We were all deeply disturbed when we learned last week that JFC voted 8-7 to fund the Statewide Student Information System (SSIS). At the very same time that the legislature is considering data privacy measures, it is essentially funding the construction of the machine that will make data mining possible. Though painted as an information resource for parents and teachers, the SSIS has ties into Department of Workforce Development, the University of Wisconsin System, the Technical College System, Department of Health, and many other systems throughout the state. DPI will warehouse personally identifiable information for all the students in the state and link it to various other state agencies.
While it’s true that many people with access to this system will not be able to personally identify students using the system and will only view statistical information, nonetheless, full, personally identifiable information is retained centrally by the SSIS at DPI. This is the machine by which data mining can occur. It would only take a small change the the law, or the interpretation of the law, and data could flow to third parties and the federal government.
Some of those legislators have said not to worry, that bills are being introduced in the assembly will protect our children, ensuring that their data remains private. Indeed Assembly Bill 618 prohibits contractors, consultants and volunteers from viewing personally identifiable information. That is important, because recently the United States Department of Education has reinterpreted the FERPA laws to allow such people and even corporations to access personally identifiable information. AB618 also prohibits sharing data with the Federal Government. However, AB 618 also supports setting up the linkages between state agencies, DPI, the University and Technical College system, and local school districts to build the SSIS. So, the we’re essentially building the machine to hold massive amounts of student information centrally. Any agency which the state sees fit to deem in need of such information, will ultimately be linked into the SSIS or Longitudinal Data system.
Limiting who can see student information and prohibiting sharing of such information with the Federal government is great. However, building a centralized system to hold all the information and encouraging sharing of such information among many state agencies at the same time is counterproductive. We should be looking to defund the SSIS and prohibit the sharing of personally identifiable information from school districts with any state agency, including DPI, without explicit parental consent. There is absolutely no need for the State to get between parents, students and their teachers and any bill that purports to support data privacy should not countenance the building of a system that enables the exploitation of personal data.