Student & Staff Data Privacy FAQ for School Records
Portrait Express is a trusted provider of school services, providing portrait and photography services to schools and families throughout North America since 1983. In preparation for Picture Day, Portrait Express requires certain directory - type information from your school (“School Data”), to be used as follows :
• To produce and deliver to schools the portrait - based products and services needed for the school’s administrative purposes and/or for use in the school yearbook (the “School Service Items”) ; and
• To deliver Picture Day notices on behalf of your school and provide parents of students photographed opportunities to purchase portraits.
The following FAQs are intended to further demonstrate Portrait Express’s commitment to responsible stewardship of your School Data.
What School Data does Portrait Express collect? The data we need for Picture Day depends upon the specific services and deliverables your photographer is providing to your school. We limit collection to only that which is necessary for an authorized school purpose. We collect basic roster and classroom information in advance of Picture Day to ensure a perfect name - image match for each portrait and for efficient distribution within the school. In some cases, we collect parents’ email addresses in order to deliver Picture Day - related communications. In such cases, we do not retain or use such information for any other purpose. In addition, School Data may be incorporated into School Service Items. For example, if Portrait Express is producing student ID cards, we need the student ID number to do the job. Schools ultimately decide how much, or how little, information is used in producing School Service Items.
How does Portrait Express use School Data? Portrait Express uses School Data solely as necessary to create, offer and deliver student images and school administrative services to the school and families of the students. Portrait Express will not sell or license such data to others. To the extent service providers are employed by Portrait Express to assist in fulfilling Portrait Express’s obligations, we require compliance with strict confidentiality and security measures. Portrait Express retains School Data only as necessary and permissible to promote the sale of portraits to parents, to retrieve the images to supply picture orders for the current school year and to support the school for an approved administrative purpose. Once such data is no longer needed for these purposes, it is securely destroyed. While retained, images remain under Portrait Express’s control and treated as confidential information.
What about FERPA - does the law allow disclosure of School Data to Portrait Express? Yes. Portrait Express acknowledges its obligations as a service provider to your school for student and staff photography pursuant to the federal Family Educational Rights and Privacy Act (FERPA), 20 U. S. C. § 1232 g and its implementing regulations, 34 CFR part 99. As such, we affirm that Portrait Express has a legitimate need for certain School Data to provide photographic services and products for the school’s administrative needs. Your school retains the authority to control Portrait Express’s use of School Data, including the right to require the return or destruction of any School Data provided to Portrait Express at any time. Additionally, Portrait Express will strive to meet any additional data handling requirements as prescribed by state law and/or school district policies, as long as we are notified of the same prior to disclosure.
How does Portrait Express protect School Data? Portrait Express employs a variety of physical, technical and organizational security measures to help protect School Data from unauthorized access and use.
Facilities. Portrait Express produces portraits and School Service Items within its own U. S. - based photo labs. Portrait Express network devices are located in a secure datacenter facility under direct control by Portrait Express employees.
Networks. Devices storing or providing access to School Data are protected with the same multi - layered security strategies that we use to protect Portrait Express’s sensitive and confidential business records. Image databases supporting our photo processing labs and websites are separated from associated data files containing identifiable information, and all databases are protected by firewalls, monitoring, vulnerability scanning and authentication procedures. We perform regular network penetration testing and intrusion prevention methods. Our systems enable secure transmission of School Data from and to the Portrait Express network with encryption technologies.
Personnel. Portrait Express’s policy is to collect, use and disclose personal information only in ways that are consistent with our respect for an individual’s privacy. We require Portrait Express employees to sign confidentiality agreements as a condition of employment, and provide training on the appropriate use and handling of School Data. Access to School Data is limited to those who need it to perform their jobs. We take appropriate measures to enforce these policies.