Dear School Administrators, School Boards, and Parent Associations,
If you assume Google is careful to protect your students when they use Google Apps for Education, you are sadly mistaken.
Too many assume that someone else must have done the due diligence necessary to ensure that Google Apps for Education adequately protects students’ privacy and safety, because they unfortunately did not. If they had, they would have been alarmed at Google’s shocking history of knowing disregard for the privacy and safety of their users including students.
This open letter will spotlight student privacy/safety concerns with Google that responsible parents and educators would want to know, given that Google Apps for Education, and Google’s other services, pervasively insinuate themselves into so many aspects of their students’ education and private lives.
It also will provide an important jumpstart to long-overdue, better due diligence of Google’s impact on student privacy and safety. Better late than never, the old adage says.
Parents and educators would never tolerate an “open-door policy” for outsiders to physically enter and freely roam a school’s grounds without accountable-entry-points and approved-adult-oversight to prevent harms to the students entrusted to their care, yet they unwittingly have acquiesced to Google’s “open-door policy” that allows unapproved outsiders to effectively enter and roam schools virtually via many Google services.
What follows is some brief, but important due diligence information that educators collectively could have gleaned from public sources, if they were as vigilant in protecting their students’ privacy and safety online as they are vigilant on school grounds. Out of sight out of mind, the old adage says.
I. Due Diligence Summary of Google Apps for Education Student Privacy/Safety Failings
A. Google knowingly violates its privacy representations and FERPA law
B. Google knowingly allowed the marketing of illegal drugs to minors for years
C. “Google’s social network is playground for online predators”
D. Google has no curation/preventative-policing to protect minors from harmful material
E. Google is lobbying against distracting driving legislation to protect Google Glass sales
II. Google Apps for Education Student Privacy/Safety Failings
A. Google knowingly violates its privacy representations and FERPA law
Consider the action-forcing event that prompted this open letter. In March, Education Week reported that Google -- in violation of both its privacy representations to schools and the Federal Educational Rights and Privacy Act (FERPA) -- was exposed in a civil suit deposition for secretly reading and profiling all student-Gmail before it was received.
In a mea culpa blog post on April 29th, Google effectively admitted that until April 29th 2014, Google secretly had been illegally collecting private student data for advertising purposes in violation of their privacy representations and FERPA. The analysis here explains why this three-years-late, privacy-violation disclosure is inadequate and misleading.
In addition, Google’s disrespect for privacy is well-documented in both Google’s corporate rap sheet and a detailed report of Google’s privacy practices for regulators.
B. Google knowingly allowed the marketing of illegal drugs to minors for years
From 2004-2011, after repeated warnings from law enforcement, Google knowingly made it easy for minors to find and buy illegal drugs like steroids and Percocet. In 2011 in a criminal non-prosecutionagreement, Google admitted to knowingly and repeatedly violating Federal criminal laws against the“unsafe and unlawful importation of prescription drugs" into the U.S. for several years. For this, Google paid a near record $500m criminal forfeiture penalty. The Rhode Island U.S. Attorney who led the Google criminal probe said the evidence was clear that current Google CEO “Larry Page knew what was going on."
Has Google cleaned up its act as a result of this half a billion dollar criminal forfeiture penalty? Sadly, the answer is no.
Just last November, Mississippi Attorney General Jim Hood wrote to Google CEO Larry Page in a (11-27-13) letter: “In my 10 years as attorney general, I have dealt with a lot of large corporate wrongdoers. I must say that yours is the first I have encountered to have no corporate conscience for the safety of its customers…” “Although Google claims to be interested in cooperating with state attorneys general, it is unwilling to take basic actions to make the Internet safe from unlawful and predatory conduct, and it has refused to modify its own behavior that facilitates and profits from unlawful conduct,” like promoting and advertising illegal drugs and stolen goods for sale.
Even after another serious warning by state attorneys general in the November 2013 letter, a 2014 Digital Citizens Alliance report entitled “Digital Weeds: How Google Continues to Allow Bad Actors to Flourish on YouTube,” shows evidence of how Google continues to promote search results and present advertising for searches such as these to students: “Buy Percocet without a prescription;” “buy steroids online;” and “find underage prostitute.”
In addition, there is a substantial body of public evidence that Google repeatedly violated the DOJ-Google Criminal Non-Prosecution Agreement – see report.
C. “Google’s social network is playground for online predators”
Any responsible parent or educator would be appalled to learn that a Consumer Watchdog study last December found: “Google’s Social Network is Playground for Online Predators, Explicit Sexual Content, Tech Whistleblower Finds; Consumer Watchdog Says Google Must Police Google+.” Google+ is Google’s social media application with about a half a billion users, many of whom are minors. The Consumer Watchdog study found that Google had long ignored complaints by users and parents that Google+ was a haven for pedophile communities and sexual predators. Frighteningly, Google has aggressively integrated Google+ with a wide variety of Google’s products and services that students and minors routinely use.
This January Consumer Watchdog reported: “Google+ Shuts Online Predators’ Accounts In Response to Consumer Watchdog Letter, But Key Privacy Design Flaw Remains and Must Be Fixed.” Only when confronted publicly with the illegal predatory activity against minors on Google+, did Google finally ban particular predators, but tellingly Google did not change the core Google policy that created the problem in the first place and that would allow the predators to return and continue to prey on different minors in the future.
Astonishingly, Google still allows anyone to join anyone else’s Google+ Circle without a person’s permission. Thus this allows any known sex offender or predator to join any child’s Circle and the child or parent cannot remove that person from their Circle, despite longstanding repeated complaints to Google from parents concerned for their children’s safety.
D. Google has no curation/preventative-policing to protect minors from harmful material
Google has an effective no-curation policy for YouTube and Google Play, and other Google services. This means Google, unlike Apple, allows anyone to upload any content or application to YouTube or Google Play without Google’s prior review to determine if the content or apps are illegal, dangerous, indecent, inappropriate for minors, etc.
Google relies on users to find and complain about potential dangers and problems and then Google will take them down -- after they have been able to harm unwitting students and users. This is an outgrowth of Google’s longstanding security policy to delegate its first line of enforcement to users not Google personnel, effectively because its puts the online freedoms of potential bad actors above the privacy and safety interests of its users and minors. Google’s aggressive outsourcing of its corporate responsibility to others predictably dramatically lowers Google’s costs and increases Google’s profit at the privacy and safety expense of unwitting users and students.
For a recent appalling example of the dangers to students of Google’s no curation or age appropriate screening see this article in The Telegraph entitled “Hardcore porn on sale next to children’s books in Google’s online store: Parents outraged as Google Play book store sells titles with graphic images and content alongside children’s literature.”
What responsible parent or educator knowingly would want educational materials used by students in their school to not be reviewed by any adult in a position of responsibility prior to the students gaining access to the inappropriate materials? Parents and schools incorrectly assume that Google as a general rule takes special precautions to ensure that minors are not exposed to inappropriate, indecent or harmful material; Google generally does not. Think about the implications of that anything-goes Google philosophy on student’s formative years.
E. Google is lobbying against distracting driving legislation to protect Google Glass sales
A Reuter’s article, “Google Sets Roadblocks to Stop Distracted Driver Legislation,” reports “Google is lobbying officials in at least three U.S. States to stop proposed restrictions on driving with headsets such as Google Glass.”
CNET Editor Molly Wood produced an excellent 2 minute video worth watching that shows why Google Glass, combined with motion, is dangerous and “a disaster waiting to happen.”
Google Glass projects a small screen up and away from one’s normal field of vision. Google trumpets Glass as a hands free device, implying no or less distraction. That is highly misleading because Glass is not an eye-free device; it’s an eye-attention device. To gain Google Glass’s benefits one must shift one’s vision and cognitive attention away from what they are doing and refocus their vision and cognitive attention on a very small projected screen above one’s eye, which can take time, especially in the changing lighting environment of driving.
This reckless Google policy of putting sales of Google Glass ahead of the safety of bus drivers, students, parents, and teachers on their way to and from school each day, and the safety of the public overall, is emblematic of Google’s reckless disregard for the safety of others.
Do school administrators, school boards, and parent associations share Google’s values and safety position on the serious teen safety issue of distracted driving?
III. Conclusion
Unfortunately, school administrators and school boards have not done effective due diligence on Google Apps for Education. They have assumed that because Google is a popular, well-known brand that many other schools use, it must be suitable for their children and students, even when copious, publicly-available facts prove the contrary. They also assume from Google’s popular brand that Google must also be a responsible corporate citizen, when actually it has a pervasive culture of unaccountability.
There is no question that Google does a lot of things right and offers free services that appeal to resource-constrained and innovation-minded educators.
However, there is also no question that Google has corporate record with law enforcement on privacy and public safety matters that should give any school administrator, school board, or parent association serious pause.
Don’t assume others have done adequate due diligence on Google Apps for Education. They haven’t, given their unwitting obliviousness to Google’s well-established, public-record of long-standing and repeated reckless disregard for the privacy and safety of others, including minors.
It’s never too late to start doing the right thing, which is don’t assume, but do responsible due diligence to determine if Google’s privacy and safety representations are true and if their track-record is worthy of the blind trust that educators and parents apparently have given the Google brand.
Ask Google to explain why they continue to have so many serious problems throughout their organization in respecting and protecting their users’ privacy and safety, especially their most vulnerable users who are minors.
Ask Google why they shoot the messenger when they don’t like the message.
Ask Google why they think their business standards for serving adults are suitable and sufficient business standards for protecting minors.
Forewarned is forearmed.
Sincerely,
Scott Cleland
Publisher, GoogleMonitor.com & Googleopoly.net
Author, Search & Destroy: Why You Can’t Trust Google
President, Precursor LLC, a research consultancy for Fortune 500 clients, some of which are Google competitors
McLean, Virginia
