I wrote the following document to try to pretty aggressively discourage instructors from using all the free/freemium products out there. It falls pretty heavily on the FUD side of things. I have mixed feelings about writing it. I think it does paint an accurate picture of the environment and of just how hard it is to do a good job vetting software. It requires a lot of different areas of expertise and a lot of communication with the vendor. It also has to be repeated regularly for as long as you’re using the product. That’s a huge load on support people and one that will only grow over time. I really wonder how people are successfully managing these types of changes while positions and budgets shrink.
The Current Educational Technology Environment
Even before COVID-19, there were a massive number of vendors vying for their share of the $70+ billion educational technology market. With COVID, the rapid influx of investment capital dramatically increased the number of companies with lesser degrees of experience and expertise. The rise of large language models (artificial intelligence) has further increased the value of student data while creating additional ethical and legal complexities. It is a complex and rapidly changing environment.
Before choosing a tool outside Middlebury’s vetted options, please consider the following.
Do we already have a solution?
Before looking elsewhere, please make sure you have looked at our existing options. You may find what you need in the Service Catalog. If you don’t see what you need, please reach out to DLINQ with your goals..
Middlebury works hard to provide a robust and diverse set of tools to meet your instructional needs. Considerable time, energy, and expertise has been spent to make sure all of our centrally-supported services have been evaluated regarding security, data privacy, and accessibility.
Vetted services are also supported through our help desk and frequently have other options that increase security and functionality (like single-sign-on integration).
Student Privacy
It is difficult to tell what companies are doing with your students’ data (intentionally or unintentionally). Before encouraging your students to use a service, make sure you understand what is happening to their personal data. “Free” services frequently generate revenue by selling information on your students and/or their intellectual property to other companies. Legally, educational records are broadly defined and require additional privacy and security measures to comply with FERPA.
- Make sure you understand Middlebury’s policy on FERPA.
- Make sure you have read Middlebury’s policy on intellectual property.
- Make sure you have read and understand the company’s privacy policy.
- Consider the data categories ITS uses to frame conversations about data and subsequent security measures.
Accessibility
Middlebury is devoted to providing accessible tools and materials to enable “full participation in our diverse community.” You’ll want to make sure any services you use provide equitable access for all of your students.
- Make sure you’ve read and understand the company’s Voluntary Product Accessibility Template (VPAT) prior to using their service with your students.
- Evaluate any web-based services using the WCAG 2.0 framework. There are a variety of tools available to help you with this analysis.
Security
It is virtually impossible to assess an application’s security without specific training and extensive communication with the company. Without Middlebury’s experts going through the processes necessary to evaluate this product, we can’t accurately assess the risk for students from data breaches, password exposures, or other serious consequences. It is also essential that security reviews happen on a regular basis due to the ever-evolving nature of threats and vulnerabilities. Choosing to use unvetted applications is a significant risk.
- Request a Higher Education Community Vendor Assessment Toolkit (HECVAT) report for the application. Evaluate the response and ask any necessary followup questions.
Support
With outside services, you will want to see what kind of technical and pedagogical support they offer. If their support falls short Middlebury will not be able to provide additional support.
- Consider whether you’ll be able to provide student support if it’s needed.
Continuity
Many of these free services are startups that are operating at a loss while hoping to be acquired by a larger company. As a result, these services frequently change their fee models, shut down, or are acquired (resulting in changes in their vision, approach, cost, data protection policies, etc.) by other companies. This can have significant implications for you and your students.
- Do some basic research on the company and its funding using a site like CrunchBase. Look at funding sources, company history, company size, and other factors likely to impact company behavior and longevity.
There’s FUD and then there’s FUD. This is the right kind of FUD, not like IBM trying to scare you away from buying a competitors product. But instead asking you to look *past* the feature set and affordances. Instead looking to the risks and viability long term. I cannot tell you how many upstart “whiteboard” entrepreneurs contacted me during Covid. Meanwhiles, Zoom Workplace, Blackboard got whiteboards, everyone’s got one.
I appreciate that. It’s a weird position to be in given my history but that was then . . . and the now is a very different place with considerably different concerns.