BILL ANALYSIS                                                                                                                                                                                                    �



                                                                            



           ----------------------------------------------------------------- 
          |SENATE RULES COMMITTEE            |                       SB 1177|
          |Office of Senate Floor Analyses   |                              |
          |1020 N Street, Suite 524          |                              |
          |(916) 651-1520         Fax: (916) |                              |
          |327-4478                          |                              |
           ----------------------------------------------------------------- 
           
                                           
                                       CONSENT


          Bill No:  SB 1177
          Author:   Steinberg (D)
          Amended:  4/21/14
          Vote:     21

           
           SENATE EDUCATION COMMITTEE  :  9-0, 3/26/14
          AYES:  Liu, Wyland, Block, Correa, Galgiani, Hancock, Hueso,  
            Huff, Monning

           SENATE JUDICIARY COMMITTEE  :  7-0, 4/29/14
          AYES:  Jackson, Anderson, Corbett, Lara, Leno, Monning, Vidak


           SUBJECT  :    Student Online Personal Information Protection Act

           SOURCE  :     Author


           DIGEST  :    This bill 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, as specified.  This  
          bill also requires an operator of an Internet Web site, online  
          service, online application, or mobile application with actual  
          knowledge that the site, service, or application is used for  
          K-12 school purposes and was designed and marketed for K-12  
          school purposes to ensure that encryption processes are used,  
          and to delete a student's personal information under specified  
          circumstances.

           ANALYSIS  :    Existing law provides that, among other rights, all  
          people have an inalienable right to pursue and obtain privacy.
                                                                CONTINUED





                                                                    SB 1177
                                                                     Page  
          2

           
          Existing law also allows a person to bring an action in tort for  
          an invasion of privacy and provides that in order to state a  
          claim for violation of the constitutional right to privacy, the  
          following three elements must be established:

          1.Legally protected privacy interest.
          2.Reasonable expectation of privacy in the circumstances.
          3.Conduct by the defendant that constitutes a serious invasion  
            of privacy.

          Existing law provides that there is no reasonable expectation of  
          privacy in information posted on an Internet Web site.   
          Additionally, federal law requires an operator on an Internet  
          Web site or online service that has actual knowledge that it is  
          collecting personal information from a child to provide notice  
          of what information is being collected and how that information  
          is being used, and to give the parents of the child the  
          opportunity to refuse to permit the operator's further  
          collection of information from the child.
           
          Existing law requires an operator of a commercial Web site or  
          online service that collects personally identifiable information  
          through the Internet about individual consumers residing in  
          California who use or visit its Web site to conspicuously post  
          its privacy policy.
           
          Existing federal law makes it unlawful for an operator of a Web  
          site or online service directed to children under the age of 13  
          to collect personal information from a child, including a  
          child's first and last name, home or other physical address  
          including street name and name of a city or town, e-mail  
          address, telephone number, or Social Security number.
           
          The Family Educational Rights and Privacy Act (Act) protects 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, the Act allows schools to disclose those records,  
          without consent, to the following parties or under the following  
          conditions:


                                                                CONTINUED





                                                                    SB 1177
                                                                     Page  
          3

          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.
          7.To comply with a judicial order or lawfully issued subpoena.
          8.Appropriate officials in cases of health and safety  
            emergencies.
          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 Act.

          This bill: 

           1. Requires an operator of an Internet Web site, online  
             service, online application, or mobile application used for  
             and designed and marketed for K-12 school purposes to comply  
             with all of the following:

             A.   It shall not use, share, disclose, or compile personal  
               information about a K-12 student for any purpose other than  
               the K-12 school purpose and for maintaining the integrity  
               of the site, service, or application.

             B.   It shall not use, share, disclose, or compile a  
               student's personal information for any commercial purpose,  
               including, but not limited to, advertising or profiling.

             C.   It shall not allow, facilitate, or aid in the marketing  
               or advertising of a product or service to a K-12 student on  
               the site, service, or application.

             D.   It shall take reasonable steps to protect the personal  
               information data at rest and in motion in a manner that  

                                                                CONTINUED





                                                                    SB 1177
                                                                     Page  
          4

               meets or exceeds reasonable and appropriate commercial best  
               practices.  An operator shall be deemed to be in compliance  
               with this paragraph if the operator ensures valid  
               encryption processes for data at rest and for data in  
               motion, as specified.

           1. Requires an operator to delete a student's personal  
             information if any of the following occurs:

             A.   The site, service, or application has actual knowledge  
               that it is no longer used for K-12 school purposes, unless  
               the information is being used or maintained at the  
               direction of a school or school district and is under the  
               direct control of the school or district.

             B.   The student requests deletion, unless it is being used  
               at the direction of a school or district for legitimate  
               educational purposes and is under the control of the school  
               or district.

             C.   The school or school district requests deletion.

           1. Provides that an operator may disclose personal information  
             of a student if other provisions of federal or state law  
             require the operator to disclose the information, and the  
             operator complies with the requirements of federal and state  
             law in protecting and disclosing that information.

           2. Provides that an "online service" includes cloud computing  
             services.

           3. Provides that an operator of an Internet Web site, online  
             service, online application, or mobile application used for  
             and designed and marketed for 
           K-12 school purposes may disclose personal information of a  
             student for legitimate research purposes as required by state  
             and federal law and subject to the restrictions under state  
             and federal law, as specified.  

           4. Defines "personal information" as any information or  
             materials in any media or format created or provided by a  
             student or the student's parent or legal guardian, as  
             specified.


                                                                CONTINUED





                                                                    SB 1177
                                                                     Page  
          5

           5. Provides that "K-12 school purposes" if defined as purposes  
             that customarily take place at the direction of the school,  
             teacher, or school district or aid in the administration of  
             school activities, including, but not limited to, instruction  
             in the classroom or at home, administrative activities, and  
             collaboration between students, school personnel, or parents,  
             or are for the use and benefit of the school.

           6. Provides that these provisions shall not be construed to  
             limit the authority of a law enforcement agency to obtain any  
             content or information from an operator as authorized by law  
             or pursuant to an order of a court of competent jurisdiction.  


           7. Provides that it is not the intent of the Legislature for  
             this chapter to apply to general audience Internet Web sites  
             and not to limit internet service providers from providing  
             internet connectivity to schools or students and their  
             families.

           8. Provides that the provisions of the bill are severable, as  
             specified.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No   Local:  
           No

           SUPPORT  :   (Verified  5/1/14)

          California Federation of Teachers
          California State PTA
          Common Sense Media
          Klaas Kids Foundation
          Privacy Rights Clearinghouse
          Services Employees International Union


          PQ:nl  5/1/14   Senate Floor Analyses 

                           SUPPORT/OPPOSITION:  SEE ABOVE

                                   ****  END  ****




                                                                CONTINUED





                                                                    SB 1177
                                                                     Page  
          6














































                                                                CONTINUED