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Effective Date: January 11, 2023
Date Last Updated: October 16, 2024

The Conover Company is committed to ensuring student privacy in accordance with local, state and federal regulations and agency policies. To this end, and pursuant to U.S. Department of Education regulations, The Conover Company is providing the following Parents’ Bill of Rights for Data Privacy and Security:

1. A student’s personally identifiable information (PII) will not be sold or released for any commercial purpose. PII, as defined by Education Law § 2-d and FERPA, includes direct identifiers such as a student’s name or identification number, parent’s name, or address; and indirect identifiers such as a student’s date of birth, which when linked to or combined with other information can be used to distinguish or trace a student’s identity. Please see FERPA’s regulations at 34 CFR 99.3 for a more complete definition.
2. Parents have the right to inspect and review the complete contents of their child’s education record, including any student data maintained by The Conover Company. This right of inspection of records is consistent with the federal Family Educational Rights and Privacy Act (FERPA). Under the more recently adopted regulations (Education Law §2-d), the rights of inspection are extended to include data, meaning parents have the right to inspect or receive copies of any data in their child’s educational record. The New York State Education Department (NYSED) will develop further policies and procedures related to these rights in the future.
3. State and federal laws such as Education Law § 2-d; the Commissioner of Education’s Regulations at 8 NYCRR Part 121, the Family Educational Rights and Privacy Act (“FERPA”) at 12 U.S.C. 1232g (34 CFR Part 99); Children’s Online Privacy Protection Act (“COPPA”) at 15 U.S.C. 6501-6502 (16 CFR Part 312); Protection of Pupil Rights Amendment (“PPRA”) at 20 U.S.C. 1232h (34 CFR Part 98); the Individuals with Disabilities Education Act (“IDEA”) at 20 U.S.C. 1400 et seq. (34 CFR Part 300); protect the confidentiality of a student’s identifiable information.
4. State and federal laws protect the confidentiality of personally identifiable information and safeguards associated with industry standards and best practices, including but not limited to, encryption, firewalls and password protection, is in place when data is stored or transferred.
5. Parents have the right to file complaints about possible breaches of student data. Complaints should be directed to: The Conover Company Data Protection Officer, 4 Brookwood Court, Appleton, Wisconsin 54914 or via email at privacy@conovercompany.com. Complaints to NYSED should be directed to: Chief Privacy Officer, New York State Education Department, 89 Washington Avenue, Albany, NY 12234; e-mail address is cpo@mail.nysed.gov.
6. The Conover Company will notify all affected parties if we identify a breach or unauthorized release of PII occurs: https://www.conovercompany.com/legal/security-policy/
7. Conover Company employees that handle PII will receive training on applicable state and federal laws, policies, and safeguards associated with industry standards and best practices that protect PII.
8. This bill of rights is subject to change based on regulations of the commissioner of education and the New York State Education Department chief privacy officer. Changes/additions are also anticipated as NYSED releases further guidance documents.

Click here to view NYSED’s Parents’ Bill of Rights
https://www.nysed.gov/student-data-privacy/student-data-privacy-bill-rights-parents-bill-rights