District Policies and Budgets

Electronic Use Policy

Welcome to Waterbury Public Schools' Guide on Student Data Privacy

Waterbury Public Schools is committed to protecting your child's personal information. This page explains how we handle student data and provides important information about contracts related to student information.

The Law: Posting Contract Notices

Connecticut law requires Waterbury Public Schools to post notices about certain contracts online. Here's what you need to know:

• Contracts with Contractors: We enter into written contracts with companies or organizations (contractors) before they can access student information.
• Website Posting: Within 5 business days of signing such a contract, we post a notice on our website about it.

What Information Is Included in the Notice?

The notice posted by Waterbury Public Schools will include:

• Date of Contract: When the contract was signed.
• Brief Description: A summary of what the contract is about.
• Student Information: An explanation of what kinds of student information, records or content may be accessed by the contractor.

Your Rights: Notification & Transparency

You will receive an electronic notification from Waterbury Public Schools when these contract notices are posted. We strive to keep you informed about contracts concerning your child's data.

• Look for Notifications: Pay attention to emails or notices from Waterbury Public Schools.
• Check Our Website: If you don't receive a notification, look for the notice on the Waterbury Public Schools website.

Why is this Law Important?

This law helps Waterbury Public Schools to:

• Increase Transparency: Keep you informed about who has access to your child's data and why.
• Promote Accountability: Hold us and our contractors responsible for handling student data properly.
• Protect Student Privacy: Ensure we consider data privacy when choosing contractors.

What Can You Do?

• Stay Informed: Regularly check the Waterbury Public Schools website for these notices.
• Ask Questions: If you have any questions or concerns about a contract or student data privacy, please contact us.
• Review District Policies: Familiarize yourself with our policies on data privacy, available on our website.

Additional Resources

For more information, visit the Connecticut State Department of Education website.

Connecticut State Department of Education

• Date of Contract: 01/08/2025
• Description: ACES serve as the fiduciary Manager for the Learner Engagement and Attendance Program, also known as LEAP. ACES will be instrumental in the hiring, onboarding, and payroll for all LEAP staff, including the City Coordinator, City Team Leader, Team Leaders, and Engagement Specialists
• Student Information Collected: No information is shared.

DOCUMENT

• Date of Contract: 01/14/2025
• Brief Description: This is providing a data platform for tracking and monitoring students’ progress to graduation.
• Student Information: Student info on their progress to graduation would be kept.

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• Date of Contract: 01/12/2025
• Brief Description: Providing internship to students
• Student Information: Data captured on student participation and progress.

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• Date of Contract: 1/21/2025
• Brief Description: An amendment to the contract to remove the following schools: Carrington, Duggan, Gilmartin, and Jonathan Reed. In addition, to request the inclusion of eDynamic site licenses for State Street and Enlightenment students, allowing American Sign Language (ASL) to fulfill the state's world language requirement for graduation. While ASL was initially approved in the contract for only one year (23-24 SY), I would like to extend this for the remainder of the contract. This would require an amendment to add the necessary additional licenses and years.( contract expires June 30, 2026)
• Student Information: An explanation of what kinds of student information, records or content may be accessed by the contractor.

4. Responsibilities of the Consultant. All data, information, etc. given by the City to the Consultant and/or created by the Consultant shall be treated by the Consultant as proprietary to the City and confidential unless the City agrees in writing to the contrary and shall be used solely for the purposes of providing services under this Contract. The Consultant agrees to forever hold in confidence all files, records, documents and other information which may come into the Contractor's possession during the term of this Contract, except where a disclosure is expressly stated as a requirement of this Contract. Notwithstanding the foregoing, where a Consultant disclosure is required to comply with statute, regulation, or court order, the Consultant shall provide prior advance written notice to the City of the need for such disclosure. The Consultant agrees to properly implement the services required in the manner herein provided.

4.2. Confidentiality/FERPA. Consultant shall strictly adhere to all State and Federal Statutes, rules, policy, regulations, codes of participant protection and confidentiality, administrative directives of the State of Connecticut Board of Education, Connecticut Department of Education and the Waterbury Board of Education regarding confidentiality of student records, files, PPTS, IEPs, etc. Consultant shall further ensure that its employees, agents, or anyone performing work on their behalf under the terms of this Agreement shall strictly adhere to all State and Federal Statutes, rules, policy, regulations, codes of participant protection and confidentiality, administrative directives of the State of Connecticut Board of Education and those of the Waterbury Board of Education regarding confidentiality of student records, files, PPTS, IEPs, etc.

4.2.1. Compliance Warranty & Privacy Policy. Edgenuity will comply with, and will cause cach of its employees, agents, and contractors to comply with, all state, federal and municipal laws and regulations applicable to its performance under this Agreement ("Applicable Laws"), including without limitation the Family Educational Rights and Privacy Act ("FERPA"), and the Children's Online Privacy Protection Act ("COPPA"). Edgenuity's Privacy Policy, which is incorporated by reference into these terms and conditions, contains additional terms regarding Edgenuity's use of and commitment to safeguarding Student Data, and compliance with other student privacy laws. Customers and End Users

find Edgenuity's privacy policy http://www.edgenuity.com/Information/Privacy/. Customer is responsible for providing notice of its own privacy policy to parents of its student and for can at Page 5 of 30

obtaining any necessary parental consents for students to use the Subscription as may be required by Applicable Law.

4.2.2. Any and all materials contained in City of Waterbury Student files that are entrusted to Consultant or gathered by the Consultant in the course of its services shall remain in the strictest confidence to prevent disclosure of the same. All information furnished by the City or gathered by Consultant shall be used solely for the purposes of providing services under this Agreement.

4.2.3. Consultant acknowledges that in the course of providing services under this Agreement, it may come into the possession of education records of City Waterbury students as defined in and governed by Family Educational Rights and Privacy Act ("FERPA", 20 U.S.C. § 1232g) and related regulations (34) C.F.R. § 99) Consultant and City shall comply with the requirements of said statute and regulations, as amended from time to time and Consultant agrees to use information obtained from the City or student education records only for the purposes provided in this Agreement. Without the prior written consent of the student's parent or guardian, as required by FERPA, Consultant has no authority to make disclosures of any information from education records. Precision Exams shall instruct its employees of their obligations to comply with FERPA.

4.3. Student Data Privacy. All student records, student information, and student-generated content (collectively, "Student Data") provided or accessed pursuant this Agreement are not the property of, or under the control of, the Consultant.

4.3.1. The City's Board of Education ("Board") shall have access to and the ability to delete Student Data in the possession of the Consultant except in instances. where such data is (A) otherwise prohibited from deletion or required to be retained under state or federal law, or (B) stored as a copy as part of a disaster recovery storage system and that is (i) inaccessible to the public, and (ii) unable to be used in the normal course of business by the Consultant. The Board may request the deletion of any such student information, student records or student generated content if such copy has been used by the operator to repopulate accessible data following a disaster recovery. The Board may request the deletion of Student Data by the Consultant within two (2) business days of receiving such a request and provide to the Board confirmation via electronic mail that the Student Data has been deleted in accordance with the request, the date of its deletion, and the manner in which it has been deleted. The confirmation shall contain a written assurance from the Consultant that proper disposal of the data has occurred in order to prevent the unauthorized access or use of Student Data and that deletion has occurred in accordance with industry standards/practices/protocols.

4.3.2. The Consultant shall not use Student Data for any purposes other than those

authorized pursuant to this Agreement.

4.3.10. Use of Subscription. Customer Data and Student Data. All data and materials uploaded or entered during use of the Subscription by Customer, including student information and student records, remain the property of Customer ("Customer Data"). All student-generated content and personally identifiable information about any students ("Student Data") shall remain the property of the student, or of the parent or legal guardian of the student. Customer represents and warrants that it has appropriate rights to any Customer Data and Student Data. Customer grants Edgenuity the right to use the Customer Data and Student Data solely for purposes of performing under this Agreement. Students (or Parents or legal guardians of the Student), retain ownership and control of all Student Data that is provided or accessed through Edgenuity's course, and ownership of such Student Data never passes to Edgcnuity. During the term of this Agreement, Customer may export Customer Data and Student Data to the extent allowed by the functionality within the Subscription. For training and demonstration purposes, Edgenuity may use and share Customer Data and Student Data, but will share only with supervisors, instructors and other Customer employees who have appropriate authorization.

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First Contract: 6/18/2020 approved by the BOE for a 5 year term.  This term expires 6/30/2025.  Amendment 3 was signed 3/11/2024 followed by Amendment 4 on 9/14/2024. Both amendments expire 6/30 2025.   

Brief Description:  This is an all- inclusive curriculum that supports student learning in alignment with the CT Early Learning and Development Standards for Early Childhood.  It provides instruction in the following areas for young children ages 3-5 years of age. Social Emotional, Physical, Language, Cognitive, Literacy, and Math development

Student Information: Students’ name, gender, date of birth, start date in school, teacher/class assignment, and school ID#s.

DOCUMENT

• Date of Contract: 10/3/2024 
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

DOCUMENT

• Date of Contract: 10/3/2024
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024 
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024 
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 12/20/2024 
• Brief Description: Provides preschool services through the School Readiness grant
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024         
• Brief Description: Provides preschool services through the School Readiness grant
• Student Information: No information is shared.

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• Date of Contract: 10/03/2024         
• Brief Description: Provides preschool services through the School Readiness grant.
• Student Information: No information is shared.

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• Date of Contract: 08/26/2024
• Brief Description: To teach students in Waterbury Public Schools personal financial literacy, consisting of the importance of investing, savings, banking, debt reduction, credit, insurance, retirement, and more.
• Student Information: No information is shared. 

DOCUMENT

• Date of Contract: 08/26/2024
• Brief Description: Providing college classes for students. Students earn college credits and are considered Post University students. Students use all programs (blackboard) that university utilizes.
• Student Information: Student attendance and performance data is captured

DOCUMENT

• Date of Contract: 5/23/24   
• Brief Description: “Leader and Me” program dealing with multi-language leadership skills.
• Student Information: No information is shared

DOCUMENT

• Date of Contract: 05/20/2024
• Brief Description: Providing Game Design and Development curriculum.
• Student Information: Student login data to the software programs used through Clever.

DOCUMENT

• Date of Contract: 6/28/2025        
• Brief Description: We use this platform to house our curriculum.
• Student Information: No information is shared.

DOCUMENT

• Date of Contract: 1/24/2024
• Brief Description: “Leader and Me” program dealing with multi-language leadership skills.
• Student Information: No student information is shared

DOCUMENT

• Date of Contract: 08/15/2023
• Brief Description: The LiveGirl MoU is for creating and holding “Confidence Clubs” for Middle & High School girls to deal with self-esteem.
• Student Information: Student info on who is attending and participating in the clubs would be kept.

DOCUMENT

• Date of Contract: 2/24/2023
• Brief Description: TORSH is an online platform for coaching and supporting teachers. It can be used to share resources electronically with teaching staff and also share monitoring documents electronically with staff after an onsite monitoring visit
• Student Information: No student information is shared.

DOCUMENT

• Date of Contract: 03/09/2023
• Brief Description: Providing college classes for students.
• Student Information: Student attendance and performance data is captured.

DOCUMENT

• Date of Contract: 01/13/2023
• Brief Description: Provide CNA training to students. Students are able to access and complete clinical hours at facility.
• Student Information: Student participation and performance data is captured.

DOCUMENT

• Date of Contract: 12/16/2022
• Brief Description: Provides Education curriculum for students who want to learn about education fields.
• Student Information: Data of students participation captured

DOCUMENT

• Date of Contract: 10/22/22
• Brief Description: This is for licenses for grades 6-12 to have access to Quill.org, a grammar, proofreading, and writing application that is used as part of the grades 6-12 ELA curriculum.
• Student Information: Quill abides by all FERPA and COPPA laws. We collect student data to personalize and maximize students' learning experiences and understand how students engage with the website. We do not advertise or share student data with any third parties.

DOCUMENT

• Date of Contract: 11/29/2022
• Brief Description: The goals of the GU Program are the following for the cohort of 2025: Increase student and family knowledge of postsecondary education options, preparation and financing. Increase student academic performance and preparation for postsecondary education, and Increase the rate of high school graduation and enrollment in postsecondary education among students in the targeted schools.
• Student Information: 
• Provide access to documents and records such as assessment, test scores, Individual Education Programs (“IEP’s”), Student Success Plans (“SSP’s”) and other educational records as needed and requested by the Local Program Coordinator in order to better evaluate the effectiveness of the Program or to provide specific assistance to specific students, and Provide access to all student level data required for state and federal monitoring.  Collaboration between the Local Program Coordinator and Waterbury Public School District contact for reporting of information is dependent on parent/guardian consents received. Student demographics will be uploaded into a tracking database provided by CSCU such as SCRIBE. Written consent from the parent or guardian of the student must be obtained in order for this information to be released to the GU Program and entered into SCRIBE. The following list is what is required for each student to participate in the GEAR UP Program in Grade 9-Grade 12 to receive free services and meet compliance with the USDOE for this federal grant.

• Item(s) to be released to GEAR UP:

• Student Name (First, Last, MI)
• SASID (State Assigned Student ID)
• Address
• Date of Birth
• School Name
• Grade Level
• Course Level
• Gender
• Ethnicity/Race
• IEP (if applicable)
• ESL/Limited English Proficiency (if applicable)
• Homeless (if applicable)
• Foster Care (if applicable)
• Free & Reduced Lunch (if applicable)
• Entry/Exit Date into District
• Standardized Test Scores/PSAT/SAT
  •  
• Provide access to relevant meetings and information from those in leadership within Waterbury Public School District, particularly those involved in the alignment of Math, Science, and English language arts curriculum with college admissions expectations and the level of the 1st year college curriculum. In addition to general student data, GEAR UP activity data will be tracked for participants in the program via Microsoft Excel and transferred to the Xcalibur SCRIBE Data Management System for hours that students spend in the following activities that align with the grant objectives as outlined below:
• Tutoring – academic.
• Summer Program/Summer Remedial Services.
• Rigorous Courses (AP, Honors, UConn ECE).
• Social-Emotional Supports.
• Teachers/Counselors receive Professional Development related to college/career readiness.
• PSAT/SAT Prep Programs.
• STEM work-based learning to enable students to apply academic lessons in the “real world” and return to school with a greater appreciation for – and commitment to – STEM learning.
• Completion of Free Application for Federal Student Aid (“FAFSA”);
• Family engagement/participation in services.
• College Visits.
• First-Year Experience (FYE) Courses and/or bridge program, and
• Dual Enrollment Program/Course.

•  

  Access to school specific data regarding truancy, course completion and participation, standardized testing, earned course credits, and graduations rates including the following:

• Students enrolled in advanced math, science, and English courses.
• Student completion rate for Pre-Algebra, Algebra I, Geometry, Algebra II, Trigonometry, Pre-Calculus, Calculus, Biology, Chemistry, Physics, and Advanced Placement courses.
• Grade level performance/proficiency
• Final Grades for courses.
• Unexcused absences.
• PSAT/SAT/ACT test results.
• Graduation rates.
• Scholarships Awarded.
• Postsecondary Enrollment.

DOCUMENT

• Date of Contract: 11/04/2022
• Brief Description: The purpose of providing students in grades 6-12 a college, career, and life readiness (CCLR) platform. It enables students to discover their strengths and interests build critical social-emotional learning skills, create actionable goals, find scholarships, complete the college application process, and find their best-fit path and career after high school.
• Student Information: 

  The contractor may be granted access to specific student information and records necessary for the integration and support of student data systems such as PowerSchool and Naviance. This access may include, but is not limited to, the following types of information:

  Demographic Information: Student name, ID number, date of birth, grade level, school enrollment, and contact details.

  Academic Records: Course enrollment, grades, transcripts, GPA, and standardized test scores.

  Postsecondary Planning Data (Naviance-specific): Student goals, college and career interest surveys, career assessment results, resume drafts, college application lists, scholarship tracking, and recommendation requests.

  Contact and Guardian Information: Parent/guardian names, contact numbers, email addresses, and home address (as needed for communication or report generation).

DOCUMENT

• Date of Contract: 09/20/2022
• Brief Description: Orchestra members provide lessons to students on various instruments.
• Student Information: Data is kept on which students are participating, scheduling times and locations of lessons and progress made along with planning of future lessons. 

DOCUMENT

• Date of Contract: 08/21/22
• Brief Description: This platform allows teachers to make and use interactive powerpoints so all students can answer and collaborate at the same time during a whole group lesson. Students use  Clever as the single sign on and the platform is linked to Google Classroom in some cases.
• Student Information: No information is shared

DOCUMENT

• Date of Contract: 6/21/2022
• Brief Description: Teachers use this extension to modify pdfs and have students make edits to scanned document. They then can add them to their Google Classroom for credit.
• Student Information: Student information through Google Classroom link

DOCUMENT

• Date of Contract: 8/24/2022
• Brief Description: TORSH is an online platform for coaching and supporting teachers. It can be used to share resources electronically with teaching staff and also share monitoring documents electronically with staff after an onsite monitoring visit. Community school readiness providers use it in house, and share only with selected members of their own agency, and with me
• Student Information: No information is shared.

DOCUMENT

• Date of Contract: 06/23/2022
• Brief Description: Managing a student run bank branch
• Student Information: Data of student accounts is captured

DOCUMENT

• Date of Contract: 04/2022
• Brief Description: Legends of Learning provides a quality program that will allow K-5 students independent, game-based learning in Math and Science. These assignable, skills-based games can be used for homework or as a center activity after completion of core/tier one and tier two assignments and can also be utilized to build the Extra School Hours and Summer School programs. Legends of Learning, Inc. offers curriculum-based games for stronger subject mastery and classroom engagement
• Student Information: Student Users will be asked to provide their first and last name or a nickname in order to access the Platform. Our collection and use of data from any user is strictly limited to the minimum requirements needed for operation of the Services.

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