Colorado Student Data Transparency and Security Guide

Primary Law

Student Data Transparency and Security Act

Citation

Colorado Revised Statutes, Article 16 of Title 22 (C.R.S. 22-16-101 et seq.; originally enacted by HB 16-1423)

Official Text

https://leg.colorado.gov/sites/default/files/2016a_1423_signed.pdf

Overview

Colorado’s Student Data Transparency and Security Act establishes statewide expectations for the collection, use, protection, and disclosure of student personally identifiable information (PII). The law emphasizes transparency, purpose limitation, reasonable security safeguards, and accountability when student data is accessed or processed by vendors or service providers.

Rather than mandating a single compliance mechanism, Colorado’s framework focuses on how student data may be used and safeguarded, particularly when vendors provide educational services to districts. Districts are expected to combine documented oversight, transparency practices, and enforceable limitations on vendor data use.

Applicability and Scope

Colorado’s requirements are most relevant when:

• Student PII is shared with vendors or service providers in connection with instructional, assessment, administrative, or analytics services
• Districts use online or cloud-based educational tools that collect or process student data
• Student data systems integrate with third-party platforms through roster synchronization, exports, or APIs

The statute distinguishes between vendor relationships that operate under formal agreements and other types of services, but in all cases centers on lawful purpose, disclosure limits, and data protection.

Transparency and Documentation Expectations

Colorado emphasizes transparency and accountability in student data practices. Districts commonly support this by:

• Maintaining an inventory of tools and services that collect or receive student data
• Documenting categories of data shared and the educational purpose for that sharing
• Identifying applicable safeguards, limitations, and oversight mechanisms

These practices support both statutory transparency goals and parent/community visibility.

Vendor Data Use Controls and Purpose Limitation

Colorado law restricts vendors from using student data beyond authorized educational purposes and prohibits uses such as targeted advertising or unrelated profiling.

Districts should ensure, through documented vetting, approval records, and ongoing oversight, that vendors use student data only to deliver the educational service for which it was provided. Where districts enter into formal agreements, those agreements typically reflect purpose limitation and downstream obligations for subprocessors, but the statute itself focuses on permitted use, not on mandating contracts.

Security Safeguards and Incident Readiness

The Act aligns with expectations for reasonable security practices appropriate to the sensitivity of student data. District oversight commonly includes:

• Confirming vendors can describe administrative, technical, and physical safeguards
• Understanding breach response procedures and notification timelines
• Documenting retention, deletion, and data disposition practices

These measures support incident readiness and audit preparedness.

How Can EdPrivacy Help Colorado Schools

Colorado districts benefit from a centralized, repeatable way to document student data use, vendor practices, and approval decisions across a growing ecosystem of tools.

EdPrivacy helps districts:

• Maintain a living inventory of district-approved tools and identify which receive student PII
• Organize vendor privacy policies, agreements (where used), and security documentation
• Record approval rationale and district-specific guardrails (purpose limitation, sharing constraints, retention and deletion)
• Prompt periodic re-review when vendors update policies, add integrations, or change subprocessors

Summary

Colorado districts should be prepared to:

• Maintain transparency through clear documentation of student data sharing
• Enforce purpose limitation and vendor accountability through governance and review processes
• Verify reasonable security safeguards and incident response readiness
• Monitor vendor practices over time as products and data uses evolve

Colorado’s Student Data Transparency and Security Act supports a governance-forward approach centered on transparency, security safeguards, and enforceable limits on how student data may be used, rather than a universal requirement for signed contracts.