Privacy policy.

THIS POLICY is adopted this the 1st day of September, 2024 by INCARNATION PLACE (IP), for the period September 1, 2024 through August 31, 2030.  Accordingly:

IP provides services at The Rose and elsewhere in the Roseland community to meet its operational and programmatic goals, to improve student academic performance, and to provide safe spaces for growth and recreation for people of all ages, including the following:

  1. Engage children living at Roseland and attending local K-12 public schools in literacy-focused learning, and social/emotional health resources and counseling; 

  2. Engage adults from the Roseland community in self-improvement classes and social/emotional health resources and counseling;

  3. Engage Roseland parents in their child’s success from birth to college;

  4. Engage Roseland children and adults in healthy living practices and recreational activities; and

  5. Offer every Roseland family a safety net of social sector resources.

IP intends to evaluate its impact in achieving the five objectives listed above, including collaboration among educational and social services agencies presently providing services to students, families, and individuals which will continue during the term of this Data Protection Policy (the “Policy”) and, thereafter, until completed by IP.   

To assess its impact, IP will collect demographic and programmatic data including:

  1. Demographic data: First Name, Middle Name, Last Name, Race, Ethnicity, Gender, Home Language(s), Date of Birth, Free/Reduced Lunch Status (children), or family income status (adults);

  2. Number and type of programs participated in;

  3. Attendance and dosage for program participants;

  4. Increased literacy skills;

  5. Improved school attendance;

  6. Increased social, emotional, and cognitive development skills;

  7. Increased accountability and sense of personal responsibility;

  8. Increased leadership and collaboration skills;

  9. Increased engagement in community improvement activities; and

  10. Increased number of adult/student or adult/adult mentoring relationships.

IP will ensure the following concerning all data collected and/or shared:

1. The release of participant information will be in compliance with all applicable laws and regulations, including, but not limited to, the Texas Education Code, Section 21.355 and Texas Government Code, Section 552.117.

2. The release of personally identifiable information of students will be in compliance with the requirements of the Family Educational Rights and Privacy Act (FERPA). FERPA permits the disclosure of personally identifiable information of students to an organization conducting a study ‘‘for, or on behalf of, educational agencies or institutions’’ for statutorily enumerated purposes, including for the purpose of developing, validating, or administering predictive tests, administering student aid programs, and improving instruction. 20 U.S.C. 1232g(b)(1)(F).

3. Student Confidentiality. The Dallas ISD has a legal obligation to maintain the confidentiality and privacy of student records in accordance with applicable laws and regulations, specifically the Family Educational Rights and Privacy Act (FERPA). IP and its authorized representatives may only receive student information in compliance with the requirements and exceptions outlined in FERPA. IP and its authorized representatives acknowledge that they must comply with said law and regulations and safeguard student information.  IP and its authorized representatives will not re-disclose the information to a third party without prior written consent from the Dallas ISD, the parent or eligible student.   

4. IP will limit the use of personally identifiable information to meeting the purpose or purposes of the work stated in this Agreement. 

5. IP and its authorized representatives will destroy any student information collected by IP and its representatives or received from the Dallas Independent School District when no longer needed for the purposes listed in this Policy. Paper records will be shredded; electronic records will be overwritten. 

6. IP and its authorized representatives will maintain the confidentiality of the student and adult records according to commercially reasonable administrative, physical and technical standards.

7. All student surveys will comply with the requirements of the Protection of Pupil Rights Amendment (PPRA). In the event that any Department of Education funding is used for this program, prior written parental consent will be obtained before surveying a student on any of the following topics:

  1. Political affiliations;

  2. Mental and psychological problems potentially embarrassing to the student and his/her family;

  3. Sex behavior and attitudes;

  4. Illegal, anti-social, self-incriminating and demeaning behavior;

  5. Critical appraisals of other individuals with whom respondents have close family relationships;

  6. Legally recognized privileged or analogous relationships, such as those of lawyers, physicians, and ministers; or

  7. Religious practices, affiliations, or beliefs of the student or parents; or

  8. Income (other than that required by law to determine eligibility for participation in a program or for receiving financial assistance under such program).

The protected categories may also be expanded by future amendments to the PPRA. Parents will have the opportunity to inspect the survey created by a third party before the survey is administered or distributed to the student regardless of the funding source.

8. IP designates the IP Board President as its authorized representative. The authorized representative has authority to bind the entity to the requirements of this agreement. The authorized representative shall also require individuals accessing the personally identifiable information to indicate their individual agreement to handle the personally identifiable information from education records properly by signing this document under Attachment A “Additional Signatories”.

9. IP will protect personally identifiable information from further disclosure and unauthorized use, including limiting the use of personally identifiable information from education records to only authorized representatives with legitimate interests in the study.

10. In the event of a security breach or a suspected security breach, IP staff will:

  1. Notify affected constituents of the incident.

  2. Decide whether to involve outside entities, including law enforcement agencies and computer forensics experts.

11. IP will defend and hold any sources of shared data harmless from all claims, liabilities, damages, or judgments involving a third party, including costs and attorney fees, which arise as a result of IP's failure to meet any of its obligations under this Agreement caused by IP’s negligence or fault.  IP is not responsible for the actions or omission of other agencies.

This Agreement and all of the rights and obligations of the parties hereto and all of the terms and conditions hereof shall be construed, interpreted and applied in accordance with and governed by and enforced under the laws of the State of Texas, and the parties hereto agree that venue shall be in Dallas County, Texas.