With virtual learning, the need for adherence to strong student safety standards and controls is paramount. Virtus and similar safety trainings are primarily geared towards in-person interactions. Following the USCCB's guidance, and with input from schools we recommend the following:

Communication with Students

• Teachers and students communicate using school-provided devices and school email addresses.

  • Faculty/staff should not be in contact with students via personal email or social networking sites.

• All teachers should be using the same video conferencing platform to communicate with students

  • CTK IT will be conducting logging and reporting

• Faculty/Staff should exercise the utmost professionalism and good judgement when chatting or video conferencing with students.

• Consider the language used when contacting students and always assume that what you write in a communication with a student will be shared with others.

• The school should be aware of every tool a teacher is using that allows student / teacher interactions

• Any 1:1 video interaction between a student & teacher should be recorded and archived

• If schools are providing “live” lessons or daily/weekly check-ins, expect adherence to communicated norms and protocols. At this time CTK does not recommend faculty / staff to record "live" lessons. Asynchronous lecture material may be recorded for reference / delivery of instruction.

  • If possible, another teacher or an administrator should join the Zoom/Google classroom as a “co-teacher.”

Conduct & Decorum

• All applicable Employee Handbook provisions for faculty remain in effect while engaged in online learning.

• All expectations for professional conduct outlined in the school’s handbook or teacher contract are in effect when instruction or communication is conducted through an online platform. These expectations include the guidance from the USCCB regarding safe school environments.

• Schools should establish norms/protocols for Virtual Learning and support sessions. (see CRNYC slide) Significant issues with adherence to established school norms for virtual learning/communication need to be addressed by school administration.

• Faculty/staff should not have pornography, inappropriate games, gambling apps, or any personal content that is not lesson-related on their computers and should not share these materials with students. (This seems obvious but needs to be stated.)

• Virtual clubs facilitated by the school need to be monitored by school personnel.

Student to Student Interactions

• All applicable student handbook policies remain in effect for students

• Student interactions should be respectful and in accordance with school guidelines

• Students should only use school-provided accounts (email, Google Meet, etc.) for interacting with teachers and other students within an academic context

• All student to student (within the academic context) interactions, and student / teacher communications must take place within a school-authorized / administrated platform

Additional Considerations

• Students using school-provided devices should know that the device is to be used for appropriate school activities

• Parents will be notified of all student expectations

• Counselors/Academic Support Personnel: maintain a log of all sessions with students that includes the date/time/duration of contact and the main topic of discussion. This log should be accessible by appropriate school administration.

• Counselors and academic support personnel should not be communicating with students using personal cell phones or home phones. If use of a personal cell phone is the only option for contacting students, consider the use of Google Voice or Dialpad as it provides students with a secondary call-in number that is connected to the counselor’s phone.

• Many schools have developed a counseling newsletter that is distributed to all students and provides general recommendations for health and safety and resources for students and their families.

• Additional resource that provide guidance and expectations related to virtual counseling:

  • The School Counselor and Virtual School Counseling

CIPA - Children's Internet Protection Act

CIPA requires that schools have an internet safety policy that provides the following measures:

• Student internet access is filtered for obscene and harmful content

• Online activities of minors are monitored by the school

• The school provides education to minors on appropriate online behavior and cyber-bullying

CIPA is required for schools receiving e-rate discounts / funds for categories beyond telecommunications services only.

Source: CIPA Guidance from the FCC; USAC; E-Rate Policy Primer

Filtering Off-Campus

Are off-campus hotspots filtered?

Yes, CTK provided hospots have been configured to use a public DNS filtering solution.

Are off-campus Chromebooks fileted?

Yes, we have Seculry set in place for our student safety.

FERPA - Family Educational Rights and Privacy Act

"The Family Educational Rights and Privacy Act (FERPA) is a federal law that affords parents the right to have access to their children’s education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records. When a student turns 18 years old, or enters a postsecondary institution at any age, the rights under FERPA transfer from the parents to the student (“eligible student”). The FERPA statute is found at 20 U.S.C. § 1232g and the FERPA regulations are found at 34 CFR Part 99. " - DoE Student Privacy Policy Office

Does FERPA Apply to Cristo Rey Schools?

Yes, CTK receives Title funds from the DoE, and so FERPA applies to the school. FERPA applies to any school receiving federal funds from a Federal Department of Education program. Most private schools do not receive Department of Education funds, so they are exempt from FERPA. E-Rate is administered by the Federal Communications Commission and does not trigger FERPA compliance. Source: Department of Education

FERPA and COVID-19

The Department of Education has released this FAQ covering topics such as:

• Information disclosure guidance if a student is diagnosed with COVID-19

• Parental Consent

• Maintaining a record of information disclosures

FERPA and Virtual Learning

The Student Privacy Policy Office (of the DoE) has released the following guidance. Notable takeaways:

• On students, video conferencing, and PII disclosure concerns:
  "Under FERPA, the determination of who can observe a virtual classroom, similar to an in-person classroom, is a local school decision as teachers generally do not disclose personally identifiable information from a student’s education record during classroom instruction. FERPA neither requires nor prohibits individuals from observing a classroom."

• Photos and Videos under FERPA

Additional Guidance

The DoE has released a Powerpoint that addresses FERPA and online learning in more detail:

COPPA - Children's Online Privacy Protection Act

COPPA applies to children younger than 13, and should not apply to any Cristo Rey schools.

HIPAA - Health Insurance Portability and Accountability Act

In most cases, HIPAA does not apply to schools for a variety of reasons. If a school is covered by FERPA, most student health information is considered an educational record, and FERPA applies, rather than HIPAA. For more information, see "Joint Guidance on the Application FERPA and HIPAA to Student Health Records" from the Department of Health & Human Services and the Dept. of Education.

G-Suite

Google's GSuite for Education core services (including Google Meet) are FERPA-compliant.

• Google Cloud Security and Compliance

• GSuite for Education Terms

Office 365

Microsoft Office 365 and its services (Microsoft Teams for Education) is FERPA-compliant.

• Microsoft FERPA Compliance

Zoom

Zoom's Privacy Policy for K-12 ; Rolling Out Zoom

We've rolled up all the Zoom information into a page, since there are so many questions and issues to be aware of.