of the teaching activity and the consent of the user (student, parent or teacher) or the signing of a contract should not be required. However, the automatic activation of additional services or functions, which are not necessary for educational purposes (for example, geolocation or social login systems) is not allowed.
In configuring the accounts associated with students and / or teachers, it is necessary, among other things, to adopt adequate procedures for the computer identification and authentication of users, to use robust processes for assigning credentials or user authentication devices. (eg – establishment of easy-to-know passwords), define appropriate and differentiated password policies according to the specific risks of the treatment and assign authorization profiles that ensure selective access to data.
In order to prevent misuse and raise awareness about the use of online services for teaching, schools should conduct awareness campaigns targeting students and their families, as well as provide instructions to teachers and other staff on the correct how to use the aforementioned services in accordance with the rights of others.
Where can we find information on privacy protection during DDI? (publication date 10/24/2020)
These indications can be found in the document “Integrated digital education and privacy protection: general indications”, edited by the joint Ministry of Education-Guarantor Office for the protection of personal data, referred to in Ministry Note no. 11600 of September 3, 2020, whose objective is to provide educational institutions with common guidelines and general principles for the implementation of the DDI with special attention to aspects related to network security and the protection of personal data. (Integrated digital education and protection of privacy: general indications)
Can educational institutions publish student names by class on their institutional website?
No, the dissemination of data related to the composition of classes on the institutional website is not allowed since, according to article 2-ter of the Code relating to the protection of personal data, the dissemination of personal data is lawful only if it is expressly provides. by law or, in the cases provided by law, by regulation.
Therefore, educational institutions that intend to guarantee the knowledge of said data in advance must use appropriate methods to ensure the protection of personal data and the rights of the interested parties.
For this purpose, the names of the students divided by class for the first grades of schools of all levels may be disclosed, by means of a specific communication to the email address provided by the family at the time of registration for the academic year . 2020-2021, while for subsequent classes, when deemed necessary, the list of students may be available in the reserved area of documents of the electronic register accessed by all students of the corresponding class.
In the case of communication by email, special attention must be paid to sending it to each recipient with a personalized message or to sending it through the field called “blind copy” (bcc) so as not to reveal the email addresses. provided by families.
In addition, it is recommended to prepare a specific “legal notice” in which it is highlighted that the aforementioned personal data cannot be communicated or disseminated (for example, by publishing them on a blog or on social networks).
However, in accordance with well-established practice, the posting of student names by class is allowed on the board displayed on the school’s bulletin board. In relation to the start of the next school year, in order to avoid gatherings and guarantee the necessary security and distancing measures, the principal arranges a timetable for access to school councils and informs the families of the students in advance.
This method of publication of the board in relation to the next school year should be adopted on a residual basis only if the school does not have an electronic record or cannot use telematic data communication tools.
In all cases, the lists relating to the composition of the classes, available in the form indicated above, must contain only the names of the students and must not contain information related to the health status of the students or other irrelevant personal data ( for example, place and date of birth, etc.).
Both in the case of publication in the electronic registry and in the case of publication through the boards displayed on the school bulletin board, the school director defines the maximum publication time, which in no case should exceed the 15 days.
Are audio and video footage and recordings of lessons conducted in the context of integrated digital learning permitted? (publication date 01/12/2020)
In the context of integrated digital teaching, the teacher can make available to students, also through the platforms used for these purposes, didactic materials composed of their own video lessons, on specific topics, for consultation and insights needed by students. .
Otherwise, video recording of the remote lesson in which the class dynamics is manifested is not allowed. This is because the use of platforms must be functional to recreate the “virtual space” in which the relationship and interaction between the teacher and students is expressed, not very different from what happens in face-to-face lessons (see FAQ of the Guarantor “School and privacy” at www.gpdp.it; see also the section dedicated to “The use of tools and data protection” of the aforementioned “Guidelines on integrated digital education and privacy protection: general indications”).
It is also recommended that measures be taken to minimize the risks derived from improper use or loss of control of the materials and video lessons made available by teachers on the platform, with possible damage to data protection and other rights (eg .. copyright). In particular, it is advisable to regulate the functionality of recording and downloading audio and video of the related documents and to provide specific instructions to the persons authorized to access (students, other teachers, other school personnel) to prevent the materials from being communicated or disseminated . improper (for example, also publishing them on blogs or social networks, in cases where they are accessible both by specific subjects and by anyone)
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