FPF Letter to Senate on School Safety

This week, the Future of Privacy Forum (FPF) sent a letter to the Senate Homeland Security & Governmental Affairs Committee in advance of today’s hearing “Examining State and Federal Recommendations for Enhancing School Safety Against Targeted Violence.” FPF’s letter focused on three key points:

• Students deserve safety measures that are evidence-based. Decisions about threats should be made by, among others, school administrators, counselors, and educators who understand students’ particular needs and circumstances. Non-evidence based protocols are more likely to trigger false alarms, fail to identify actual threats, and increase the workload on already overburdened administrators—administrators who could otherwise be doing things that actually make schools safer. And there is a model on how to do this: Utah’s 2019 school safety law found ways to bake-in evidence-based policies and privacy guardrails without hindering school safety.
• Increased surveillance and data sharing without clear justification frequently overwhelms administrators with information, undermines effective learning environments, increases inequities, and can fail to promptly identify individuals who may pose genuine threats to school safety. In particular, overbroad school surveillance programs can place important data-driven school initiatives at risk: data collected to help ensure students are treated equitably under the Every Student Succeeds Act, for example, should not be repurposed in the name of school safety to harm or stigmatize those students.
• Even when policies are evidence-based and don’t repurpose sensitive data in ways that break trust, without sufficient privacy and equity guardrails, certain information collected for school surveillance purposes will disadvantage particular minority groups. School safety policies must be created in an evidence-based way that avoids creating a disparate impact on vulnerable communities.

FPF invited the committee to seek answers about how privacy and equity guardrails are or are not being incorporated into state and local school safety initiatives. Prior to implementing school safety programs, officials ought to 1) find and analyze the best available evidence to inform policy; 2) perform privacy impact assessments, commonly-used and established processes for ensuring the appropriate balance between the benefits and risks of data collection and use initiatives, particularly as they related to already vulnerable communities; and 3) transparently engage with all stakeholders, including parents, students, and educators.

Read the full letter here.