File System by iBjorn
Because I have a background of being involved in discussions around data protection I sometimes get a prod about online storage and web 2.0 tools. Over the last 6 months I have had quite a few over online storage options, but I have never really stuck down on (electronic) paper what my concerns are and why I have them.
There are a few concerns I have, some centre around ownership of files and data, some around data protection and some around management of the tools.
Online storage often comes under attack over IPR of images, concerns about control, heated rants about how company x is making use of *our* files / photos to generate revenue on a free service, etc … and we only have ourselves to blame for not reading the T&Cs fully, for not keeping abreast of changes to the T&Cs (though some companies make life extremely difficult to find the changes or contribute to those changes) and for not accepting that if we take part in a free service then there are likely to be limitations and issues. We take on that risk ourselves and we need to accept some responsibility for that. Whether we are talking about LinkedIn using profile photos of members in their marketing by default, changes to FaceBook privacy options, changes in security / ownership when companies merge products … there have been so many times when the masses rise up indignantly to protest and then rush around making changes and, in the worse cases, swap services … and yes, I have been there, expressing my frustration too.
This is increasingly important if we are asking children to make use of these tools as we are being trusted in our judgement and selection of these tools … after all not all children, across the broad age range we have using these tools, are emotionally, intellectually or perhaps even legally in a position to make some of these choices on their own … but that is a discussion for another time probably.
But discussions today centred around online storage, and in particular the growing use of DropBox to remove the need for USB memory devices. For those who have not come across DropBox.com, it is a an online storage system which will synchronise selected folders from one or multiple devices to an online repository. Folders or sub-folders can be shared for automated synching with other users, making it a fantastic tool for collaborative sharing of files and materials. There are a number of other tools like this ranging from Microsoft’s SkyDrive, shared document libraries in Sharepoint, Moxy, Box.net, ADrive and many more. DropBox and SkyDrive are both free so that is why you will see them in heavy use … especially in education. Free comes with limits though and sometimes that can be the amount of space, sometimes the SLA doesn’t really exist and sometimes there is a lack of control over certain aspects of functionality or how it changes.
When it comes to DropBox though, my main concern is that users are significantly at risk of breaching the Data Protection Act and they don’t even know it. This is especially important right now as it is being recommended to NQTs who might not know any better … let’s face it, there is not that much about Copyright law, Data Protection and IPR within teacher training and, from what I have seen and been told, there is a presumption that this is covered within schools by school policies … and we all know how wonderful many schools are for having decent Data Protection policies and explaining them to *all* staff.
I know that my blog is read by a wide range of people so I just need to go back a little to cover an aspect or two of the Data Protection Act. The DPA has 8 principles, which are pretty self explanatory and the 2 most important principles to look at for this conversation are 7 & 8.
If we start with DPA Principle 8 first … this about where data can be stored, moved through, processed, accessed, etc. And this is the first place we fall down with DrpoBox. There is an ongoing query that has never been fully answered about whether DropBox.com is compliant with this.
Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Now, what this means is that if you use your online storage and sharing to move about or access anything that can be deemed ‘personal data’ (which for teachers can range from pictures of children, their personal details, information about their progress, medical information and so on) then you have to do it within the European Economic Area or other countries where we have set agreements. With the US this is called the U.S. – EU Safe Harbor and there is a list of companies who have been certified with this and across what aspects. It is important to remember that being certified is only part of this … the specifics of what has been agreed is equally as important and that will differ from company to company. I have previously commented about iCloud and Apple before to reflect this.
When you look at the list you will spot that DropBox.com is not there. When you dig through the T&Cs for DropBox you will find that they use Amazon for their storage facilities … which is good … Amazon *are* on the Safe Harbor list so that seems to tick the boxes … apart from they don’t say that they will only ever use Amazon and they don’t say how they use them, and what agreements they have in place. Ah … so we are back to square one then.
I have asked the question twice now of DropBox.com and not even had tickets opened. There is a discussion at the moment about this on the forums and still no definitive answer.
To deal with this I know some users of DropBox will make use of other security solutions to bolster how they deal with DropBox. This involves using an encryption tool to create a secure folder / file which is then synchronised via the only service. A common tool for this is TrueCrypt and that works fine at a technical level … meeting the criteria of DPA Principle 7, where you are taking suitable technical measures to ensure the security of data … but the principles are not pic and mix … you have to meet them all. Right now I use an encrypted folder on Dropbox for my non-sensitive files (so only I and others I trust can access them) and do not use it at all for sensitive items.
For sharing pictures for stimulus with others (teachers / children), for sharing videos, etc, especially cross-platform and when using apps on mobile devices, then I can see that it will be fine for use in UK schools … but for staff to share in general … no … not yet.
SkyDrive does meet the criteria as the data centre used is in Ireland, but it is still worth thinking carefully about what you are sharing with others and how.
Article published on EduGeek.net and copyright to EduGeek.net and Tony Sheppard
Image : File System by iBjorn (CC BY-SA 2.0)