What are the key considerations when utilizing educational data? Learning of Tomorrow Submits Public Comments

　

The General Incorporated Association Learning of Tomorrow (http://lot.or.jp/), which promotes the utilization of educational data, submitted the following public comments to the Digital Agency.

　

■ Use of Educational Data—Public Comment ■

November
25, 2021, Learning of Tomorrow (General Incorporated Association)

Throughout Questions 1 and 2, decentralized management should be established as a fundamental principle, and this should be explicitly stated.
Specifically, we propose the following policy:

・Standardize the APIs for the e-Learning Portal and require disclosure to the PDS

・The PDS is decentralized (with the user as the sole data controller), and access to the learning e-portal's API is limited to applications running on personal devices.

・Ensuring that data subjects (students and teachers) themselves manage and utilize educational data—including electronic certificates of academic history—in conjunction with other personal data

・Organizations to which learners’ parents or teachers belong should also be able to manage and utilize educational data based on the data subject’s consent or a legal basis.

　

Question 1: What do you think are the key points to keep in mind when utilizing educational data?

There are three points to keep in mind.

1) Definition of Educational Data

Clarification of data involving teachers, learners, parents, educational institutions, private organizations, and others

2) Establishment of Basic Rules (Guidelines)

The Nature of Rights Regarding the Creation, Ownership, Modification, and Access to Data

Approaches to Obtaining Consent for the Use and Utilization of Various Data Sets

3) Clarification of Data Management Guidelines

Principles of Openness for Utilization

Ensuring Safety and Stability

The specific details are as follows.

・It is necessary to establish definitions for educational data. When considering the utilization of educational data, it is essential to formulate guidelines for defining such data and standardizing its specifications, as these serve as the foundation for its use. Since multiple government agencies and industries are involved in the process of developing these guidelines, it is important for the Digital Agency to lead a cross-sectoral effort that involves relevant government agencies and private-sector entities.

・We should clearly distinguish between public data collected by schools and private data collected by private-sector entities, and establish clear rules governing their handling, including coordination between the two. A system is needed that allows private-sector education service providers to make broad, timely, and appropriate use of public data in their research and development efforts.

・Educational data must be handled appropriately to prevent leaks and unauthorized use. It is necessary to encourage users more than ever before to participate in educational programs and training designed to foster digital literacy. In addition, attention should be paid to securing efficient resources (such as support staff, grants, and official certifications) to support teachers’ transition to digital teaching.To provide literacy education, we should promote the support and development of operational systems that enable the expansion and creation of relevant content.

　

Question 2: What do you think is necessary when building an architecture for the accumulation and distribution of educational data?

 You should present a simple and easy-to-understand architectural concept that includes the following four points.

1) The Nature of Certification

Individual Authentication

Verification of Individual Relationships (Teacher, Student, and Parent Relationships)

Organizational Certification

2) Organizing Data Access Rights

Rights Regarding Ownership, Modification, and Access to Data

3) Formulation of Guidelines for Standardization Initiatives

4) Clarifying the division of responsibility for terminal and network infrastructure maintenance and security

The specific details are as follows.

・In the provided architectural diagram, the distinction between existing elements at the site and new elements is unclear, which could lead to confusion. It is necessary to organize the information so that stakeholders can correctly understand the overall architecture and the guidelines for its design.

・It is necessary to present a “roadmap” that clarifies the entities responsible for reviewing the basic rules, the deadlines for such reviews, and the review plan. By providing clear guidelines on how stakeholders for each type of data are defined—with a focus on a structure in which learners manage and operate their own data—it becomes possible to implement an architecture that delivers benefits to learners.

・An architecture that ensures interoperability across all schools and the organizations where learners are employed is necessary. Furthermore, we should look ahead to the utilization of data through means such as API integration with private-sector entities. An ID is needed that allows learners to manage their educational data in a comprehensive and cross-cutting manner. In accordance with the principle of decentralized management, this should be a self-sovereign ID managed by the learner themselves.

・I believe that both student and faculty/staff devices should allow for the use of data—including school administrative information—anytime and anywhere under appropriate authentication and access controls, and that proper management and storage, such as through encryption, are essential.

　

Furthermore, I believe that, as a fundamental premise for this question, consideration of the following three points is also required.

○ Necessary Verifications as a Prerequisite for the Use of Educational Data

What benefits will stakeholders derive from the development of this system architecture? Furthermore, is it necessary to describe specific needs, or to outline the added value compared to traditional education? (This applies to learners—including not only children in the school system but also working adults—as well as educators such as teachers in compulsory and higher education, and businesses.)

○ Scope

While the government’s policy is to create a roadmap with a view to future integration of data from both within and outside schools, the description of how data from outside schools will be handled is not necessarily sufficient; therefore, shouldn’t discussions on this point continue?

○ Not only visualizing learning history, but also from the perspective of ensuring the quality of learning history

Isn't the introduction of so-called "badges" and the like a prerequisite for data utilization?