School board updates JRCA student-data policy to match Virginia code; vendors must document deletion procedures
Summary
The board approved revisions to policy JRCA to align vendor contracts with Virginia code; staff said the Virginia student-data binding agreement requires vendors to document how they will handle and delete data and that the district has received written deletion verification in past cases.
The Orange County School Board on Feb. 2 approved proposed revisions to policy JRCA (school service providers' use of student personal information) intended to bring the policy into alignment with current Virginia law.
Superintendent Dr. Hornick presented the proposed language and said items in red reflected direct statutory language. Board members sought clarification about retention periods and the mechanics for requesting deletion of student information. Dr. Hornick said retention timelines are often specified in individual contracts and that the division's procurement and legal teams (including Dawn Knight and her staff) vet vendors and deletion processes as part of contract negotiations.
Division staff member Brenna explained the Virginia student-data binding agreement (consortium) used by the division: "it creates that binding agreement that they're required to comply with," she said, and added that vendors normally either delete data after a stated renewal/retention period or delete when the district directs them to do so. She also said the district has completed deletion requests previously and receives written verification from vendors when deletion occurs.
Board members asked whether deletion timelines are decided when a contract is signed; staff confirmed they are and said the district obtains verification in writing when deletion is completed. The board discussed student safety and data privacy as ongoing concerns and approved the policy revision following motion and second.
What changed: the policy revisions incorporate specific contract language and reference to the relevant Virginia code sections; administration said the division will continue to require vendors to sign state-level student-data agreements and to document deletion procedures in contracts.
Key quote: on vendor obligations, Brenna said, "...if we do request student data or we stop using that service, they're required to enumerate how they're going to handle our data moving forward."
