Google Workspace for Education’s 2021 DPIA adequately addresses privacy risks

Google complies with the agreements

In January 2023, SIVON, together with a team of external (privacy) experts and lawyers, thoroughly investigated and evaluated the steps taken by Google in response to the 2021 DPIA. SIVON shared the results of this interim analysis with Google in February 2023. Discussions continued on several important issues that were still unresolved. Google confirmed in March that it would still resolve these remaining points before June 9. SIVON has now – in consultation with the Ministry of Education, Culture and Science – decided that Google has sufficiently complied with these agreements and that schools can continue to use Google Workspace for the time being.

Protecting the privacy of students and staff is our top priority. Schools must maintain control over that data at all times. SIVON is therefore pleased with the steps taken by Google to mitigate the aforementioned privacy risks.

What does this mean for schools?

There are and will be school boards Ultimately responsible for the safe use of (digital) educational applications; You decide which apps your school uses and under what conditions. This summer you’ll get the full DPIA report outlining all the privacy risks identified in 2021 and the steps Google has taken to cover them. With this report, schools can make their own decisions about using Google Workspace.

Data Transfer Impact Assessment

One of the points arising from the DPIA in 2021 is the transfer of data to the US. Earlier this year, a separate process was launched to this point, called the Data Transfer Impact Assessment (TDIA). This includes examining the privacy risks of transferring data to countries outside the European Economic Area (EEA). Google supports this. The DTIA — including the implementation of the resulting measures — is expected to be completed this fall.

The state of Chromebooks, ChromeOS, and the Chrome browser

DPIA in Google Workspace is different from DPIA performed on Chromebooks, ChromeOS, and the Chrome browser. In the process, SIVON has entered into agreements with Google regarding the new version of ChromeOS. This modified version will be available to schools in August this year. Read more about this SIVON website. In a letter to the House of Representatives, the Minister informed the House of Representatives about the issues related to the use of Google Workspace and Chromebooks.

Continuous monitoring of regulation is very important

SIVON recognizes the importance of privacy and does everything possible to embed privacy agreements in contracts with Google and other suppliers. That is why we place great emphasis on continuous evaluation of (cloud) services and assessing their feasibility. We are alert to changing laws and regulations and periodically review existing agreements against them and amend them where necessary. We proactively monitor, regularly discuss and negotiate with Google and other suppliers to ensure that students and staff use (digital) education services safely and responsibly.