The Enlarged City School District of Middletown is committed to protecting the privacy and security of student, teacher, and principal data. In accordance with the New York Education Law 2-d and its implementing regulations, the District informs the school community of the following:
- A student's personally identifiable information cannot be sold or released for any commercial
- Parents have the right to inspect and review the complete contents of their child's education record.
- State and federal laws protect the confidentiality of personally identifiable information, and safeguards associated with industry standards and best practices, including but not limited to encryption, firewalls, and password protection, must be in place when data is stored or transferred.
- A complete list of all student data elements collected by New York State is available for public review at the following website: NYSED Student Data Inventory or by writing to the Office of Information and Reporting Services, New York State Education Department, Room 865 EBA, 89 Washington Avenue, Albany, New York 12234.
- Parents have the right to submit complaints about possible breaches of student data Complaints should be directed in writing to The Enlarged City School District of Middletown Data Privacy Officer, 223 Wisner Avenue, Middletown, NY, 10940, or email dpo@ecsdm.org. Complaints may also be directed in writing to the Chief Privacy Officer, New York State Education Department, 89 Washington Avenue, Albany, New York 12234, or by using the form available at the NYSED Report an Improper Disclosure website.
Appendix
Supplemental Information Regarding Third-Party Contractors
In the course of complying with its obligations under the law and providing educational services to District residents, the Enlarged City School District of Middletown has entered into agreements with certain third-party contractors. Pursuant to these agreements, third-party contractors may have access to "student data" and/or "teacher or principal data," as those terms are defined by law and regulation.
For each contract or other written agreement that the District enters into with a third-party contractor where the third-party contractor receives student data or teacher or principal data from the District, the following supplemental information will be included with this Bill of Rights:
- The exclusive purposes for which the student data or teacher or principal data will be used by the third-party contractor, as defined in the contract;
- How the third-party contractor will ensure that the subcontractors, or other authorized persons or entities to whom the third-party contractor will disclose the student data or teacher or principal data, if any, will abide by all applicable data protection and security requirements, including but not limited to those outlined in applicable laws and regulations (e.g., FERPA; Education Law Section 2-d);
- The duration of the contract, including the contract’s expiration date, and a description of what will happen to the student data or teacher or principal data upon expiration of the contract or other written agreement (e.g., whether, when, and in what format it will be returned to the District, and/or whether, when, and how the data will be destroyed);
- If and how a parent, student, eligible student, teacher, or principal may challenge the accuracy of the student data or teacher or principal data that is collected;
- Where the student data or teacher or principal data will be stored, described in a manner as to protect data security, and the security protections taken to ensure the data will be protected and data privacy and security risks mitigated; and
- Address how the data will be protected using encryption while in motion and at rest.
Please read the Parents' Bill of Rights for Data Privacy and Security.
