See also Part I, Part II and Part III of the narrative revealed by these communications between the Gates Foundation and the NY State Education Department -- hidden until now.
This post, the final one with excerpts from the emails I FOILed from NYSED, documents the rise and fall of inBloom; through their communications to officials at the Gates Foundation and assorted consultants and allied organizations. inBloom was formally launched as a separate corporation in Feb. 2013 and died in April 2014, after little more than one year of existence. These fourteen months were marked by myriad public relations and political disasters, as the Gates Foundation’s plans for data collection and disclosure experienced national exposure for the first time and fierce parent opposition in the eight inBloom states and districts outside NY.
Once parents in the rest of the country learned through blogs and news articles of the Foundation’s plans to upload onto a data cloud and facilitate the sharing of their children’s most sensitive personal information with for-profit vendors, their protests grew ever more intense, and inBloom’s proponents were powerless to convince them that the benefits outweighed the risks. Though the Gates Foundation had hired a phalanx of communications and PR advisers, they were never able to come up with a convincing rationale for inBloom’s existence, or one that would justify this “data store”, as they called it, that cost them more than $100 million dollars to create.
The Foundation started the 2013 with a plan to promote inBloom through the media and at the large SXSWedu conference, and to expand the number of inBloom “partners” beyond the original nine states and districts that they said were already committed; instead they watched as every one of these nine states and districts withdrew or claimed they had never planned to share data with inBloom in the first place.
For the previous posts in this saga, see Part I showing how, after waiting a year and a half, we finally received the emails in December 2014, after inBloom had collapsed and the day after John King announced his resignation as NYS Commissioner to become Arne Duncan’s top adviser. He is now Acting US Secretary of Education. Part II contains FOILed emails from 2011, and Part III has highlights from emails sent in 2012.
1/10/13: Henry Hipps, Senior Program officer of the Gates Foundation, tells Ken Wagner of NYSED that “We’re ramping up for a pretty big push for the new post-SLC [Shared Learning Collaborative, the LLC which morphed into inBloom Inc.] at SXSWedu in March. [SXSWedu is an annual conference focused on education and dominated by tech companies that takes place in Austin Texas.] It’s a watershed moment for the project and our engagement of the vendor community and additional states and districts. We are doing a couple of LEA/SEA-focused panels and I’d love to have you join us to discuss NYSED’s view of the world. We’ve got a whole slate of events. And Bill [Gates] is joining us for both a private reception as well as the keynote address of the conference. Should be fun.
Once parents in the rest of the country learned through blogs and news articles of the Foundation’s plans to upload onto a data cloud and facilitate the sharing of their children’s most sensitive personal information with for-profit vendors, their protests grew ever more intense, and inBloom’s proponents were powerless to convince them that the benefits outweighed the risks. Though the Gates Foundation had hired a phalanx of communications and PR advisers, they were never able to come up with a convincing rationale for inBloom’s existence, or one that would justify this “data store”, as they called it, that cost them more than $100 million dollars to create.
The Foundation started the 2013 with a plan to promote inBloom through the media and at the large SXSWedu conference, and to expand the number of inBloom “partners” beyond the original nine states and districts that they said were already committed; instead they watched as every one of these nine states and districts withdrew or claimed they had never planned to share data with inBloom in the first place.
For the previous posts in this saga, see Part I showing how, after waiting a year and a half, we finally received the emails in December 2014, after inBloom had collapsed and the day after John King announced his resignation as NYS Commissioner to become Arne Duncan’s top adviser. He is now Acting US Secretary of Education. Part II contains FOILed emails from 2011, and Part III has highlights from emails sent in 2012.
1/10/13: Henry Hipps, Senior Program officer of the Gates Foundation, tells Ken Wagner of NYSED that “We’re ramping up for a pretty big push for the new post-SLC [Shared Learning Collaborative, the LLC which morphed into inBloom Inc.] at SXSWedu in March. [SXSWedu is an annual conference focused on education and dominated by tech companies that takes place in Austin Texas.] It’s a watershed moment for the project and our engagement of the vendor community and additional states and districts. We are doing a couple of LEA/SEA-focused panels and I’d love to have you join us to discuss NYSED’s view of the world. We’ve got a whole slate of events. And Bill [Gates] is joining us for both a private reception as well as the keynote address of the conference. Should be fun.
Are you available? The dates of the actual panels are March 6th and 7th, so we’d cover you for T and E [travel and expenses] for at least two nights. I’ll know if we can support you for more time in Austin once I finalize the budget. Please let me know ASAP.”
1/18/13: Class Size Matters produces a national fact sheet for parents in the nine states that inBloom lists as “partners”, including Louisiana, NY, Kentucky, Georgia, North Carolina, Delaware, Illinois, Colorado, and Massachusetts, alerting them to the threat to student privacy. The next day Diane Ravitch reprints our warning on her widely read blog.
2/5/13: Henry Hipps of Gates emails Ken Wagner about the “Notice of Acquisition of SLC by inBloom”, essentially the transformation of this LLC into a separate corporation with an address in Atlanta, Georgia. “Hi Ken, Hopefully you’ve already seen the announcement of the inBloom launch and some of the press coverage it has generated today….Let me know if you have any questions.” Press release here; which says “Nine states, representing more than 11 million students, are participating in the development and pilot testing of the inBloom technology services to ensure they meet the needs of states, districts, teachers and students.” The press release includes positive quotes from a long list of vendors, including PBS and Scholastic, that plan to develop products to take advantage of the student data that will be made available. The media, concentrated in the technology sector at this point, is mostly approving.
On the same day, deShawn Wright, Gov. Cuomo’s Asst. Sec. of Education, writes us that despite his assurances, it has proven impossible to arrange a meeting between NYC parents and NYSED about inBloom, and that instead, they have agreed to answer written questions from us within five business days. We later send a list of 16 simple factual questions for NYSED. More than a week later, Wright tells me that NYSED refuses to answer any of our questions.
3/1/13: In a press release, eScholar, a for-profit vendor announces its “partnership” with inBloom, and that “inBloom and eScholar are working together to launch the New York State Education Data Portal (EDP), which will be implemented in the Fall of 2013. eScholar myTrack will provide a data dashboard and goal management system, while inBloom will deliver the data infrastructure from which eScholar myTrack will pull and load data.”
3/4/13: The SXSWedu conference begins in Austin Texas, with Bill Gates announced as the keynote speaker and inBloom as a key co-sponsor. On the very same day, the first article appears in the national media about inBloom, by Reuters reporter Stephanie Simon, entitled “K-12 student database jazzes tech startups, spooks parents.” Simon is the first reporter to take note of parent opposition to this project, based upon its risk to children’s privacy. Here is an excerpt:
“Entrepreneurs can't wait. ‘This is going to be a huge win for us," said Jeffrey Olen, a product manager at CompassLearning, which sells education software… While inBloom pledges to guard the data tightly, its own privacy policy states that it ‘cannot guarantee the security of the information stored ... or that the information will not be intercepted when it is being transmitted.’
3/6/13: Ken Wagner appears on a SXSW panel entitled “Field Notes on Implementing inBloom” to help the Gates Foundation promote inBloom to other states and districts. Meanwhile, NY parents who have emailed opt out letters to Commissioner King’s office get no response. When a NYC parent follows up by phone, a NYSED staffer tells her that they are too busy compiling the data and transmitting it to inBloom Inc. to respond to parents’ concerns.
3/8/13: Leonie Haimson of Class Size Matters, attorney Norman Siegel, NY State Senator Liz Krueger, Panel for Educational Policy member Patrick Sullivan and special education parent
Karen Sprowal meet with Michele Cahill, the vice-president of the Carnegie Corporation, who is heading the board tasked with developing inBloom’s long term governance plan. We try to convince her to appoint at least one parent representative to the board. Cahill is openly dismissive of our concerns related to student privacy and rejects our proposal.
3/12/13: Ken Wagner emails Hipps, Streichenberg and Genevieve Haas of Waggener Edstrom, one of the Gates Foundation’s many PR consultants, with a “draft field memo…I am a bit tired and can no longer focus…I cannot tell for sure. I am most in need for you to make sure everything in the memo about inBloom is accurate.” [The memo is not attached.]
3/13/13: Haas responds that she is reviewing the memo and will get it back to him ASAP. “On a related note, we have seen an announcement from Leonie Haimson that she is holding press conference tomorrow in front of Tweed. Link below. We wanted to both make sure you were aware of the planned press conference and make sure you have whatever support you need from us on a response strategy.” Wagner responds, “Yes we are aware. Dennis [Tompkins] and Tom [Dunn] (copied here) planned to reach out for validator statements …I assume you folks saw the EPIC USED lawsuit [about the weakening of FERPA by the US Education Department to encourage data-sharing] in the WaPo."
The same day in Albany, NYS Assemblyman Daniel O’Donnell introduces bill A6059 to protect student privacy to block any vendor from redisclosing personal student data without parental consent, as inBloom was designed to do. It also would place strict security provisions on any vendor and require that they indemnify the state for breaches. NYS Senator Mark Grisanti soon introduces a companion bill in Senate, # S04284. The New York Daily News subsequently writes about the bill here. Within two weeks the bill has 38 co-sponsors in the Assembly and three in the Senate.
3/14/13: Class Size Matters holds a press conference on the steps of Tweed, the NYC DOE headquarters. Parents, Councilmembers Letitia James, Daniel Dromm and Stephen Levin all speak out against the state’s plan to share data with inBloom. Video of the press conference is here. The Daily News reports on the issue in a two page spread including an op-ed by me; the press conference is also covered by CBS News, GothamSchools, ABC Local, NBC New York, the Village Voice, the New York Daily News and WNYC/Schoolbook.
3/19/13: Genevieve Haas emails NYSED that Dori Marlin of CBS 6 News in Albany is working on a story on inBloom, “focused on whether inBloom can guarantee the security of student data, provisions for data breaches and whether inBloom will enable vendors to access the data.” Tom Dunn responds that Ken is being interviewed by the reporter the next day.
Haas sends them some talking points to be shared with the reporter: “…inBloom can be a game-changer by doing two things: first by giving teachers more time, more visilbility into what students need, and easier access to tools and resources, and second by making it possible to personalize learning for every kids in a classroom... Q Can inBloom GUARANTEE that NY students’ personal private information will not be compromised or intercepted? Data privacy and security is a top priority for inBloom. In this day and age no security protections can be 100% guaranteed …etc.”
3/21/13: Tom Dunn rejoices when the CBS piece runs: “This is actually a fair piece. Ken’s presentation is measured and thoughtful. The opposing POV is radical and presented w/o support.”
4/5/13: Daniel Kim of “inBloom site Engagement” writes to NYSED and NYC DOE to inform them that “Leonie Haimson has called a town hall meeting in Brooklyn on April 29 to discuss privacy. There will be 2 members of the NYS Board of Regents in attendance. Leonie has invited specific individuals from inBloom, and has indicated that members of NYSED and NYCDOE will also be invited. The inBloom team would like to hold a conference call on Monday or Tuesday with our three teams to ensure that our approach and communications back to Leonie are aligned.”
4/8/13: Tom Dunn sends to Gates, inBloom and Waggener Edstrom a copy of the letter that John King finally sent in response to the “800 parents who responded to Leonie’s petition.” King’s letter never uses the words inBloom, instead calls it the “NY’s Education Data Portal (EDP)” and claims it will greatly benefit students, “help teachers deliver high quality personalized instruction”, as well as “maintain stringent data security and privacy protections,” and achieve the goal of “preparing all children for college and careers.…”
4/19/13: Responding to Louisiana parent and school board outrage at finding out about inBloom from the media, and the fact that inBloom was collecting students' Social Security numbers along with their names and other personal information, Louisiana Superintendent John White announces he has changed his mind, and is pulling student data out of inBloom – the first state to do so. This signals the beginning of inBloom’s collapse, only six weeks after its launch.
Iwan Streichenberger writes to John King and to reporters that “an article was published this morning that had a number of inaccuracies about Lousiana’s continued involvement with inBloom.” He claims that Louisiana “remains part of the inBloom consortium.” John King asks Streichenberger if Louisiana or inBloom could “put out a press advisory clarifying these points.”
4/21/13: King makes an additional request to the Gates Foundation: “Would it be possible to quickly secure a letter to NYS from 4 or 5 top independent tech privacy experts endorsing the inBloom approach?”
This never happens, though Steve Winnick, an attorney on the inBloom payroll writes a statement affirming that their plans do not violate federal law, similar to an oped he had written for the WaPost AnswerSheet on March 28. Michael Gibbons, a security expert at Alvarez and Marsal, another paid Gates consultant, also composes a statement that says he has been reviewing inBloom’s system security documentation “for the past 4 weeks[!]” and his “impression is that there are no significant unmitigated risk to data at inBloom.”
4/23/13: Streichenberger writes to inBloom’s state partners, again attempting damage control regarding Louisiana Superintendent John White’s decision to pull out. He describes how Louisiana was initially Phase II state, but then “the team in Louisiana saw an opportunity to move more quickly…Last week, Superintendent White decided to pause their fast-track implementation in order to have the kinds of conversations with his Board and other stakeholders that Phase 1 states have been having for more than a year…The pause also supports Louisiana’s efforts to transition from using Social Security numbers to randomized student ID numbers, in keeping with inBloom’s requirements and with industry best practices….We welcome the chance to support your efforts to communicate clearly and transparently with your stakeholders, for your convenience I’ve attached a document with fact s about inBloom’s approach to privacy and security .”
When EdWeek follows up, and asks John White to respond to Streichenberger's comments that the state is only on "pause," White says, "I don't really know what it means," and emphasizes that the state no longer has any student data stored with inBloom.
4/25/13: Streichenberger thanks Ken Wagner for the time he took today to “catch up” and provides him with a “proposed statement for Commissioner King” that he could offer to mitigate some of the damage around Louisiana’s defection:
“We are confident that inBloom has made privacy and security of student data their highest priority, and are committed to working with them to improve instruction and achievement for all New York students. Following a recent meeting of the New York Board of Regents, where I shared with the Regents the vision for New York’s Education Data Portal, I want to restate my commitment to providing the best technology tools to support our educators in preparing students to be college and career ready. Making these tools available is frequently inefficient and inconvenient because they do not typically work as easily as they should with school and district data systems. This frustrates teachers and short-changes students and their families. For this reason, NYSED is excited to be partnering with the non-profit inBloom to provide New York with services to integrate our data systems. This will increase the educational technology options available to our schools and lower costs, all while protecting data security and the privacy of all students.”
4/30/13: On April 30, 2013, Class Size Matters and 23 other organizations hold a Town Hall meeting at Brooklyn Borough Hall about inBloom. About 150 parents and community members attend. Though no major media outlets cover the event, there are stories in the Village Voice: NYC Parents Grill Department of Education Over Private Student Data Cloud ; EdSurge: NYC Parents Raise Questions About InBloom; The Indypendent: How Murdoch, Bill Gates and Big Corporations Are Data Mining Our Schools;WINS radio/CBS: Parents Irate Over NYC DOE Plan To Give Student Data To Nonprofit Organization ; and Brooklyn Daily Eagle: Parents eye city plan to give individual student records to private biz .
We invite NYSED officials to attend and answer questions. Dennis Tompkins, Chief of NYSED External Affairs, and Nicolas Storelli-Castro, Director of Governmental Relations, attend the meeting, though they refuse to speak or to answer any questions. Two Board of Regents members come and listen intently: Kathy Cashin of Brooklyn and Betty Rosa of the Bronx. Though we also invited Sharren Bates of inBloom and Stacey Childress of the Gates Foundation, they refused to attend or send any representatives. Adina Lopatin, Deputy Chief Academic Officer of NYC DOE, does answer some of our questions and reveals that much confidential NYC student data has already been uploaded into the inBloom cloud, which sparks even more parent outrage. My account and the videos of this event are here.
On the same day, Joe Scantlebury emails John King, urging him to “Stay Strong.” King replies with a quote from Martin Luther King that “justice too long delayed is justice denied.”
This is the end of the emails I received, as I requested communications only until May 1, 2013, having initially submitted the FOIL in June 2013. The following is from a timeline showing the sequence of events that followed. (A more detailed and extensive timeline is available here.)
5/4/13: Georgia Superintendent Dr. John Barge assures parents at a town hall meeting that he “will not share the student data with InBloom.” Georgia was listed as a Phase II inBloom “partner.”
5/13/13: Bill A7872, introduced by Chair of the NY Assembly Education Committee Cathy Nolan, is passed in the Assembly. The bill would allow parents to opt out of having their children’s personal information shared with third parties, unless required to do so by court order or for safety reasons.
5/21/13: Comptroller John Liu sends a letter, warning the Board of Regents and the Commissioner King against disclosing any student data to inBloom or to any other vendors without parental consent. A resolution is introduced in the NYC Council by Council Members Brewer, Jackson and Lander against the sharing of personal student data without parental consent and in support of the student privacy bill, A.6059 / S.4284.
5/28/13: At a candidate debate, all the Democratic candidates for NYC Mayor affirm their opposition to sharing student data with inBloom, except for Christine Quinn, who is not present. The candidates subsequently reaffirm their opposition in candidate surveys, again except for Christine Quinn.
5/29/13: Reporter Stephanie Simon writes another article for Reuters entitled “School database loses backers as parents balk over privacy.” She reveals for the first time that “Kentucky, Georgia and Delaware – all initially listed as partners on the inBloom website – told Reuters that they never made a commitment and have no intention of participating….Officials in two other states on the list, Massachusetts and North Carolina, said they are still evaluating the project and may never upload student data.” Among the remaining inBloom participants only three remain clearly committed: New York, Colorado, and Illinois.
5/28/13: CNN runs a segment on the inBloom controversy, drawing further national attention.
8/1/13: Guilford County schools officially pull out of using inBloom — the one inBloom pilot district in North Carolina.
9/4/13: S.5930-2013 is introduced in the NY State Senate, the same student privacy bill as A7872, already passed by the Assembly.
9/4/13: Public Advocate Bill de Blasio, who will be elected NYC mayor in November, tells the New York Daily News, “As mayor, I will protect students’ privacy and stop this needless invasion of privacy.”
9/24/13: Under growing pressure, Cindy Stevenson, Superintendent of Jefferson County, Colorado announces that parents will be allowed to opt out of inBloom’s data collection and the dashboards populated with data from the inBloom cloud.
10/25/13: Beginning in late October, Superintendents throughout NY State return their Race to the Top funds so that they can refuse the data dashboards developed by vendors and populated with personal student data from the inBloom cloud. As of February 2014, at least forty superintendents have returned these funds, including Pleasantville (Westchester County), Southold (Long Island), Pearl River (Rockland County), and Hyde Park (Dutchess County). Yet NYSED officials say that while they can refuse the data dashboards, the personally identifiable data of their students will be provided to inBloom anyway.
Some of the newsclips generated
by the hearings: NY
Only State Still on Board With School Data Plan (AP/ABC), Assembly grills education chief on data plan (Rochester
Democrat & Chronicle); Common Core:
Assembly grills education chief King on student-data privacy (LoHud Journal
News); Data
Dashboard fears addressed at education hearing (Times Herald-Record); Plan: Gather
data on pupils (Albany Times Union); Student privacy
a major concern (NY Public Radio); Assembly
education chair threatens subpoena against data company (Capital New York).
12/11/2013: NYS School Boards Association releases survey results showing that 75 percent of school board members oppose sending personal student data to inBloom, and 78 percent believe parents should be allowed to opt out of having their children’s data shared.
12/16/13: NY Assembly Education Chair Cathy Nolan along with scores of other Assemblymembers send a letter to Commissioner John King, thanking him for his testimony, and saying that “We do not believe the State Education Department should share [student] information with InBloom, especially not at this time.” Three days later, the leader of the Assembly, Speaker Sheldon Silver calls on State Education Department to suspend the state’s participation in the project.
1/8/14: In legal filings in response to our lawsuit, the NY Attorney General reveals that NYSED has moved back its date for the transfer of data to inBloom to no earlier than April 1, 2014. NYSED claims the delay is caused by their “contractors” running behind schedule. In response to my tweeted question, the inBloom CPO, Sharren Bates disputes this claim:
2/28/14: The NYS Assembly holds another set of hearings, this time in NYC, where Ken Wagner continues to insist that this data-sharing project must go forward. For the first time, representatives from inBloom show up and testify as well, including Virginia Bartlett, the recently appointed inBloom “chief privacy officer.” The Assemblymembers do not seem convinced by their arguments that the data will be safe from abuse or breaches. Education Committee Chair Cathy Nolan and Assemblymember Daniel O’Donnell are particularly critical. See a video of the hearing here. Read more about it here and here.
Epilogue: As you have seen, neither NYSED, the Gates Foundation nor their many paid consultants, lobbyists and non-profits they funded were able to figure out a message that would quell parents’ anger at being left out of the decision-making loop, anger which was quickly communicated to elected school board members, district Superintendents, legislators, and even the Governor.
Though among the emails I received there was no smoking gun, no damning revelation showing why NYSED officials signed on with such alacrity to the inBloom deal, there was plenty of evidence of the various grants and travel expenses offered that helped induce them into an ongoing alliance with the Gates Foundation, the richest foundation in the world, with its own personal interest in facilitating the exchange of as much student data as possible with ed tech vendors and assorted researchers.
The inBloom debacle not only led to the Gates Foundation losing over $120 million, but kickstarted a debate over student privacy that continues to this day, as parents became aware for the first time how vulnerable their children’s personal information was to being shared with a host of ed tech vendors, services providers, and other private organizations for a variety of purposes and goals.
According to the Data Quality Campaign, a Gates grantee, 110 bills on student data privacy were introduced in 2014, and twenty states approved 28 of these bills. In 2015, 36 states had 110 student privacy bills, and 24 of these bills were approved in 21 states. At least five federal student privacy bills have now been introduced in Congress. Rarely have public school parents had so much immediate impact on an issue of such importance to powerful and wealthy interests, though few if any of the bills approved so far are strong enough, in our view.
Several of those responsible for inBloom and who were so dismissive of parents’ privacy concerns, were promoted following its collapse. John King is now the Acting Secretary of the US Education Department. Stacey Childress, who led the inBloom project for the Gates Foundation, is CEO of the New Schools Venture Fund, which raises capital to expand charter schools and online learning. Ken Wagner was appointed Rhode Island’s Education Commissioner. Henry Hipps and Allen Golston are still at the Gates Foundation, while Joe Scantlebury is Vice President of the Kellogg Foundation. Debbie Robinson, Communications Officer for Gates, is now the VP for Government Affairs and Communications at Education Trust.
Michele Cahill, formerly Carnegie Vice President, is now a Distinguished Fellow in Education and Youth Development at the National Center for Civic Innovation. Gene Wilhoit, who helped spearhead the project when he was head of the Council of Chief State School Officers, is the CEO of the Center for Innovation in Education at the University of Kentucky and a partner at Student Achievement Partners. Matthew Gross, former head of the Regents Research Fund, is CEO of Newsela, a literacy technology company.
Sharren Bates is Senior Director at Lifion, another technology company. Iwan Streichenberger, inBloom’s former CEO, is an “executive consultant” advising “turn-around and business strategy” and “business/product launches.” Merryl Tisch is still Regents Chancellor, but has announced she will step down from the Regents this year, after twenty years on the Board. Stephanie Simon, whose investigating reporting was invaluable, not just on inBloom but on a whole host of education issues, is now Managing Editor of Stat News, a national journal covering medical and health issues.
I am still fighting for smaller classes at Class Size Matters, and still advocating for student privacy as the co-chair of the Parent Coalition for Student Privacy, which Colorado parent activist Rachael Stickland and I co-founded in July 2014, following inBloom’s demise. Please visit our website here.
 |
| Diane Ravitch, education historian and blogger |
1/28/13: Diane Ravitch re-posts on her blog another post I wrote on Data Privacy Day, again alerting parents to the plan of the Gates Foundation to collect as much personal student data as possible and share it with vendors. The original post is here, in which I urged NY parents to email Commissioner King, and demand that he not disclose their child’s data to the Shared Learning Collaborative.
1/31/2013: Mike Hall of Alvarez and Marsal, another Gates consultant on the data-sharing project, emails Ken Wagner and Kathleen Moorhead of NYSED, Amrit Singh of the Regents Research Fund; as well as officials in the nine other SLC states and districts alerting them to our attempt to get the message out to other parents about the risk this project represented, and to schedule a call to strategize their defense:
 |
| Mike Hall of Alvarez and Marsal |
“As you are aware a letter critical of the Shared Learning Collaborative and its partners was recently posted to a blog belonging to Diane Ravitch, an education policy analyst. The letter was written by NYC activist Leonie Haimson who is an outspoken critic of the Gates Foundation and other education reform efforts. Haimson, who heads the organization, Class Size Matters, is calling on parents to challenge the right of states and districts to leverage the SLC’s infrastructure to facilitate the sharing of student data with third party providers. For context, a version of the letter originally appeared on Haimson’s blog in October 2012, at which time the NY State Education Department took steps to address the concerns raised.” [Of course they did nothing of the kind.]
While we agree that privacy and data security are important issues, Haimson’s letter and ongoing critique of the SLC contain distortions and inaccuracies that we feel are important to correct and the SLC has posted several resources on its site that address these issues as well as posting a comment on Ravitch’s blog post. We also we recognize [sic] that you will need accurate information and tools to allay concerns among your stakeholders. In view of this we propose to hold a call to discuss any concern and identify what resources and strategies would be helpful to you. We recommend that you, the project lead for SLC implementation and your communications lead attend. Feel free to invite your superintendent and/or state chief to the call at your discretion. For this call, we ask that you come prepared to talk about any feedback you have already received from your stakeholders and to help us understand what your current communications priorities and strategies are.”
The company is headed by Iwan Streichenberger, formerly chief marketing officer of Promethean, a company that sells whiteboards. The Chief Product Officer is Sharren Bates, who led the ARIS project for DOE.
 |
| Iwan Streichenberger, inBloom CEO |
2/10/13: Hipps write Ken Wagner: “Per our conversation last week, here is the link to the letter from Steve Winnick as outside counsel confirming that inBloom’s approach to data privacy and security is FERPA compliant.
We shared with Mitchell Chester [Massachusetts State Commissioner] the NYSED letter responding to Leonie’s initial claims from Last October. He and his team really appreciated it. As I mentioned, we think that letter is really strong and would love to see you guys post that publicly. Given that you already consider it a public document, any chance of that happening?” [I’m not sure if they ever posted that unconvincing letter, but I did here.]
We shared with Mitchell Chester [Massachusetts State Commissioner] the NYSED letter responding to Leonie’s initial claims from Last October. He and his team really appreciated it. As I mentioned, we think that letter is really strong and would love to see you guys post that publicly. Given that you already consider it a public document, any chance of that happening?” [I’m not sure if they ever posted that unconvincing letter, but I did here.]
 |
| reporter Stephanie Simon |
“Entrepreneurs can't wait. ‘This is going to be a huge win for us," said Jeffrey Olen, a product manager at CompassLearning, which sells education software… While inBloom pledges to guard the data tightly, its own privacy policy states that it ‘cannot guarantee the security of the information stored ... or that the information will not be intercepted when it is being transmitted.’
Parents from New York and Louisiana have written state officials in protest. So have the Massachusetts chapters of the American Civil Liberties Union and Parent-Teacher Association. If student records leak, are hacked or abused, ‘What are the remedies for parents?’ asked Norman Siegel, a civil liberties attorney in New York who has been working with the protestors. "It's very troubling.’”
Simon’s story become the buzz at SXSWEdu, and is soon followed up by articles in the Hechinger Report, Politics 365, The Denver Post, and The Washington Post Answer Sheet. On the same day, hundreds of NY parents start sending opt-out letters and emails through our website to Commissioner King, Chancellor Walcott, Stacey Childress of the Gates Foundation, Michele Cahill of Carnegie Foundation, NY Attorney General Schneiderman, Regents Chancellor Merryl Tisch and Assembly Speaker Sheldon Silver, demanding that their children’s data not be disclosed to inBloom.
Simon’s story become the buzz at SXSWEdu, and is soon followed up by articles in the Hechinger Report, Politics 365, The Denver Post, and The Washington Post Answer Sheet. On the same day, hundreds of NY parents start sending opt-out letters and emails through our website to Commissioner King, Chancellor Walcott, Stacey Childress of the Gates Foundation, Michele Cahill of Carnegie Foundation, NY Attorney General Schneiderman, Regents Chancellor Merryl Tisch and Assembly Speaker Sheldon Silver, demanding that their children’s data not be disclosed to inBloom.
 |
| Bill Gates with Iwan Streichenberger at SXSWedu |
3/7/13: Bill Gates gives the closing address at SXSWEdu, focused on the potential of technology, innovation and data to transform education and “personalize learning.” He ends by sharing the stage with three technology CEOs who are “fostering this revolution”, including Iwan Streichenberger, newly appointed head of inBloom. “We do need a lot of risk-takers in this space, and that’s why it’s really great to see this now…In this space, we either improve the quality of education. Or we stay flat, like we have for the last few decades,” says Gates. Below is a screenshot during Streichenberger’s presentation. Video here.
 |
| Michele Cahill of Carnegie Corporation |
3/12/13: Ken Wagner emails Hipps, Streichenberg and Genevieve Haas of Waggener Edstrom, one of the Gates Foundation’s many PR consultants, with a “draft field memo…I am a bit tired and can no longer focus…I cannot tell for sure. I am most in need for you to make sure everything in the memo about inBloom is accurate.” [The memo is not attached.]
3/13/13: Haas responds that she is reviewing the memo and will get it back to him ASAP. “On a related note, we have seen an announcement from Leonie Haimson that she is holding press conference tomorrow in front of Tweed. Link below. We wanted to both make sure you were aware of the planned press conference and make sure you have whatever support you need from us on a response strategy.” Wagner responds, “Yes we are aware. Dennis [Tompkins] and Tom [Dunn] (copied here) planned to reach out for validator statements …I assume you folks saw the EPIC USED lawsuit [about the weakening of FERPA by the US Education Department to encourage data-sharing] in the WaPo."
The same day in Albany, NYS Assemblyman Daniel O’Donnell introduces bill A6059 to protect student privacy to block any vendor from redisclosing personal student data without parental consent, as inBloom was designed to do. It also would place strict security provisions on any vendor and require that they indemnify the state for breaches. NYS Senator Mark Grisanti soon introduces a companion bill in Senate, # S04284. The New York Daily News subsequently writes about the bill here. Within two weeks the bill has 38 co-sponsors in the Assembly and three in the Senate.
3/14/13: Class Size Matters holds a press conference on the steps of Tweed, the NYC DOE headquarters. Parents, Councilmembers Letitia James, Daniel Dromm and Stephen Levin all speak out against the state’s plan to share data with inBloom. Video of the press conference is here. The Daily News reports on the issue in a two page spread including an op-ed by me; the press conference is also covered by CBS News, GothamSchools, ABC Local, NBC New York, the Village Voice, the New York Daily News and WNYC/Schoolbook.
3/19/13: Genevieve Haas emails NYSED that Dori Marlin of CBS 6 News in Albany is working on a story on inBloom, “focused on whether inBloom can guarantee the security of student data, provisions for data breaches and whether inBloom will enable vendors to access the data.” Tom Dunn responds that Ken is being interviewed by the reporter the next day.
Haas sends them some talking points to be shared with the reporter: “…inBloom can be a game-changer by doing two things: first by giving teachers more time, more visilbility into what students need, and easier access to tools and resources, and second by making it possible to personalize learning for every kids in a classroom... Q Can inBloom GUARANTEE that NY students’ personal private information will not be compromised or intercepted? Data privacy and security is a top priority for inBloom. In this day and age no security protections can be 100% guaranteed …etc.”
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| CBS6 News screenshot |
3/15/13: Doug Jaffe of the NY Regents Research Fund plaintively asks Streichenberger and Hipps if they are “planning any validator quotes or statements that could be used to counter the current (inaccurate) narrative that is developing should it continue to gain traction?” Streichenberger says they are working with Waggener and have “engaged one of the journalists and are putting together a plan together.”
4/8/13: Tom Dunn sends to Gates, inBloom and Waggener Edstrom a copy of the letter that John King finally sent in response to the “800 parents who responded to Leonie’s petition.” King’s letter never uses the words inBloom, instead calls it the “NY’s Education Data Portal (EDP)” and claims it will greatly benefit students, “help teachers deliver high quality personalized instruction”, as well as “maintain stringent data security and privacy protections,” and achieve the goal of “preparing all children for college and careers.…”
4/19/13: Responding to Louisiana parent and school board outrage at finding out about inBloom from the media, and the fact that inBloom was collecting students' Social Security numbers along with their names and other personal information, Louisiana Superintendent John White announces he has changed his mind, and is pulling student data out of inBloom – the first state to do so. This signals the beginning of inBloom’s collapse, only six weeks after its launch.
Iwan Streichenberger writes to John King and to reporters that “an article was published this morning that had a number of inaccuracies about Lousiana’s continued involvement with inBloom.” He claims that Louisiana “remains part of the inBloom consortium.” John King asks Streichenberger if Louisiana or inBloom could “put out a press advisory clarifying these points.”
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| Superintendent John White of Louisiana |
This never happens, though Steve Winnick, an attorney on the inBloom payroll writes a statement affirming that their plans do not violate federal law, similar to an oped he had written for the WaPost AnswerSheet on March 28. Michael Gibbons, a security expert at Alvarez and Marsal, another paid Gates consultant, also composes a statement that says he has been reviewing inBloom’s system security documentation “for the past 4 weeks[!]” and his “impression is that there are no significant unmitigated risk to data at inBloom.”
4/22/13: Ken Wagner follows up, and again emphasizes the need for independent assessments of the safety and privacy of student data held by inBloom: “Iwan, These are good, but it is important to have validator statements from independent third parties (not paid by inBloom) Can you send some of these?”
4/23/13: Streichenberger writes to inBloom’s state partners, again attempting damage control regarding Louisiana Superintendent John White’s decision to pull out. He describes how Louisiana was initially Phase II state, but then “the team in Louisiana saw an opportunity to move more quickly…Last week, Superintendent White decided to pause their fast-track implementation in order to have the kinds of conversations with his Board and other stakeholders that Phase 1 states have been having for more than a year…The pause also supports Louisiana’s efforts to transition from using Social Security numbers to randomized student ID numbers, in keeping with inBloom’s requirements and with industry best practices….We welcome the chance to support your efforts to communicate clearly and transparently with your stakeholders, for your convenience I’ve attached a document with fact s about inBloom’s approach to privacy and security .”
When EdWeek follows up, and asks John White to respond to Streichenberger's comments that the state is only on "pause," White says, "I don't really know what it means," and emphasizes that the state no longer has any student data stored with inBloom.
4/25/13: Streichenberger thanks Ken Wagner for the time he took today to “catch up” and provides him with a “proposed statement for Commissioner King” that he could offer to mitigate some of the damage around Louisiana’s defection:
“We are confident that inBloom has made privacy and security of student data their highest priority, and are committed to working with them to improve instruction and achievement for all New York students. Following a recent meeting of the New York Board of Regents, where I shared with the Regents the vision for New York’s Education Data Portal, I want to restate my commitment to providing the best technology tools to support our educators in preparing students to be college and career ready. Making these tools available is frequently inefficient and inconvenient because they do not typically work as easily as they should with school and district data systems. This frustrates teachers and short-changes students and their families. For this reason, NYSED is excited to be partnering with the non-profit inBloom to provide New York with services to integrate our data systems. This will increase the educational technology options available to our schools and lower costs, all while protecting data security and the privacy of all students.”
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| An angry parent berating NYSED officials at our Town hall |
We invite NYSED officials to attend and answer questions. Dennis Tompkins, Chief of NYSED External Affairs, and Nicolas Storelli-Castro, Director of Governmental Relations, attend the meeting, though they refuse to speak or to answer any questions. Two Board of Regents members come and listen intently: Kathy Cashin of Brooklyn and Betty Rosa of the Bronx. Though we also invited Sharren Bates of inBloom and Stacey Childress of the Gates Foundation, they refused to attend or send any representatives. Adina Lopatin, Deputy Chief Academic Officer of NYC DOE, does answer some of our questions and reveals that much confidential NYC student data has already been uploaded into the inBloom cloud, which sparks even more parent outrage. My account and the videos of this event are here.
On the same day, Joe Scantlebury emails John King, urging him to “Stay Strong.” King replies with a quote from Martin Luther King that “justice too long delayed is justice denied.”
This is the end of the emails I received, as I requested communications only until May 1, 2013, having initially submitted the FOIL in June 2013. The following is from a timeline showing the sequence of events that followed. (A more detailed and extensive timeline is available here.)
5/4/13: Georgia Superintendent Dr. John Barge assures parents at a town hall meeting that he “will not share the student data with InBloom.” Georgia was listed as a Phase II inBloom “partner.”
5/13/13: Bill A7872, introduced by Chair of the NY Assembly Education Committee Cathy Nolan, is passed in the Assembly. The bill would allow parents to opt out of having their children’s personal information shared with third parties, unless required to do so by court order or for safety reasons.
5/21/13: Comptroller John Liu sends a letter, warning the Board of Regents and the Commissioner King against disclosing any student data to inBloom or to any other vendors without parental consent. A resolution is introduced in the NYC Council by Council Members Brewer, Jackson and Lander against the sharing of personal student data without parental consent and in support of the student privacy bill, A.6059 / S.4284.
5/28/13: At a candidate debate, all the Democratic candidates for NYC Mayor affirm their opposition to sharing student data with inBloom, except for Christine Quinn, who is not present. The candidates subsequently reaffirm their opposition in candidate surveys, again except for Christine Quinn.
5/29/13: Reporter Stephanie Simon writes another article for Reuters entitled “School database loses backers as parents balk over privacy.” She reveals for the first time that “Kentucky, Georgia and Delaware – all initially listed as partners on the inBloom website – told Reuters that they never made a commitment and have no intention of participating….Officials in two other states on the list, Massachusetts and North Carolina, said they are still evaluating the project and may never upload student data.” Among the remaining inBloom participants only three remain clearly committed: New York, Colorado, and Illinois.
5/28/13: CNN runs a segment on the inBloom controversy, drawing further national attention.
8/1/13: Guilford County schools officially pull out of using inBloom — the one inBloom pilot district in North Carolina.
9/4/13: S.5930-2013 is introduced in the NY State Senate, the same student privacy bill as A7872, already passed by the Assembly.
9/4/13: Public Advocate Bill de Blasio, who will be elected NYC mayor in November, tells the New York Daily News, “As mayor, I will protect students’ privacy and stop this needless invasion of privacy.”
9/23/13: Despite the loss of all the states but three, Sharren Bates, the chief product officer of inBloom, tells Information Week, “The project is going well -- it's in the green. You will see production dashboards in the fall."
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| JeffCo Superintendent Cindy Stevenson |
9/30/13: The NYC Council Education Committee holds hearings on inBloom and Resolution 1768-2013 in support of the state bills to block the project. Many parents and advocates including Class Size Matters testify against the data-sharing project. Ken Wagner, the NYSED Deputy Commissioner testifies and insists that the sharing of student data with inBloom Inc. and other vendors is important to ensure that students are college and career ready. Though inBloom officials are asked to testify, they claim a “prior engagement."
10/6/13: An article about inBloom finally appears in the NY Times, more than seven months after inBloom’s launch. While the article by Natasha Singer provides a thorough exploration of inBloom’s pros and cons, it focuses almost exclusively on Jefferson County in Colorado, with only three sentences on NY state’s participation in the data-sharing project.
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| Superintendent David Gamberg |
10/28/13: Southold schools Superintendent David Gamberg writes to inBloom, demanding that his district’s student data be deleted from the inBloom data system. In the letter, Gamberg quotes a specific provision in NY’s service agreement that clearly states “If a school district decides they no longer wish to use the SLI system, they may request that district student data be deleted from the SLI data store.” More about this here and here. InBloom fails to respond.
11/7/13: The school board election in Jefferson County in Colorado causes a major turnover in members, with an anti-inBloom majority elected. The pro-inBloom JeffCo Superintendent immediately resigns, and the existing school board votes to sever its contract with inBloom. Now, only New York and Illinois remain participants in inBloom.
11/13/13: A lawsuit is filed on behalf of NYC parents to bar NYS Education Department and Commissioner King from sharing personal data with inBloom on the grounds that this violates the state’s Personal Privacy Protection Law.
11/20/13: The NYS Assembly Education Committee holds
a hearing on student privacy where Commissioner John King and Ken Wagner
are grilled by the Assemblymembers. Parents, state superintendents, and Class Size
Matters testify
against the sharing of personally identifiable student information with third
parties. A video of the hearing can be found here.
Though InBloom officials are asked to testify, they again claim a "prior engagement" -- the same response the NYC Council received from the company when the Education Committee held their hearings the prior month.
Commissioner John King testifies
that the state has already uploaded a large amount of personal student data to
the inBloom cloud, only without student names attached, to help inBloom
"test" and develop their infrastructure -- though both Wagner
and King avoided answering questions about what exact data elements were
shared. Ken Wagner also explains
how soon, each district will have to pay a per student fee to both inBloom and
the vendors of the data dashboards that will be populated by student data from
the inBloom cloud.
Though InBloom officials are asked to testify, they again claim a "prior engagement" -- the same response the NYC Council received from the company when the Education Committee held their hearings the prior month.
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| John King and Ken Wagner at the Assembly hearings on inBloom |
11/ 21/13: Chicago parent groups PURE and More than a Score along with the Chicago Teachers Union hold a forum on inBloom, at which I speak. Earlier that same day, we meet with the editorial boards of the Chicago Tribune and Chicago Sun Times to discuss the project’s risk to student privacy. At the forum that evening, Brandon Williams of the Illinois State Board of Education confides to a CTU representative that the issue was getting too “hot”. He confides that Illinois Commissioner Chris Koch has decided to keep the state’s student data system separate from inBloom, and to make district participation voluntary. Almost immediately, on Nov. 26, Chicago officials announce that they will not participate. The next day, Stephanie Simon reports on Twitter that Illinois has decided to completely withdraw from inBloom. At this point, New York State is inBloom’s last remaining known client.
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| Assembly Education Chair Cathy Nolan |
12/16/13: NY Assembly Education Chair Cathy Nolan along with scores of other Assemblymembers send a letter to Commissioner John King, thanking him for his testimony, and saying that “We do not believe the State Education Department should share [student] information with InBloom, especially not at this time.” Three days later, the leader of the Assembly, Speaker Sheldon Silver calls on State Education Department to suspend the state’s participation in the project.
1/8/14: In legal filings in response to our lawsuit, the NY Attorney General reveals that NYSED has moved back its date for the transfer of data to inBloom to no earlier than April 1, 2014. NYSED claims the delay is caused by their “contractors” running behind schedule. In response to my tweeted question, the inBloom CPO, Sharren Bates disputes this claim:
@leoniehaimson @AssessWell @ADKEducation @gsuhm Our dev backlog is public & shows no current tech delays.
— sharren bates (@sharrensharren) January 9, 2014
2/7/14: Judge Thomas Breslin of the New York Supreme Court dismisses our lawsuit to prevent the NY State Education Department from uploading personal student data to inBloom.
2/10/14: Commissioner John King announces that “the State has delayed the launch of the data dashboards related to inBloom to allow SED to work with legislators to address concerns about data security and third party providers used by the State and districts.” Yet ten days later, NYSED officials reveal that they still intend to share data with inBloom as early as July.
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| Assembly Member O'Donnell questioning Ken Wagner |
3/5/14: The full NYS Assembly passes A8929 by a vote of 117-10, which would allow parents to opt out of the sharing of personal student information with vendors. Read more about the bill’s passage here.
3/10/14: Governor Cuomo’s Common Core Commission recommends the state end its relationship with inBloom, among other proposals in their report “Common Core Implementation Panel: Putting Student First”. Read more here.
3/23/14: The Wall Street Journal, owned by Rupert Murdoch, runs its first story on inBloom , and falsely reports that inBloom still has three clients, including NY, Massachusetts and Illinois, though both Massachusetts and Illinois have already signaled otherwise. The story leads with a quote from Steven Ross, a professor at the Center for Research and Reform in Education at Johns Hopkins, who claims that data-sharing is the only way to improve schools, as “using data to help tailor education to individuals will drive learning in the future. ‘Most of us in research and education policy think that for today's and tomorrow's generation of kids, it's probably the only way.’”
Unreported is the fact that Ross’s Center has recently received a large grant from the Gates Foundation “to promote specific improvements in the purchasing practices of K-12 school district buyers as they seek to implement innovative digital technology products and services.”
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| Steven Ross Johns Hopkins professor and inBloom enthusiast |
Unreported is the fact that Ross’s Center has recently received a large grant from the Gates Foundation “to promote specific improvements in the purchasing practices of K-12 school district buyers as they seek to implement innovative digital technology products and services.”
The article also contains reassuring statements from inBloom’s Chief Privacy officer, Virginia Bartlett, that a breach from the inBloom cloud is nearly impossible: “The data is stored through Amazon Web Services in what she describes as a safe-deposit box. Even if there was a leak of data, she says, it would be nearly impossible to use.”
Unmentioned is how inBloom wrote its privacy policy to say that they would not be responsible if the data breached in storage or transmission.
Unmentioned is how inBloom wrote its privacy policy to say that they would not be responsible if the data breached in storage or transmission.
3/31/14: The New York legislature approves the 2014-2015 state budget bill which includes a provision barring the NY State Education Department from sharing personal student data with any “Shared Learning infrastructure service provider” or “SLISP” –that is, a company storing the information for the purpose of sharing it with a data dashboard provider. This provision is written to prevent the state from sharing student data with inBloom. For more information on the other privacy provisions in the bill, read our blog post here.
4/2/14: Stephanie Simon, now a reporter for Politico, writes that the New York State Education Department has directed inBloom to delete all their student data. The Journal News reports a statement by Dennis Tompkins of NYSED: “As required by statute, we will not store any student data with inBloom and we have directed inBloom to securely delete the non-identifiable data that has been stored.” Given that NY is the last known inBloom client, the company’s future looks extremely shaky.
4/21/14: inBloom’s CEO Iwan Streichenberger announces that the company is shutting down, nearly three years after we first wrote about this data-sharing project. See our statement here.
Epilogue: As you have seen, neither NYSED, the Gates Foundation nor their many paid consultants, lobbyists and non-profits they funded were able to figure out a message that would quell parents’ anger at being left out of the decision-making loop, anger which was quickly communicated to elected school board members, district Superintendents, legislators, and even the Governor.
Though among the emails I received there was no smoking gun, no damning revelation showing why NYSED officials signed on with such alacrity to the inBloom deal, there was plenty of evidence of the various grants and travel expenses offered that helped induce them into an ongoing alliance with the Gates Foundation, the richest foundation in the world, with its own personal interest in facilitating the exchange of as much student data as possible with ed tech vendors and assorted researchers.
The inBloom debacle not only led to the Gates Foundation losing over $120 million, but kickstarted a debate over student privacy that continues to this day, as parents became aware for the first time how vulnerable their children’s personal information was to being shared with a host of ed tech vendors, services providers, and other private organizations for a variety of purposes and goals.
According to the Data Quality Campaign, a Gates grantee, 110 bills on student data privacy were introduced in 2014, and twenty states approved 28 of these bills. In 2015, 36 states had 110 student privacy bills, and 24 of these bills were approved in 21 states. At least five federal student privacy bills have now been introduced in Congress. Rarely have public school parents had so much immediate impact on an issue of such importance to powerful and wealthy interests, though few if any of the bills approved so far are strong enough, in our view.
Several of those responsible for inBloom and who were so dismissive of parents’ privacy concerns, were promoted following its collapse. John King is now the Acting Secretary of the US Education Department. Stacey Childress, who led the inBloom project for the Gates Foundation, is CEO of the New Schools Venture Fund, which raises capital to expand charter schools and online learning. Ken Wagner was appointed Rhode Island’s Education Commissioner. Henry Hipps and Allen Golston are still at the Gates Foundation, while Joe Scantlebury is Vice President of the Kellogg Foundation. Debbie Robinson, Communications Officer for Gates, is now the VP for Government Affairs and Communications at Education Trust.
Michele Cahill, formerly Carnegie Vice President, is now a Distinguished Fellow in Education and Youth Development at the National Center for Civic Innovation. Gene Wilhoit, who helped spearhead the project when he was head of the Council of Chief State School Officers, is the CEO of the Center for Innovation in Education at the University of Kentucky and a partner at Student Achievement Partners. Matthew Gross, former head of the Regents Research Fund, is CEO of Newsela, a literacy technology company.
Sharren Bates is Senior Director at Lifion, another technology company. Iwan Streichenberger, inBloom’s former CEO, is an “executive consultant” advising “turn-around and business strategy” and “business/product launches.” Merryl Tisch is still Regents Chancellor, but has announced she will step down from the Regents this year, after twenty years on the Board. Stephanie Simon, whose investigating reporting was invaluable, not just on inBloom but on a whole host of education issues, is now Managing Editor of Stat News, a national journal covering medical and health issues.
I am still fighting for smaller classes at Class Size Matters, and still advocating for student privacy as the co-chair of the Parent Coalition for Student Privacy, which Colorado parent activist Rachael Stickland and I co-founded in July 2014, following inBloom’s demise. Please visit our website here.
Thank you for writing this post. I am curious about whether the collection of data that occurs when students are assessed with either PARCC or Smarter Balanced will allow the supporters of inBloom to achieve their purpose of mining student data. In other words, aren't inBloom's supporters still going to be able to access student data under the guise of testing?
ReplyDeleteAlso, I would like to see federal and state legislation that requires every official or representative connected to education in any capacity to be required to divulge the source of funding, including grants, from any source that pays for trips, conferences, training, consulting fees, etc.