The U.S. Department of Education opened investigations on Monday into North Monterey County Unified School District, Palo Alto Unified School District, and San Francisco Unified School District over activities tied to required ethnic studies courses.

The agency's Student Privacy Policy Office said the curriculum at all three districts included "Wheel of Power/Privilege" or "Mapping My Identities" activities, which it called "invasive questionnaires" subject to the Protection of Pupil Rights Amendment. That law requires schools to notify parents and obtain written consent before surveying students on protected information.

The Education Department stated that the ethnic studies activities "require students to identify personal information such as their sexual orientations, gender identities, mental and physical health conditions, family economic status, race, and more." The department also noted that parents alleged the California districts did not respond to requests to review the curriculum or allowed only partial access to materials.

"Schools in California seem to be collecting a myriad of protected and private information on students without involving parents, raising serious concerns that they deliberately keep parents in the dark about the most sensitive information pertaining to their children," said Frank Miller, director of the Education Department's Student Privacy Policy Office, in an Oct. 26 statement.

Jason Glass, superintendent of Palo Alto Unified School District, responded that the district would "cooperate fully and respond to the Department." Glass said the district is reviewing the lessons identified by the federal agency, including whether any personal disclosure was required and how parent requests to review materials were handled. "If we find something that should be done differently, we will fix it," Glass said.

Glass later clarified that both of the district's high schools confirmed students are not asked to complete the "Wheel of Power/Privilege" or "Mapping My Identities" activities. The wheel appears in the syllabus "only as a teacher example used for class reference, and it is labeled that way," Glass said. The course description, however, invites students to use the wheel to write reflections on areas where they experience privilege or marginalization.

In August, the Trump administration sent guidance to districts saying that even optional mental health screenings and surveys will be considered "required" under student privacy law and subject to parental notification and written consent. The administration reiterated this warning in early October to state attorneys general.