BILL ANALYSIS                                                                                                                                                                                                    �





                                          
                           SENATE COMMITTEE ON EDUCATION
                                  Carol Liu, Chair
                              2013-14 Regular Session
                                          

          BILL NO:       AB 1442
          AUTHOR:        Gatto
          AMENDED:       June 5, 2014
          FISCAL COMM:   No             HEARING DATE:  June 11, 2014
          URGENCY:       No             CONSULTANT:Lenin Del Castillo

           NOTE  :  This bill has been referred to the Committees on  
                    Education and 
          Judiciary.  A "do pass" motion should include referral to the  
                    Committee 
          on Judiciary.  

           SUBJECT  :  Pupil records:  social media.
          
           SUMMARY   

          This bill requires a local education agency (LEA) that  
          considers a program to gather or maintain in its records any  
          personal information obtained from social media of any enrolled  
          pupil to notify pupils and their parents about the proposed  
          program. 

           BACKGROUND  

          Current law authorizes schools to suspend or recommend for  
          expulsion a student who engages in an act of bullying, which is  
          defined as any severe or pervasive physical or verbal act or  
          conduct, including communications made in writing or by means  
          of an electronic act, directed toward one or more students that  
          has or can be reasonably predicted to have the effect of one or  
          more of the following:

          1)   Placing a reasonable student or students in fear of harm  
               to that student's or those students' person or property.

          2)   Causing a reasonable student to experience a substantially  
               detrimental effect on his or her physical or mental  
               health.

          3)   Causing a reasonable student to experience substantial  







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               interference with his or her academic performance.

          4)   Causing a reasonable student to experience substantial  
               interference with his or her ability to participate in or  
               benefit from the services, activities, or privileges  
               provided by a school.  (EC � 48900(r)(1))

          Current law defines "electronic act" as the creation and  
          transmission, originated on or off the schoolsite, by means of  
          an electronic device, including but not limited to a telephone,  
          wireless telephone, or other wireless communication device,  
          computer, or pager, of a communication, including but not  
          limited to any of the following:


          1)   A message, text, sounds, or image.

          2)   A post on a social network website including, but not  
               limited to:

               a)        Posting to or creating a burn page, as defined,  
                    created for the purpose of having one or more of the  
                    effects listed above.

               b)        Creating a credible impersonation of another  
                    actual student, as defined, for the purpose of having  
                    one or more of the effects listed above.

               c)        Creating a false profile, as defined, for the  
                    purpose of having one or more of the effects listed  
                    above.  (EC � 48900(r)(2))

          Current law prohibits a student from being suspended or  
          expelled unless the act is related to a school activity or  
          school attendance.  Schools are specifically authorized to  
          suspend or expel a student for acts that are related to a  
          school activity or school attendance that occur at any time,  
          including but not limited to:

          1)   While on school grounds.

          2)   While going to or coming from school.







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          3)   During the lunch period whether on or off the campus.

          4)   During, or while going to or coming from, a  
               school-sponsored activity.  
               (EC � 48900(s))

          Current law prohibits a school district from permitting access  
          to student records to any person without written parental  
          consent or pursuant to a judicial order except as set forth in  
          the federal Family Educational Rights and Privacy Act (FERPA).   
          Access to those particular records relevant to the legitimate  
          educational interests of the requester shall be permitted to  
          specific requesters, including, but not limited to, school  
          officials, employees of the district, members of a school  
          attendance review board and officials and employees of other  
          public schools where the pupil intends to or is enrolled.   
          (Education Code � 49076)

          The federal Family Educational Rights and Privacy Act (FERPA)  
          is intended to protect the privacy of student education  
          records.  It applies to all schools that receive funds under an  
          applicable program of the U.S. Department of Education.   
          Generally, schools must have written permission from the parent  
          or eligible student in order to release any information from a  
          student's education record.  However, FERPA allows schools to  
          disclose those records, without consent, to the following  
          parties or under the following conditions:

             1)   School officials with legitimate educational interest;

             2)   Other schools to which a student is transferring;

             3)   Specified officials for audit or evaluation purposes;

             4)   Appropriate parties in connection with financial aid to  
               a student;

             5)   Organizations conducting certain studies for or on  
               behalf of the school;

             6)   Accrediting organizations;







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             7)   To comply with a judicial order or lawfully issued  
               subpoena; 

             8)   Appropriate officials in cases of health and safety  
               emergencies; and

             9)   State and local authorities, within a juvenile justice  
               system, pursuant to specific State law.

          Schools may disclose, without consent, "directory" information  
          such as a student's name, address, telephone number, and date  
          and place of birth.  However, schools must tell parents and  
          eligible students about directory information and allow them a  
          reasonable amount of time to request that the school not  
          disclose such information.  Schools must also notify parents  
          and eligible students annually of their rights under FERPA.   
          (20 U.S.C. Section 1232g; 34 CFR Part 99)

           ANALYSIS 

          This bill: 

             1)   Requires a school district, county office of education,  
               or charter school (LEA) that considers a program to gather  
               or maintain in its records any personal information  
               obtained from social media of any enrolled pupil to notify  
               pupils and their parents or guardians about the proposed  
               program and provide an opportunity for public comment at a  
               regularly scheduled public meeting before adoption of the  
               program, as specified.

             2)   Requires an LEA that adopts a program to do all of the  
               following:

                 a)       Gather or maintain only information that was  
                   made publicly accessible, which shall not include  
                   either of the following:

                    i)             Information that the LEA knows or has  
                         reason to believe was reposted or otherwise made  
                         publicly accessible by another party without the  







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                         express consent of the original author.
                    ii)            Any secondary information, including,  
                         but not limited to, geolocation information,  
                         derived from content posted to social media,  
                         unless that secondary information was  
                         intentionally made publicly accessible or unless  
                         the LEA has obtained consent from an eligible  
                         pupil or parent or guardian.

                 b)       Provide a pupil with access to any personal  
                   information about the pupil gathered or maintained by  
                   the school district, county office of education, or  
                   charter school (LEA) that was obtained from social  
                   media, and an opportunity to correct or delete  
                   information that was gathered or maintained in  
                   violation, as specified. 

                 c)       Destroy personal information gathered from  
                   social media and maintained in its records within one  
                   year after a pupil turns 18 years of age or within one  
                   year after the pupil is no longer enrolled in the LEA,  
                   whichever occurs first.

                 d)       Notify each parent or guardian of a pupil  
                   subject to the program that the pupils personal  
                   information is being gathered from social media and  
                   that any information subject to the bill's provisions  
                   that is maintained in the LEA's records with regard to  
                   the pupil shall be destroyed, as specified.  Provides  
                   that the notification contain explanations regarding  
                   the process by which a pupil or a pupils parent may  
                   access and request removal of personal information, as  
                   specified.

          1)   Provides that if the LEA contracts with a third party to  
               gather personal information from social media on an  
               enrolled pupil, the contract shall do all of the  
               following:

               a)        Prohibit the third party from using the  
                    information for its own purposes.








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               b)        Prohibit the third party from selling or sharing  
                    the information with any person or entity other than  
                    the LEA.

               c)        Require the third party to destroy the  
                    information immediately upon satisfying the terms of  
                    the contract, within one year after a pupil turns 18  
                    years of age, or within one year after the pupil is  
                    no longer enrolled in the LEA, whichever occurs  
                    first. 

          2)   Defines eligible pupil as any pupil 18 years of age or  
               older.

          3)   Defines school purposes as those that customarily take  
               place at the direction of a school, teacher, school  
               district, county office of education, or charter school or  
               aid in the administration of school activities, including,  
               but not limited to, instruction in the classroom or at  
               home, administrative activities, or collaboration between  
               pupils, school personnel, and parents or guardians.

          4)   Defines social media as an electronic service or account,  
               or electronic content, including, but not limited to,  
               videos, still photographs, blogs, video blogs, podcasts,  
               instant and text messages, email, online services or  
               accounts, or Internet Web site profiles or locations.   
               Provides that social media shall not include an electronic  
               service or account used exclusively for school purposes.

          5)   Defines publicly accessible as anything posted on social  
               media or any other Internet Web site that is accessible to  
               the general public.  Provides that publicly accessible  
               does not include anything posted on social media or any  
               other Internet Web site that is only accessible to a  
               restricted group of persons.

           STAFF COMMENTS  

              1)   Need for the bill  .  According to the author's office,  
               the number of social media platforms that students have  
               access to such as Facebook, Twitter, and Instagram has  







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               never been greater.  And while social media outlets  
               provide numerous opportunities for networking, keeping in  
               touch, information sharing and self-expression, they also  
               deliver platforms for questionable behavior such as  
               cyber-bullying, hate speech, and self-destructive  
               language.  In recent years, students, parents, and the  
               general public have had to confront the increasing  
               incidence of cyber-bullying or the use of electronic media  
               to harass, intimidate, or terrorize another student.  As a  
               result, existing law now allows a student to be suspended  
               or recommended for expulsion for bullying by means of an  
               electronic act.  

               Some school districts have also elected to monitor the  
               social media activities of their pupils as a means for  
               early discovery and intervention to prevent incidences of  
               cyber-bullying from escalating to something more serious  
               such as violence or personal injury.  Specifically, the  
               Glendale Unified School District contracted with a social  
               media monitoring service that mines publicly available  
               information from students' accounts that might suggest the  
               need for an intervention, such as suicidal thoughts,  
               bullying, or vandalism and provides daily reports to  
               school administrators.

               According to the author's office, some students and  
               parents feel that this data collection constitutes an  
               inappropriate intrusion into their off campus lives.  In  
               addition, they indicate that pictures and texts posted by  
               still-young and impressionable students have the potential  
               to be stored by private companies, only to be released  
               later in ways that could haunt them in their adult lives.   
               This bill is intended to address those concerns by  
               imposing restrictions on the use of information obtained  
               from social media by local education agencies and their  
               contractors.

              2)   New era of digital technology  .  Recent advances in  
               technology have changed the landscape of education in  
               schools and have resulted in the expansion of student  
               data.  School districts are increasingly integrating the  
               use of computers and tablets in the classroom to instantly  







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               deliver personalized content, employ virtual forums for  
               interacting with other students and teachers, and utilize  
               other interactive technologies to enhance student  
               learning.  These technologies, which may be provided  
               directly by school districts and through the use of  
               private contractors and subcontractors, have the potential  
               to transform the classroom and learning processes.  Online  
               forums are used to assist teachers with sharing lesson  
               plans and web-based applications help teachers with  
               customized learning experiences for individual students.   
               With access to personal student level education records,  
               these new technologies raise questions concerning the  
               security of this information.    

              3)   Protecting student privacy  .  Because there may be  
               potential risks to student privacy resulting from the use  
               of technology for student learning, there have been  
               numerous pieces of legislation seeking to protect student  
               personal information.  Last year, SB 568 (Steinberg),  
               Chapter 336, Statutes of 2013, was enacted and prohibits  
               website operators from sending advertisements to minors  
               for products that they were not old enough to legally use  
               or purchase.  Additionally, as a follow up to SB 568 from  
               2013, SB 1177 (Steinberg) currently seeks to prohibit K-12  
               online educational sites from compiling, sharing, or  
               disclosing student information.  Another bill, AB 1584  
               (Buchanan) proposes certain student privacy assurances  
               that school districts must include in any contracts they  
               enter into with contractors regarding the digital  
               management of pupil records.
                  
               There may very well be benefits to social media  
               monitoring, especially if it is found to be an effective  
               tool of intervention and allows a school to identify  
               instances where a student is at risk of harming him or  
               herself or others.    However, it is unclear if these  
               benefits outweigh any privacy risks that they may pose,  
               especially if students and parents are unaware that such  
               social monitoring is taking place.  It is important to  
               note that this bill would not prevent school districts  
               from contracting with a third-party for social media  
               monitoring services.  It would require school districts to  







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               notify students and their parents if they are considering  
               such a program.  As a point of clarification that the  
               author may wish to address as the bill moves forward, if  
               there is public comment from a student, parent, or the  
               community objecting to the school district's proposed use  
               of a social media monitoring program, what course of  
               action would a school district be required to take, if  
               any?  Are the objections binding?  In other words, could  
               the bill be interpreted to prohibit a school district from  
               establishing a program if objections are raised?   

              4)   Related and prior legislation  .  

               Senate Bill 1177 (Steinberg) prohibits K-12 online  
               educational sites, services, and applications from  
               compiling, sharing, or disclosing student personal  
               information and from facilitating, marketing, or  
               advertising to K-12 students.  This bill is pending before  
               the Assembly Education Committee.

               AB 1584 (Buchanan) requires a local educational agency  
               that elects to enter into a contract with a third-party  
               for the purpose of providing digital management of pupil  
               records to include specific assurances in those contracts  
               that are intended to protect the privacy of student  
               information.  This bill is also scheduled to be heard by  
               the Senate Education Committee on June 11, 2014.

           SUPPORT
           
          American Civil Liberties Union
          Privacy Rights Clearinghouse

           OPPOSITION
           
          Capitol Resource Institute













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