Persónuvernd og stafrænt skólastarf

Til að tryggja öryggi barna og unglinga þarf að vanda val á stafrænni tækni sem nýta á í skólastarfi.

Reykjavíkurborg hefur sett sér persónuverndarstefnu byggða á persónuverndarlögum. Skólastjóri ber ábyrgð á notkun stafrænnar tækni í skólastarfi ásamt því að sinna upplýsingaskyldu gagnvart foreldrum. 

Góð stafræn borgaravitund felst meðal annars í því að koma vel fram hvert við annað í netheimum sem og í raunheimum.

Persónuvernd fræðsluerindi

Fimmtudaginn 19. maí 2022 var Steinunn Birna Magnúsdóttir, lögfræðingur og verkefnastjóri í málefnum barna hjá Persónuvernd, með fræðsluerindi um persónuvernd. Fræðsluerindið var í tveimur hlutum og er upptökurnar að finna hér fyrir neðan. 

Processing Personal Information in Cromebook

When using Cromebook, hereafter device, students´personal information is processed.

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How do we ensure the security of personal data?

The City of Reykjavik and the primary schools safeguard personal data through appropriate organizational and technical measures, including access controls.

The above processing of personal data has undergone a risk assessment and a Privacy Impact Assessment (PIA).

Privacy Policy

The City of Reykjavik stresses the importance of ensuring that all processing of personal data within the municipality is carried out in accordance with the provisions of the privacy legislation as well as the policies of the City’s departments and central administration. The Policy applies to all processing of personal data by the City, including activities on the City's councils and committees, as well as those activities where third parties have been entrusted with carrying out tasks on behalf of the City.

Digital Technology

The adoption of digital technologies in school and recreational settings requires a risk assessment. Due care must be given to the selection and use of software for schooling in order to ensure the safety of students.

The City of Reykjavik follows a specific procedure and software is evaluated, among other things, on:

  • Age restrictions
  • Collection of personal data
  • Whether data is stored inside or outside Europe
  • Whether ads are associated with usage
  • How to delete data and accounts at the end of schooling or when the software is no longer in use

Managers at each location are responsible for informing parents about what digital technology is used and how.

What data is processed?

Personal data that is processed:

  • Basic information about the student, their name and primary school.
  • Basic information about parents when they are asked to confirm terms of use on their devices.
  • The devices have a camera and a microphone. The camera comes with a shutter that blocks out the camera. The microphone is generally turned off, but can be turned off manually by going to the device settings.
  • In general, location data is not collected. The location of the device can be traced if it is lost or stolen, but otherwise that information is not collected. It is also possible to view which user last logged in to a tablet and on which IP address. If a device is lost or stolen, the device is locked and information is deleted from the device within a specified time limit.
Sensitive personal data is not processed on the devices.

Where does the information come from?

Access information from the devices comes from the student account for Gschool created by the primary school based on the basic information on the student at the school. A student may enter personal information on the device, but teachers will implore students not to enter personal information on the device in accordance with the device terms of use and education to parents and students.

Basic parental information is obtained from Mentor/Namfus to ensure parental confirmation of the terms of use on the devices.

How long is the personal data kept?

It should be pointed out that according to Act No. 77/2014 on the Public Archives, part of the documentation shall be deposited at the Reykjavik Municipal Archives as the City is an entity subject to an obligation of transfer.

Other than that, the information will be stored in Google Workspace for Education during a student's studies, and it will be deleted three months after the student has finished their studies at the school and has returned the device to the school.

Taking & Publishing Photographs

The student shall comply with the rules of the school and the City of Reykjavik as well as the national legislation on taking and publishing photographs. The taking and publishing of photographs in the City’s school and recreational activities are subject to specific guidelines.

It is important that students themselves are not the main subject of the photos and image editing is only allowed as part of project work.

Learning Devices & Privacy

Notkunarskilmálar

Parents/guardians agree to the terms and conditions for lending students Chromebooks and accessories on My Pages.

Have your electronic ID available.

Students are also considered to have accepted the terms and conditions when they login to the Chromebook for the first time. This approval is a prerequisite for a student to be allowed to take the device home.

The terms and conditions contain these important points:

  • The Chromebook is a learning device and should primarily be used for learning.
  • The student should always follow the instructions of the school staff regarding its use.
  • The device should be be brought back fully loaded and ready to work if it is taken home.
  • The Chromebook should be handled carefully and transported in a case between places.
  • Never consume food or drinks near the device.
  • The learning device may not under any circumstances be used illegally. It is forbidden to install pirated software or software that modifies its operating system and to delete data or settings from the learning device.
  • Students return the Chromebook at the end of the school year, along with other equipment, and receive it back at the beginning of the next school year.

Chromebækur

When using chromebooks, hereinafter referred to as devices, students' personal data is processed. The information is necessary so that a user account can be created for students to access the device and the software that comes with it. Then the device itself is marked with a student's first name. The child's primary school is considered to be the guarantor of the processing that the use of the chrome books entails under the provisions of the Personal Data Protection Act No. 90/2018.

The Department of Education and Recreation has assisted the city's primary schools in setting up the chromebooks and guided them in making organizational security arrangements so that the security of personal information is adequate. A privacy risk assessment and impact assessment has been carried out for this personal data processing activity.

Personal data that is processed:

  • Basic information about the parents and the student, their name and primary school.
  • The devices have a camera and a microphone. The camera comes with a shutter that blocks out the camera. The microphone is generally turned off, but can be turned off manually by going to the device settings.
  • In general, location data is not collected. The location of the device can be traced if it is lost or stolen.
    It is also possible to view which user last logged in to a tablet and on which IP address. If a device is lost or stolen, the device is locked and information is deleted from the device within a specified time limit.
  • Sensitive personal data is not processed on the devices.

Jöfn tækifæri til náms

The purpose of the project is to ensure that students have equal opportunities to study and have the opportunity to choose subjects and approaches in their own studies. Students have a solution that meets their needs and have access to a device that facilitates communication with teachers and fellow students if access to school is restricted or school is closed. As well as enabling students to participate in school despite illness. It is also important that the City of Reykjavik is able to fulfil its statutory obligations to the registered student on the right to schooling.

Vinnsla upplýsinga

The purpose of using the tool is to follow up the focus of the Primary Education Act and the Primary Education Curriculum on providing multiple pathways for knowledge acquisition through the use of technology media, information technology, and collective and documentary work. Elementary Law and Primary Curriculum pay particular attention to the intake and organization of learning in specific disciplines and explicitly specify informational and technical education there. It is also stated that students should be given equal opportunities to study and have the opportunity to choose subjects and approaches in their own studies. Students have a solution that meets their needs and have a solution that facilitates communication with teachers and fellow students if access to school is restricted or school is closed. At the same time, to enable students to participate in school despite illness. It is also important that the City of Reykjavik is able to fulfil its statutory obligations to the registered student on the right to schooling.

The legality of the processing of personal data is based on the legal obligation resting on the primary school according to the provisions of the Elementary School Law No. 91/2008 and the provisions of the Primary Curriculum established on the basis of the Primary Education Act. It is also considered that the processing of personal data in this case is necessary for the exercise of public authority exercised by the City of Reykjavik in the selection of ways of providing teaching to undergraduate students.

There will be other homeschooling options available for Chromebooks if parents don't want students to take their devices home.

Other recipients of the information are the processors responsible for setting up and operating the systems necessary for the functioning of the computers. This involves Google and Lightspeed respectively, and a processing agreement has been concluded with both of these parties. In this case, other recipients of personal data may be involved in specific software solutions/apps that may be used by the chromebooks, but parents will be educated on any such software use at that time.

Children's personal data will not be shared outside of Europe when using the chromebooks.

Andmæli vinnslu persónuupplýsinga

You may generally object to this processing of personal data.

If you object to processing, the Elementary School may not further process the personal data, unless it can demonstrate important legitimate reasons for processing that override the interests, rights and freedoms of you.

Miðlun persónuupplýsinga til þriðja aðila

After the specified time, the City of Reykjavik may have to hand over some of the documentation to the City Archives.

The other recipients of the information are the processors responsible for setting up and operating the systems necessary for the functioning of the devices. This involves Google and Lightspeed respectively, and a processing agreement has been concluded with both of these parties. In this case, other recipients of personal information may be involved in specific software solutions/apps that the chromebooks may use, but parents will be educated about any such software use at that time.

Réttindi þín

Students and parents may have the right to access the personal data that the city of Reykjavik and the primary school process on the devices. You may also have the right to object to the processing, to have the information corrected, to request deletion, to restrict the processing, and/or to have the information provided to you in a computer-readable format.

You can find more information about these rights in the Reykjavik City Privacy Policy, which is available on the City's website.

Kvörtun yfir vinnslu

Note that if you do not agree with the City of Reykjavik handling your personal data you can always contact the Reykjavik City Data Protection Officer personuverndarfulltrui@reykjavik.is or write to the the Icelandic Data Protection Authority (DPA)

Digital Citizenship

Digital citizenship—being a digital citizen—is having the knowledge, skills and attitudes needed to demonstrate responsible and respectful behavior when using technology.

With the adoption of learning devices in the City’s schools, everyone is encouraged to review good online practices.

Children and adults sail on boats at the Reykjavik Family Park & Zoo

Hotline for Save The Children – Iceland

The website of Save The Children – Iceland has a button for a hot line marked Ábendingalína. There, you can submit tips about bad online behavior and illegal, inappropriate or uncomfortable content about children or adolescents.

This could, for instance, be photographs of someone that are already in distribution.

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For Your Information

Ný birtingamynd kynferðisofbeldis - fræðslumyndskeið

in the video below, the principal of the School for Gender Equality will talk briefly about how children can get bored taking a picture of themselves and sending it via the Internet. She points out ways for parents/presbyters to educate their children about online video projections.

Hvernig dreifist mynd á netinu - fræðslumyndskeið

On the SAFT; Community, Family and Technology page, you'll find a short video describing how well and quickly an image can spread to many people.

Börn og persónuvernd

In the video below, the School and Recreation Privacy Attorney discusses briefly what needs to be considered to protect the privacy of children and youth.