Comment
Submitted by:
Nancy
Willard, M.S. J.D.
Center for Advanced Technology in Education
University of Oregon, College of Education
Eugene, Oregon 97403
541-346-2895
541-346-6226 (fax)
E-mail: nwillard@oregon.uoregon.edu
URL: http://netizen.uoregon.edu
Responsible Netizen Institute
P.O. Box 50412
Eugene Oregon 97405
541-344-9125
541-344-1481 (fax)
URL:http://responsiblenetizen.org
27 August
2002
Evaluation
of Available Technology Protection Measures
Section
1703(a)(1) of the Act requires NTIA to evaluate whether or not currently
available technology protection measures, including commercial Internet
blocking and filtering software, adequately address the needs of educational
institutions.
1.
Discuss whether available technology protection measures adequately address
the need of educational institutions.
I am providing
copies of chapters of my new book, Safe and
Responsible Use of the Internet: A Guide for Educators as an attachment
to this. Please also consult my Analysis of the Constitutionality (and
Advisability) of the Use of Commercial Filtering Software in Public Schools,
which is available online at: http://responsiblenetizen.org/documents/constitutionality.doc.
In brief,
what these chapters discuss are the concerns regarding school reliance
on commercial filtering software, which include: their use as a surrogate
for the more important responsibilities of education; constitutional concerns
(about the use of this particular technology, not CIPA itself); overblocking
which interferes with the effective educational use of the Internet in
school; viewpoint discrimination; and the failure to support the effective
use of the Internet for educational and instructional purposes.
I believe
the use of commercial, proprietary-protected filtering software by public
schools to be unconstitutional because such use results in the abdication
of decision-making authority by local school decision-makers to third party
companies that are not blocking based on educational standards, protect
their criteria, processes and relationships as confidential trade secrets,
and are engaging in viewpoint discrimination.The
ability of local school officials to override the systems to provide access
do not cure the constitutional concerns because this places undue burden
on students seeking sensitive, possibly controversial, information, and
is simply not timely or efficient.
Other
technologies, which presumably could be used to comply with CIPA (this
is an open question, which is addressed in "Children's Internet Protection
Act"), include: blocking based on first party rating; filtering technologies
where the criteria and processes are not protected; products that filter
and warn; content limited access; filtered monitoring; and SPAM control
technologies.These technologies
can be effectively incorporated into a comprehensive education and supervision
approach.
2.
Is the use of particular technologies or procedures more prevalent than
others?
Most public
schools are using commercial proprietary-protected filtering software
3.
What technology, procedure, or combination has had the most success within
educational institutions?
There
are no research funds available to accurately ascertain the answer to this
question. Funding for research in the use of educational technology has
been very limited. The NRC report captures the essential points in regards
to this question. In the preface to the report, Dick Thornberg , former
Attorney General and committee chair, indicated that the report would "disappoint
those who expect a technology 'quick fix'" and chided school officials
and others for seeking "surrogates to fulfill the responsibilities of training
and supervision needed to truly protect children from inappropriate sexual
materials on the Internet.[1]
"
The NRC
Committee asked educators, "What is the benefit of having filters?" In
virtually every school the committee visited the primary reasons offered
for filters were to avoid controversy in the community and to avoid liability
for exposing children to inappropriate material[2].Essentially,
it appears that the primary reason schools have filters is not to protect
kids -- but to protect the school.
The NRC
report also stated the following:
(F)ilters
can be highly effective in reducing the exposure of minors to inappropriate
content if the inability to access large amounts of appropriate material
is acceptable[3].
In various
site visits conducted by the NRC committee students "often reported that
information on blocked sites might have been useful for legitimate academic
research purposes" and teachers reported that "educationally relevant sites
were blocked regularly[4]."
It light
of these findings, it is clear that the use of commercial filtering software
in public schools can not be considered to be "successful."
4.
Please explain how the technology protection products block or filter prohibited
content (such as Ayes@ lists, (appropriate content); Ano" lists, (prohibited
content), human review, technology review based on phrase or image, or
other method.) Explain whether these methods successfully block or filter
prohibited online content and whether one method is more effective than
another.
Without
full and complete data from the companies, it is impossible to ascertain
any of this information. The questions should be asked to determine what
material is appropriately blocked and what material is inappropriately
blocked due to technical process problems or bias.
5.
Are there obstacles to or difficulties in obtaining lists of blocked or
filtered sites or the specific criteria used by technology companies to
deny or permit access to certain web sites? Explain.
Please
note the history of the proceedings in the ALA trial. At one point in the
trial, N2H2, a filtering company intervened to close the hearing for fear
of their trade secrets being disclosed. In The chapter "Analysis of the
Constitutionality (and Advisability) of the Use of Commercial Filtering
in Public Schools," the issue and implicationsof
the lack of public accountability are discussed. The following is the type
of information I suggest would be essential to be made publicly availableto
fully understand how effectively and responsibly these filtering technologies
actually function:
•Database
of blocked sites
•Internal
criteria and guidelines related to the blocking decision-making processes.
Records and pertinent material related to training and supervision of employees
who are engaged in the blocking decision-making. All corporate records,
memos, and the like related to the establishment of the categories and
the determination of the types of material to be blocked within each category.
Qualifications of employees who have established blocking criteria and
those who are making the blocking decisions
•Complete
description of technical systems that are utilized in the blocking decision-making
process, including all internal audits and reports assessing the effectiveness
of these systems.
•Records
related to the blocking processes, including numbers of sites returned
by the search engine, average number of sites reviewed by each employee
by the hour, results of the review process (number of sites blocked and
number of sites not blocked).
•Keywords
that are used to identify potential sites that are then reviewed for possible
blocking. If the filtering system blocks in "real time" based on an analysis
of the incoming traffic, a list of all keywords that are used to identify
sites that are blocked. All memos, reports and the like related to the
development of these keywords.
•Identification
of marketing targets and all reports related to marketing approaches and
activities related to these clients. List of all major clients, any clients
that have a religious focus, and any clients that are government units
in countries that are filtering the Internet for their citizens. All proposals
presented by the company to anyprospective
religious-orientedclient, prospective
governmental units in countries engaging in censorship of their citizen's
access to the Internet, and any other relevant major clients.
The advantage
of the use of the other technologies outlined in the chapter "Technology
Protection Measures," which drew directly from the NRC Report, is that
their use would address the concerns of public accountability.
6.
Do technology companies readily add or delete specific web sites from their
blocked lists upon request? Please explain your answer.
In schools,
the first line of request to gain access to a blocked site is at the school
or district level, with a request for an override. It should be noted that
there is some inconsistency or lack of clarity in the CIPA legislation
related to overriding or disabling. The confusion relates to provisions
in CIPA that allow the school to disable the filter to provide access for
adults for legitimate research purposes -- although it is unclear how one
can make a decision to allow access to material that is illegal for legitimate
research purposes. This disabling provision does not apply to the system
when used by minors thus leaving the question of whether or not it is ever
possible for a school to override the filter and whether all unblocking
decisions and actions must be made at the company level. This inconsistency
was addressed by the court in the ALA ruling.
I personally
posed this question to an official at F.C.C. and my understanding of his
response was that there was a difference between overriding and disabling
and that the local standards provisions of CIPA would allow for local overriding.
The following is the information provided by Mark Seifert, Deputy Division
Chief, Accounting Policy Division, Common Carrier Bureau, Frontline Manager
for FCC for Oversite of the School and Libraries Division:
Issues
of selection of the Technology Protection Measure, configuration of the
Technology Protection Measure, and operation of the Technology Protection
Measure with respect to unblocking sites that have been inappropriately
blocked are all matters for the local community to decide. The FCC considers
these issues to fall within the provision of the law set forth in Section
1732. (2) Local determination of content. The FCC has not received any
complaints under CIPA and does not have enforcement procedures in place.According
to the Commission's order, the FCC believes that Congress did not intend
to penalize recipients that act in good faith and act in a reasonable manner
to implement available Technology Protection Measures.The
Commission also found that it was reasonable to presume that a school or
library would comply with its certification, and therefore, the Commission
would "rarely, if ever," be called upon to look beyond that certification[5].
As noted
by the NRC, in virtually all schools they visited there were complaints
regarding the time it took to gain an override of the filter. In most cases,
the time and process demands are such that people are dissuaded from even
requesting an override. Students who have unfiltered access at home get
access there. Students without Internet access at home do without.
Most technology
educators I have communicated with have indicated that the level of intentional
access to pornography or other inappropriatematerial
in schools is very low. If such intentional access is not very low, this
would be an indication of failure in supervision and discipline. Therefore,
according to these educators, the vast majority of sites that are blocked
appear to fall into two categories: material that is not relevant, but
was accessed in the context of conducting research (the "chaff"); and material
that is highly relevant to a particular research topic (the "wheat"). In
schools that allow a significant amount on non-instructional use of the
Internet --open access times--it would be reasonable to suspect that there
would also be blocked access to a range of popular culture sites.
One of
the frustrations that is frequently reported is that if a site is found
to be blocked during research activities it is not possible to tell whether
this is a "wheat" site or a "chaff" site. Therefore, there is reticence
about seeking to have the site overridden because it is unknown whether
or not going through the override process would be worthwhile. There are
likely more requests for an override when the system is blocking access
to a site that is known by the user to contain appropriate relevant material.
This question
also raises another issue. Many of the products used in schools are also
used by conservative religious ISPs who are requesting that their users
submit the URLs for sites that they think ought to be blocked. It is probable
that the companies are very responsive to these requests. This has a strong
possibility of leading to blocking based on viewpoint bias.
7.
Discuss any factors that were considered when deciding which technology
tools to use (such as training, cost, technology maintenance and upgrades
or other factors.)
Not applicable
for me to comment on. It should be noted that an additional cost, which
is rarely accounted for, is the human costs that would be involved if the
district did seek to promptly respond to each and every request to unblock.
Fostering
the Development of Technology Measures
Section
1703(a)(2) directs NTIA to initiate a notice and comment proceeding to
make recommendations on how to foster the development of technology measures
that meet the needs of educational institutions.
Obviously
the first thing that needs to be said is that the focus should not be on
new technologies--rather the focus should be on the development of more
effective educational and social strategies.
The second
really important issue of concern is that CIPA has actually undermined
the development of new technologies. The *vast majority* of school administrators
think that the only way to comply with CIPA is through the use of the current
type of commercial, proprietary-protected filtering software. They think
that if they try anything else, they will end up in trouble with the FCC.
I have
provided some guidance to a company called Vericept, which provides filtered
monitoring. This kind of approach is a really good way to hold secondary
level students accountable and is far preferable to the commercial filtering.
There was an article that appeared in the NY Times about this company.
In this article, there is a statement from some unidentified members of
Congress saying that they wanted CIPA to be flexible enough to allot for
newer technologies. But the company has told me that they are having difficulties
getting school administrators to consider their product as a means of complying
with CIPA.
Rather
than let the market unfold as it would have, which would have facilitated
the introduction of newer, perhaps better technologies, CIPA has forced
the adoption of a particular technology. It will be exceptionally hard
for any other form of technology to gain any kind of a foothold. Investors
will know this, so newer technologies will not even be developed. There
will be no funds for development made available.
Congress'
intervention in this area has and will restrict all further technological
development.
1.
Are current blocking and filtering methods effectively protecting children
or limiting their access to prohibited Internet activity?
The NRC
Report answered this question directly:
(F)ilters
can be highly effective in reducing the exposure of minors to inappropriate
content if the inability to access large amounts of appropriate material
is acceptable[6].
The inability
to access large amounts of appropriate material is unacceptable in the
secondary levels of school. For elementary students, this is likely not
a significant concern.
Essentially,
the foundation question here is what is the meaning of the term "protection."
No technology protection measure is or ever will be 100% effective in protecting
young people from exposure to material that is potentially harmful. There
is simply too much material on the Internet, with more material posted
every second, for any technological system to be truly effective. Virtually
every young person will, at one time or another, have unsupervised access
to the Internet through an unfiltered, unblocked, and unmonitored system.
Any time a technology is created that seeks to block access to material,
another technology will emerge to get around such blocking actions. Technically
proficient young people can easily obtain information on effective strategies
to get around these systems.
As the
NRC Report indicated: "Technology solutions seem to offer quick and inexpensive
fixes that allow adult caregivers to believe that the problem has been
addressed, and it is tempting to believe that the use of technology can
drastically reduce or eliminate the need for human supervision.[7]"
But that technology is not a "substitute for education, responsible adult
supervision, and ethical Internet use.[8]"
Ultimately
the only filtering and blocking methods that will protect children will
be the filtering and blocking software that resides in the hardware that
sits upon shoulders.
This is
not to say that there is not a role for technologies. Technologies can
help to create safe places for younger students and ensure accountability
on the part of older students.
The best
approach for younger children is the use of "white lists" of pre-reviewed,
approved sites with access provided within a secure environment. There
area variety of technologies, such as proxie servers and the use of the
Internet Content Rating Association system to limit access to specific
sites, that can be effective in this regard. As noted in the NRC report
there is a need for much greater focus on developing and identifying these
good sites for young people.
Monitoring
technologies can be very effective in limiting access to prohibited Internet
activity, if appropriately implemented. Appropriate implementation requires
full disclosure and notice of the existence of monitoring. But the limitation
is indirect-- the teen exerts self-control
to limit access because of the knowledge that if they do access inappropriate
material, they will be identified and subject to appropriate discipline.
But it
remains to be seen whether any school districts will shift to a more comprehensive
education and supervision approach. They all believe that they must use
commercial filtering software.
2.
If technologies are available but are not used by educational institutions
for other reasons, such as cost or training, please discuss.
As was
revealed in the NRC report, virtually all schools that have installed filtering
software noted that their reason for doing so was for the purpose of reducing
controversy and addressing concerns of liability. Many have also done so
because of state or federal mandate. In many states the filtering has been
applied at the state level, with no options provided at the local level
to not use the filtering selected by the state.
As was
discussed above, since the existing filtering software has been sold as
the "necessary solution" it will be very hard to convince administrators
of the need for a change -- either to a newer technology or to a focus
on comprehensive education and supervision strategies. Most of the school
administrators I have discussed this issue with are of the opinion that
the only way to comply with CIPA is to install the commercial, proprietary
filtering software.
There
has been a wide perpetration of the "myth" that the use of filtering software
is necessary to protect young people. It was only in May of this year that
the "voice of reason" in the form of the NRC report suggested that filters
were merely "technology quick fixes" and that our attention should be more
strongly focused on education and supervision. But there has not been much
national attention paid to this report -- and the only folks with marketing
money are those promoting filtering software.
As noted
in the NRC report, and verified by my own work, comprehensive strategies
thatare grounded in education and
supervision are not quick and easy. They require professional development
for staff, education for students and parents, attention to how and when
students are using the Internet, and responsive intervention and discipline.
It is my personal perspective that very few schools really are interested
in approaching these issues in a comprehensive manner. They have been sold
on the value of the "quick fix" and are not as willing to entertain the
possibility that more may be necessary.
3.
What technology features would better meet the needs of educational institutions
trying to block prohibited content?
The focus
of attention should not be on new technologies. The focus of attention
should be on the development and implementation of a comprehensive education
and supervision approach to protect children by preparing them to make
safe and responsible choices.
4.
Can currently available filtering or blocking technology adjust to accommodate
all age groups from kindergarten through grade twelve? Are these tools
easily disabled toaccommodate bona
fide and other lawful research? Are these tools easily dismantled?
Some products
purport to provide "granularity" to allow for different settings for different
grades. But the category and blocking decisions are not being made on the
basis of educational standards; nor are decisions being made by educators.
Without access to internal information, it is not possible to tell whether
the technology is being adequately adjusted to serve different educational
needs.
The tools
are not easily overridden. Recently, a professional trainer of teachers
told me that the teachers she had trained this summer were having difficulties
reaching a site through the filtering system at their school. This site
was an important basic site for the educational activities the teacher
had learned to accomplish during the summer. Upon contacting the school,
she was told that the override committee would take this issue up in October!
Most teachers
and librarians I have spoken with have told me that the process to request
and achieve an override within the district is so time consuming and delayed,
that they simply teach their students alternative ways to get around the
school computer, such as use their home computer. This impedes the education
of students who do not have a home computer. Further, this results in ineffective
use of the expensive computer technology that has been installed in schools.
The filters
that are used on school systems are not easily dismantled. There was, however,
a great story in Salon magazine of a high school student who was so frustrated
by the filter at school that he set up an external server that made it
possible for students to go around the filter. It is unknown how often
this particular approach has been taken by frustrated students or teachers.
There
are also many ways that students can get around a filtered system, if they
so desire. The issue that should have greater concern is addressing the
"desire."
Current
Internet Safety Policies
Section
1703(a)(3) requires NTIA to evaluate the development and effectiveness
of local Internet safety policies currently in operation that were established
with community input.
1.
Are Internet safety policies an effective method of filtering or blocking
prohibited material consistent with the goals established by educational
institutions and the community? If not, please discuss the areas in which
the policies do not effectively meet the goals of the educational institutions
and/or community.
The greatest
disappointments in the implementation of CIPA are the following:
-
Primary focus on filtering technologies.
-
The failure of Congress to wait for guidance in the form of the NRC Report.
-
The failure of school districts to effectively address the requirements
of an effective Internet Safety Plan.
The requirements
set forth in CIPA for the Internet Safety Plan were excellent requirements.
Had CIPA consisted of these requirements andhad
CIPA been delayed until after the release of the NRC Report, SIGNIFICANT
advanced and improvements would have been made in addressing the important
concerns of inappropriate materials and dangers present on the Internet.
We now have the most troubling situation--over 90% of schools using technological
quick fixes as surrogates for their more important responsibilities of
education and supervision. And, as a result, our children have been placed
in a position of much greater vulnerability and risk.
Undoing
this colossal mess and shifting the attention of educators to the approaches
recommended by the NRC will be extremely difficult. School decision makers
want to think they have solved the problem. They have not--but convincing
them of this after they have been convinced that filtering will solve their
problems--will present a difficult challenge.
CIPA done
significant harm to the overall objective of protecting and preparing young
people to engage in the safe and responsible use of the Internet and effectively
avoid and address the dangers and concerns present on the Internet.
As one
who has provided consulting services to schools related to technology for
over a decade, I am able to draw comparisons to the experiences with the
requirements for technology plans that were incorporated into the Technology
Literacy Challenge law. At the time these requirements were implemented,
there was, within the field, a good understanding of the kinds of provisions
and approaches that were necessary to develop a good technology plan. Because
the TLC requirements simply required a plan and noted the topics that needed
to be addressed, knowledgeable consultantsand
technology directors were able to use the TLC requirements in an effective
manner to help districts develop good technology plans. The TLC requirements
were broad enough to encompass the needs of all districts. (I myself provided
consulting services in the development ofTLC
technology plans for one of Oregon's largest school districts, as well
as 8 one room districts in Eastern Oregon.) The TLC technology plan requirements
were very similar to the Internet Safety Plan requirements in CIPA.
If Congress
had had the wisdom to wait until the issuance of the NRC report and had
limited CIPA to the Neighborhood Children's Internet Protection Act portion
of the law, we would now be able to make great strides in developing the
kinds of approaches and action plans that would truly protect our young
people.
This was
an opportunity lost. Congress' rush to implement a one-size-fits-all technological
quick fix has set the matters back considerably.
And, just
for the record, I did try to educate members of Congress, especially some
of the key members of the Senate Commerce committee on this important issue.
2.
Please discuss whether and how the current policies could better meet the
needs of the institutions and the community. If possible, provide specific
recommendations.
I have
provided an entire book of specific suggestions. Whether or not any school
districts will actually read and follow this guidance remains to be seen.
I attempted to promote many of these same strategies to school districts
last year, while they were coming into compliance with CIPA and was entirely
unsuccessful.
I would
also suggest comparing the materials I have provided to the CIPA-compliant
policies that was recommended by N2H2, one of the commercial filtering
software companies whose testimony was relied upon by Congress in the development
of CIPA. It is entirely evident from a comparison of the N2h2 recommended
policy how the company's view of these issues comes from an entirely inadequate,
over-simplistic understanding of the issues. They fail to understand what
is necessary for effective policy and planning in a school environment.
N2H2's policy is set forth below.
3.
Are educational institutions using a single technology protection method
or a combination of blocking and filtering technologies?
Why is
this question in a section focusing on the Internet safety plan? The vast
majority of schools have adopted the use of a commercial filtering software
product. I advocate the use of a variety of technologies to provide for
different levels of protection and accountability at different levels of
schooling.
4.
Describe any best practices or policies that have been effective in ensuring
that minors are protected from exposure to prohibited content. Please share
practices proven unsuccessful at protecting minors from exposure to prohibited
content.
I am providing
an entire book of suggestions. I request you consider the news article
that ran last January in our local newspaper. It features a presentation
of the approach taken by the school district my children attend. This district
was one of the few to have decided to not apply for E-Rate funds because
of their lack of willingness to install filtering when the approach they
are using is working.
"Filtering
out the filth: Eugene schools use traditional methods to block
inappropriate
material"
http://www.registerguard.com/news/20020127/1a.safesurfing.0127.html
I further
request you consider the editorial that ran several days later, which provided
full support for the approach taken by our district
"The best
Internet filter: It's in students' minds, not their computers"
http://www.registerguard.com/news/20020129/ed.edit.filters.0129.html
All of
the approaches recommended in my book have come from my conversations with
knowledgeable technology directors in districts that had not installed
filtering.
N2H2's
Recommended CIPA Policy
Online
at: http://www.filteringinfo.org/sample_school_erate.html
(Filtering
Info is N2H2's service for schools.)
Sample
policy for a School Receiving E-rate Funding
An Internet
Acceptable Use Policy (AUP) is required for schools and libraries receiving
the E-rate. The E-rate requirements list several specific items that must
be addressed in the policy. To help schools and libraries understand what
requirements apply to them, FilteringInfo.org has created a sample policy
that covers these minimum policy requirements:
Enforce
use of a technology protection measure that blocks or filters Internet
access when in use by minors. A minor is defined in the legislation as
"any individual who has not attained the age of 17 years."
- Address
access by minors to inappropriate material.
- Address
access by minors to material harmful to minors.
- Address
safety of minors when using e-mail, chat, etc.
- Address
unauthorized/unlawful use by minors.
- Address
disclosure of personal info by minors.
- Provide
means for monitoring access by minors. However, the legislation states
that "Nothing in this title or the amendments made by this title shall
be construed to require the tracking of Internet use by any identifiable
minor or adult user."
Sample
Policy
Below
is a sample policy that you may use to craft your own Internet Acceptable
Use Policy (AUP). Please feel free to copy any and all of the language
below to help you create and edit your own policy document to fit your
particular needs. Note that the placeholder [YOUR SCHOOL] is meant to be
replaced with the name of your organization. Also, carefully review the
information in your policy to be sure that your district or local governing
body is in accordance with the language.
[YOUR
SCHOOL] Policy on Internet Access
Internet
users are expected to use the Internet as an educational resource. The
following procedures and guidelines are used to help ensure appropriate
use of the Internet at [YOUR SCHOOL].
Student
Expectations in Use of the Internet
a. Students
shall not access material that is obscene, pornographic, child pornography,
"harmful to minors", or otherwise inappropriate for educational uses.
b. Students
shall not use school resources to engage in "hacking" or attempts to otherwise
compromise system security.
c. Students
shall not engage in any illegal activities on the Internet.
d. Students
shall only use electronic mail, chat rooms, and other forms of direct electronic
communications for school-related purposes.
e.Students
shall not disclose personal information, such as name, school, address,
and telephone number outside of the school network.
Any violation
of school policy and rules may result in loss of school-provided access
to the Internet. Additional disciplinary action may be determined in keeping
with existing procedures and practices regarding inappropriate language
or behavior. When and where applicable, law enforcement agencies may be
involved.
Staff
Expectations in Use of the Internet
a. Staff
shall not use access material that is obscene or is child pornography.
(Note the absolutely absurd policy provision that allows staff to access
material that is harmful to minors! This, of course, is in accord with
CIPA.))
Any violation
of school policy may result in loss of school-provided access to the Internet.
Additional disciplinary action may be determined in keeping with existing
procedures and practices. When and where applicable, law enforcement agencies
may be involved.
Enforcement
of policy
a. [YOUR
SCHOOL] uses a technology protection measure that blocks or filters Internet
access to block access to some Internet sites that are not in accordance
with the policy of [YOUR SCHOOL].
b. The
technology protection measure that blocks or filters Internet access may
be disabled by a [YOUR SCHOOL] staff member for bona fide research purposes
by an adult.
c. A [YOUR
SCHOOL] staff member may override the technology protection measure that
blocks or filters Internet access for a student to access a site with legitimate
educational value that is wrongly blocked by the technology protection
measure that blocks or filters Internet access.
d. [YOUR
SCHOOL] staff will monitor students' use of the Internet, through either
direct supervision, or by monitoring Internet use history, to ensure enforcement
of the policy.
[YOUR
SCHOOL] Internet Acceptable Use Policy, Approved by [YOUR SCHOOL BOARD],
[On this date]