OVIC examination into Victorian primary schools use of digital learning tools

By Annan Boag, Assistant Commissioner Privacy and Assurance

OVIC recently completed an examination of the use of apps and web-based learning tools in Victorian government primary schools.

The purpose of the examination was to help OVIC and the Victorian community better understand what digital tools are used in primary schools in Victoria, and how privacy risks are identified and addressed when those tools are selected.

We started the examination prior to COVID-19 restrictions and the move to remote learning in Victoria. Even before the move to remote learning, it was clear that digital tools were an important feature of students’ everyday classroom life.

Numerous apps and web-based tools were used by students in the schools that we examined. Our examination identified challenges for the Department of Education (DET) and for schools in identifying the privacy implications of using these tools and communicating this to parents and carers.

This post summarises some of the main things we learnt during the examination.

1. Primary schools choose which apps and web-based learning tools to use in their schools

Apps and web-based tools are used widely in Victorian government primary schools. They are generally used for four main purposes:

• Teaching and learning;
• Communicating with parents and carers;
• Assisting teachers to plan and share resources; and
• Assessing students against school curriculum.

DET is responsible for managing Victorian government schools. DET purchases licences for some tools in bulk and offers them to schools. However, in addition to this, schools are free to choose other tools that suit the needs of the children at their school. Decisions about which apps and tools will be used by each year level is usually decided and approved within a school prior to the start of the school year. Examples of the tools used by primary schools in Victoria are listed in the examination report.

2. Schools have difficulty assessing the privacy risks for all the digital learning tools they use

Making sure children’s personal information is protected is a complex challenge that needs to be addressed. This is especially important as Victorian schools are currently relying on online teaching and digital learning tools during the Covid-19 pandemic.

OVIC’s examination revealed that schools are dealing with competing demands, which make it difficult for them to complete a Privacy Impact Assessment (PIA) for every app or tool they consider using. A PIA document is a thorough assessment of the privacy risks posed by a project.

DET told OVIC that it sees its role in ensuring schools handle personal information appropriately as key. In the past 12 months DET has revised its PIA template to better assist schools to carry out this risk assessment process and put more resources into privacy support for schools.

For guidance on the use of digital learning tools in Victorian government schools, see DET’s Being online at home – tips for parents and carers.

3. Managing privacy risks is a shared responsibility

There are several parties involved in the protection of primary school aged children’s information privacy including

• DET;
• schools; and
• parents and carers.

DET assesses the privacy risks of the apps they provide to schools. DET also provides guidance and training to schools about privacy.

Schools are responsible for assessing the privacy risk of apps considered for use that are not on DET’s list of provided apps and tools. Schools are also responsible for sending parents and carers information notices and opt out forms where these are required.

Parents and carers are responsible for considering the information provided to them by schools and deciding whether to opt out of services where this is an option. Parents and carers also have an important role in educating their children about privacy and protecting themselves online.

For more information about helping children have safe experiences online, see the Office of the Australian Information Commissioner’s guidance on privacy tips for parents and carers or the Australian eSafety Commissioner’s website.