School’s out for the summer — or is it?

In the hazy, lazy, remaining days of August, the last thing parents and kids want to think about is school! As a student, I remember being in denial about it right up until Labour Day weekend. Only then would my mind suddenly turn to seeing my classmates again, meeting my new teachers, deciding which activities to join or what to wear on my first day back at school. As a parent, I was similar, procrastinating for as long as I could before running those last-minute errands to get my kids’ school supplies. 

For most of us, the start of school follows the Labour Day weekend. But for many teachers and school administrators, the hard work begins much earlier. As they get ready for the new school year, they have courses to plan, classrooms to set up, and schedules to organize. 

In today’s age of digital education, educators have a whole new dimension of responsibilities they must contend with. For example, they must develop rules and policies around students’ use of cell phones and other mobile devices in the classroom. Which apps and games should they allow (or disallow) students to use and explore for school projects? 

Educators must decide whether to use digital education platforms for things such as attendance reporting, homework assignments, academic grading, and online exam proctoring. And if so, what terms and conditions will they negotiate with their service provider? School administrators may wish to consult some of our previous decisions (MC18-48, MC17-52, MC18-17 and PI- PI21-00001) on these and other related issues. Our recent guidance on contracting with third-party service providers could also be of help in navigating the complex procurement, implementation, and management of “ed tech” tools and services. 

Educators must also meet new provincial curriculum requirements for digital literacy, digital citizenship, and online safety. Our Privacy Pursuit! lesson plans can help teachers engage meaningfully on these issues with children and youth from grades 2-8. In addition, our new Youth Ambassador Toolkit can support peer-to-peer discussions among older students and help equip them with the knowledge and skills they need to understand the broader policy issues and become advocates for privacy rights within their communities.

In short, schools are in serious planning mode as they strive to protect their students’ personal information from online risks and harms to their privacy, while also empowering their students to learn to become savvy and responsible digital citizens. That might seem like a fine needle to thread: protecting students from the very technologies you want them to use. However, in discussion with others, we have given careful thought to balancing the need for protection alongside the empowerment of students, and have developed what we believe to be just the right needle threader. 

In June 2024, after an eight-month open consultation period, my office finalized the Digital Privacy Charter for Ontario Schools as part of our strategic priority work on Children and Youth in a Digital World. The digital charter contains twelve commitments for schools and school boards to adopt. For example:

• limiting collection, use, and disclosure of students’ personal information to only what’s necessary for discharging responsibilities as educators 
• requiring strong privacy protections when engaging third-party providers of digital education tools and services
• explaining what type of personal information is collected and the purposes for which it is used or shared with others in a way that is easy for students, parents, and guardians to understand
• providing guidance to students on how to protect their own personal information; and
• supporting continual awareness of evolving risks and ongoing learning about privacy in the digital environment 

While signing on in support of the digital charter is voluntary, the twelve commitments reflect already-existing legal obligations or best practices for how schools and school boards can meet those legal obligations. These commitments also align directly with the government’s stated intention to strengthen safeguards for children’s personal information in schools.  

With the tabling of Bill 194: Strengthening Cyber Security and Building Trust in the Public Sector Act, schools should already be preparing to meet higher standards and obligations regarding the types of digital technologies they make available to children and youth under the age of eighteen, and how they collect, use, and disclose personal information using these technologies. Much of the detailed content of Bill 194 has yet to be developed through regulations. 

While we may not yet know the details of what those regulations will look like or when they will take effect, we certainly know which way the wind is blowing. The digital charter provides a blueprint for schools and school boards to begin aligning with this new direction.

As schools and school boards prepare for the new school year, they have a remarkable opportunity to show leadership by stepping up to the charter commitments. By adopting the digital charter, schools and school boards can proactively demonstrate just how serious they are about protecting privacy and empowering the next generation of digital citizens. Most importantly, they can secure the respect and confidence of their students, parents and communities, and nurture a positive and trusting learning environment. 

As Bill 194 makes its way through the legislature, and the government makes plans to strengthen privacy protection for children and youth, I urge all Ontario schools and school boards to heed one of the most important life lessons they teach their students — prepare well in advance and avoid waiting until the last minute. 

Sign on to the digital charter and show your commitment to doing the right thing now, to avoid the frantic scramble come exam time.

— Patricia