Bull Valley Software1 (BVS) understands that it and its employees may have access to Student Personal Information2 during the routine provision of implementation and technical support services to its school district customers. BVS also understands that it has been entrusted to maintain the confidentiality of said Student Personal Information and therefore pledges to carry out responsible stewardship and appropriate use of information gathered in our role as a School Service Provider3 , according to the commitments below and in adherence to all laws applicable to it as School Service Providers.
DocumentLOK™ is a platform developed, sold, and supported by Bull Valley Software (BVS) that K-12 school districts utilize for the sole intended purpose of storing and managing student-related documents as part of the district’s overall Education Records. These document types may include, but are not limited to:
Documents committed to the document repository by a School Official6 may or may not contain sensitive student information, completely dependent upon the document’s nature and purpose.
DocumentLOK™ stores these documents as 256-bit encrypted objects within a Microsoft SQL database, along with the documents’ associated metadata. The document repository and SQL database may be stored on the district’s in-house network, or on a cloud-based service selected by the district.
Specific metadata to be stored with the documents is at the sole discretion of authorized School Officials when DocumentLOK™ is initially installed and may be updated by the district throughout the period that the district continues to use DocumentLOK™. The purpose of the metadata is to allow for the efficient filing and retrieval of the documents by district staff. Examples of the metadata may include but are not limited to:
This metadata may be obtained through integration with the district’s Student Information System (SIS), integration with another education-related software application in use by the district, and/or manual input by district staff at the time the document is committed to the document repository.
The district’s Education Records, document repository and associated metadata are controlled solely by the district’s School Officials. Bull Valley Software, Inc. does not have access to the district’s Education Records, document repository, or metadata unless granted access by a School Official, and then only to support the authorized use of DocumentLOK™. Information may be exchanged for the execution of an integration with another software application in use at the district, but only at the request of a School Official at the district.
Use of Student Personal Information
Bull Valley Software sells, implements, and provides technical support for the DocumentLOK™ document management platform, which a K-12 school district uses to manage their Student Records. Bull Valley Software does not come in contact with any student information beyond that needed for authorized Educational/School Purposes7 (including the providing of technical support to the district vis-ŕ-vis their use of the DocumentLOK™ document management platform).
BVS’ access to Student Personal Information is limited to data exposed to BVS incidental to the implementation process, or during the provision of DocumentLOK™ technical support to the district. Once the requested task or service has been completed, Bull Valley Software’s access to the educational records, document repository, and/or the SQL database is terminated. Any Student Personal Information that BVS has been exposed to is not, and will not be copied, collected, used, or retained by BVS after the requested task or service has been completed, and no Student Personal Information or documents are stored or managed by Bull Valley Software.
BVS does not, and will not, collect any information to create a student profile that would allow BVS or any other party to use said student profile in any way that is not specifically for an Educational/School Purpose as defined above.
BVS does not, and will not, use any behavioral information contained in a district’s DocumentLOK™ system or any other Educational Record, or knowingly allow any third-party advertiser, to provide targeted advertising to students.
If a parent8 or student9 has any concerns about information to which BVS may have been exposed during the normal course of providing requested services to the district, he/she should contact their school with any questions. Bull Valley Software will support the district and cooperate fully with any such requests.
Security of Student Personal Information
Bull Valley Software does not and will not sell any student data (including Student Personal Information) under any circumstances, even if consent is given by a School Official.
End Notes / Definitions
1 Bull Valley Software (BVS) is a software developer with a mailing address of P.O. Box 2029, Woodstock IL 60098. Its telephone number is (815) 788-1888, and its email address is SalesAdmin@BullValleySoftware.com
2Student Personal Information is personally identifiable information as well as other information when it is both collected and maintained on an individual level and is linked to personally identifiable information.
3 School Service Provider refers to any entity that: (1) is providing, and is operating in its capacity as a provider of, an online or mobile application, online service or website that is both designed and marketed for use in United States elementary and secondary educational institutions/ agencies and is used at the direction of their teachers or other employees; and (2) collects, maintains or uses student personal information in digital/electronic format. The term ‘School Service Provider’ does not include an entity that is providing, and that is operating in its capacity as a provider of, general audience software, applications, services or websites not designed and marketed for schools.
4 Education Records means records that are directly related to a student and are maintained by an educational agency or institution or by a party acting for the agency or institution. For more information, see the Family Educational Rights and Privacy Act regulations. 34 CFR § 99.3.
5 FERPA The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.
6 School Official means any employee, including teacher, that the school or district has determined to have a “legitimate educational interest” in the personally identifiable information from an education record of a student. School officials may also include third party contractors, consultants, volunteers, service providers, or other party with whom the school or district has outsourced institutional services or functions for which the school or district would otherwise use employees under the school official exception in FERPA. 34 CFR § 99.31(a)(1).
7 Educational/School Purposes are services or functions that customarily take place at the direction of the educational institution/agency or their teacher/employee, for which the institutions or agency would otherwise use its own employees, and that aid in the administration or improvement of educational and school activities (e.g., instruction, administration, and development and improvement of products/services intended for educational/school use).
8 Parent includes a student’s legal guardian.
9 Student applies to students of United States elementary and secondary schools, and with regard to notice and consent applies only to students of appropriate age as authorized under relevant United States federal law.