What can School Councils do to align with CASL? … First; don’t panic or rely on Head Office (see below). Second; keep doing what it is you do to engage your parents but do it better so that they WANT to stay connected. Third; in September send a warm welcoming email with bright ideas/plans, and the reminders that you have their implied consent under CASL and they can opt out at any time. Fourth; make your emails attention-getting and interesting, and give the option to opt out. Fifth; if you’re not already using a professional email service that’s free and CASL-compliant, do so. In a nutshell, I say follow the lead of Gateway PS School Advisory Council. I think that Nazerah Shaikh and her colleagues, solidly supported by principal Patricia Sutherland, have created a Flagship School Council with policies and procedures that should be adopted as Best Practices. They welcome outsiders to join their email list as a “community” member and learn from what works for them. They use MailChimp so your privacy and opt-out capability are strong. For parents who are interested in the Big Picture, the achievement and well-being of all of our children, I’d like us to consider petitioning the TDSB for a major 2- or 3-year COMMUNICATIONS OVERHAUL. Allow me to share these observations: 1. My notice of the on-line CASL survey, intro and Q&A came via a link tucked away in a school’s emailed newsletter which I happened to open and read promptly. I noticed the thoughtfully included link which I had the time to pursue and act upon. If I’d procrastinated on any of these steps likely I’d have missed my chance to vote. Note: as an active parent the board has had my email address for ages yet they have sent me no direct message as did many others that email me. 2. I’d have been lost without that link to the survey because if one searches “CASL” or “anti-spam” on tdsb.on.ca nothing is found. 3. The board’s words on CASL imply that the sky will fall in just four days and they omit to mention the 36-month grace period that begins on July 1, 2014 (reference: “Transition” on fightspam.gc.ca/eic/site/030.nsf/eng/h_00050.html). 4. Furthermore they fail to differentiate between implied and express consent and have invented a new one, “formal consent.” 5. Instead they try hard to educate everyone on Commercial Electronic Messaging and all the permutations of it. By forcing the separation of informational messages from CEM’s they’re DOUBLING the number of email lists and ADDING to the work of busy principals and puzzled school council officers who must now do value assessments before deciding which email list to use. This unnecessary extra work will discourage many schools from using email at all. Heck, let’s face it; by not acting electronically push-back principals are “doing themselves and their bosses a favour by avoiding any chance of a $1m and $10m fine!” 6. The board promises that “Electronic messages sent for informational purposes such as student progress and information nights will continue to be sent without formal consent” yet many people call ANY unsolicited non-personal email spam! Folk, especially partners in an important enterprise, tend to resent having definitions, e.g. of “spam”, foisted upon them. 7. Another thing; TDSB is using a survey to register our express consent, not a database form. My understanding is that all the data collected on a survey must be uploaded to carefully prepared fields in the database in order to be readily and properly utilized. If the database is ready now, why use a survey? … If it is not yet ready, when will it be up, TESTED, passed inspection and put to use? … 8. I filled in my surveys, one for each school, with the mandatory phone number (why?). I hit “submit”, my personal profiles disappeared and I waited – am still waiting – for acknowledgements and a repetition of what I had written so that I remember what I wrote!! For follow up, all I see is the blind email address [email protected]; there’s no secure on-line link, no Privacy Office name and phone number … sloppy and worrisome. 9. Not only is there no known TDSB Privacy Officer but we have no name at all, no one to reference; zero accountability. To try to drill down on this, earlier today I called enquiries, 416.397.3000, was put through to IT and left a full message on a voice mail. I also emailed [email protected] and asked for contact info. Have heard nothing back as yet. 10. TDSB’s CASL response fails to appreciate the Big Picture, the size and complexities of Toronto’s partners in education; e.g., the 260,000 students, 588 schools each of which should have an active school council, 38,000 staff, 500,000-odd parents/guardians/caregivers and our 2,800,000 population. For significant numbers of these massive publics to convert from potential partners to active partners, they need timely effective and safe communications that “Enter their world through their portal” so that they can make informed choices in a comfortable fashion. 11. To say that public education in Toronto has 1,000+ different email lists is likely an understatement. That’s a lot of stakeholders who need to be brought on side before policy is finalized. Some of those lists belong to School Councils, PIAC and Trustees; folk who jealously keep them under wraps and are loath to share them with Big Brother TDSB where who knows what may become of them. (I wonder if Legal has figured out how TDSB protects itself from liability if one of these arm-length entities is sued by a legitimate litigator or a vexatious one? …) 12. This seemingly inevitable complexity of email lists leads one to wonder, when one has two or more children in the system, has multiple interests and receives an unwanted email or, maybe, the same email two or three times, which list it is coming from, how does one stop duplication? … Looks like we could be getting more spam rather than less or none. In short, I see TDSB’s response to CASL as a hornet’s nest; a flawed lawyer-driven panic reaction. Likely it bypassed Senior Team decision makers, certainly parents weren’t consulted; the tail wagging the dog! Yet this can be a call to action. I see the CASL and its draconian penalties as crystallization of problems and the catalyst for solutions. I suggest we need TDSB COMMUNICATIONS OVERHAUL; a major 2- or 3-year program – driven by the Senior Team in consultation with partners – that reviews and updates communications in all media between all stakeholders. For starters the board should rethink CASL and adopt – be SEEN to adopt – today’s standards in privacy protection. E.g.; all of our publics need to SEE implementation of the 2004 Personal Information Protection and Electronic Documents Act (PIPEDA) aligned with the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and Personal Health Information Privacy Act (PHIPA). Plus the board’s own E-Mail Usage Operational Procedure (PR572) needs revamping; it is woefully inadequate. The IT department needs to be brought in early, not after the fact; etcetera; let’s pro-act rather than react. One wonders what other school boards are doing in this. The Thames Valley District School Board at least has a named officer in charge of Privacy and Freedom of Information. I haven’t yet had a chance to call to ask if and what she can share with me. Bottom line: Evolution itself, our own Ministry of Education, Donna Quan and her Senior Team all urge parents to actively partner in the education of our own and each other’s children. The success of any partnered endeavor depends upon good communications; I reckon that our children and grandchildren NEED us to do what we can to ensure that every TDSB stakeholder has smooth and effective access to its communications, right? In the meantime let’s hope we hear from the Senior Team; a reassuring message to all email lists would be nice from Donna Quan or Carla Kisto, Associate Director – Finance & Operations (#3 on the Senior Team list and responsible for IT) or Erin Moroz, Executive Officer Communications & Public Affairs, to name just three. FYI their contact information is [email protected], 416.397.3190; [email protected], 416.397.3188; and [email protected], 416.397.3951. Thank you for taking the time and trouble to read and consider this post. Have a great family-filled summer! Parent Peter
Posted on: Thu, 03 Jul 2014 00:23:44 +0000
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