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This generic Privacy Impact Assessment (PIA) template and its contents are intended to be used and modified by authorized members. Non-members should obtain written consent for any use or modifications of this document. Also, remove this page from the final, completed version of your PIA.

Privacy Impact Assessment forBC Digital Classroom Core CollectionPIA#[assigned by your privacy office(r)]

Note to Districts:

Instructions within RED text in this document should be removed from the final version of your District’s PIA and the GREEN text throughout the document should be replaced with information specific to your district.

Your school district has chosen to implement the BC Digital Classroom Core Collection (BC Digital Classroom). By conducting this Privacy Impact Assessment, it will help your district ensure compliance with the Freedom of Information and Protection of Privacy Act (FIPPA) and your school district’s relevant Use Policy. It will also provide documentation on your school district’s transparency processes when introducing new programs or services that may involve the collection, use and disclosure of personal information. With heightened sensitivity about personal information, this PIA demonstrates to all stakeholders the due diligence that is applied to new services and initiatives within the school district.

To assist with the deployment of these services, this PIA has been partially completed. Review and edit this document carefully to ensure it accurately reflects the intent and scope of your initiative. Areas where information from your district is required are indicated in the template. It is your district’s responsibility to ensure that all information in this PIA is accurate and complete.

Please note: the comments and opinions expressed in this document are to help show Districts and Schools the considerations taken in completing the PIA for School/District educational use and does not cover personal subscription entered into with vendors. This information does not constitute OIPC approval of the initiative being consulted on or fetter the Commissioner’s discretion should the initiative later be the subject of a complaint or investigation. It remains the responsibility of public bodies to ensure that they comply with their duties and obligations under applicable law.

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Enquiry BC: Privacy and Access Helpline Victoria: 250-356-1851 Vancouver: 604-660-2421 & elsewhere in BC toll-free:1 800-663-7867.


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Why complete a PIA?

The PIA for BC School Districts is an assessment tool designed to help School Districts comply with applicable BC privacy legislation. This generic document can help staff identify specific privacy risks associated with various products and services before being deployed in their district. Where privacy challenges become apparent, the document can help guide the privacy designate or PIA Drafter through a process which includes consulting with staff to contemplate mitigation strategies that will protect users. With multiple staff perspectives, the author(s) of this document will be able to provide meaningful mitigation strategies when addressing potential risks and may contemplate and identified unintended consequences associated with the use of the product or service being considered. As part of the assessment process, schools/districts can then take appropriate steps to ensure that parents, students and educators understand what meaningful measures have been taken to protect the safety and security of their personal information. Annual PIA Reviews help address any changes in the vendor’s Terms and Conditions that can occur with product and services. These can be documented using the attached PIA Update form. Completed PIAs and updates are to be retained in a secure location at the School/District for the purposes of demonstrating due diligence and if needed, to respond to a requested Privacy Commissioner’s Audit.

The privacy office(r) or PIA Drafter, at a School/District, is typically appointed by their Superintendent of Schools. This person will determine internal policies for review and signing-off of a Privacy Impact Assessment. Staff need to contact their designed privacy officer before considering the purchase and deployment of products and services being used in the district. If you have any questions about this PIA template or FIPPA in general, you may contact your designated PIA Drafter as noted in this document or call the provincial Privacy and Access Helpline at Enquiry BC as noted below.

Note: This process can help identify and reduce many of the unintended risks and consequences that may potentially jeapordize student and educator privacy and security issues.

What if the initiative does not include personal information?

Best practices indicate that School/Districts’ may want to complete Part 1 of the PIA (Questions 1-4) and submit it along with the signature pages to their privacy office(r) for safe-keeping even if it is thought that no personal information is involved. This process ensures that the initiative has been accurately assessed to meet the requirements of FIPPA while helping districts communicate, monitor, and educate staff about new initiatives.

Note: The definition of personal information is: Recorded information about an identifiable individual other than contact information.The following examples are a non-exhaustive list of personal information:

Name, address, email address or telephone number; Age, sex, religious beliefs, sexual orientation, marital or family status, blood type; Information about an individual’s health care history, including a physical or mental disability; Information about an individual’s education, financial, criminal or employment history; Social Insurance Number (SIN) and Personal Education Number (PEN); and Personal views, opinions, religious or political beliefs or associations.


Part 1 – General

Name of Organization:

<Name> Board of Education – SD <##>

PIA Drafter: <Name, Title of School District Contact>Email: <Email of School District Contact> Phone: <Number of SD Contact>Program Manager:

<Name, Title of initiative contact, if different from PIA Drafter>

Email: <Alternate to the above> Phone: <Alternate to the above>

Please do not remove any parts of the PIA. Where a section does not apply, enter “Not Applicable.”

1. Description of the Initiative

Our school district is implementing the BC Digital Classroom Core Collection (BC Digital Classroom) of resources for students and teachers. This initiative includes a variety of digital content from 8 different vendors. Resources which make up the BC Digital Classroom offer educational materials and activities that build on the in-class experience and align with the BC curriculum.

This umbrella Privacy Impact Assessment (PIA) is to facilitate <School District Name and ##> in implementing the BC Digital Classroom in our district and ensuring that these services are used in a way that is compliant with the Freedom of Information and Protection of Privacy Act (FIPPA).

This 3-year subscription agreement with the multiple vendors commences August 1, 2019 and ends July 31, 2022. The collection includes the following vendors: <the list below includes all components of the BC Digital Classroom Core Collection; any components that will not be implemented in your district can be removed accordingly.>

Digital copies

Canoe Kids – Authentic indigenous digital magazine Volume 1-3


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IP Authenticated (and Generic Login for home use)

EBSCO – Elementary Mini-Suite (Primary Search, Middle Search, Novelist K – 8 Plus); Secondary Mini-Suite (Masterfile Premier, Canadian Reference Centre and Consumer Health Complete).

Gale Cengage – National Geographic Kids, Power Search, Global Issues in Context, Science in Context, Canada in Context.

KnowBC – Online Encyclopedia of BC including the following publications: Marine Life of the Pacific Northwest; The Encyclopedia of Raincoast Place Names; Far West: The Story of BC; Raincoast Chronicles; Lilies and Fireweed; Frontier Women of BC and Where Mountains Meet the Sea.

World Book (WB) – WB Advanced, WB Discover, WB Early World of Learning, L’Encyclopédie Découverte, WB Kids, WB Science Power, WB Student, WB Timelines.

Personalized accounts (for students)

Doublethink - myBlueprint Educational Planner (CDN Post-Secondary Database and Occupation Database for Grade 10-12).

Teachers resources in classroom

Magic Lantern - Teens 101 for Grade 8-10 (one generic login credential for internal and external access across BC.)

Twig Education - Tigtag for Grade 3-6

For students, only myBlueprint requires the creation of personalized user accounts.

For teachers, only Tigtag requires the creation of personalized user accounts.

For all other resources, while in the school environment, user access is IP authenticated and from home generic, anonymous login credentials are used.

2. Scope of this Umbrella PIA

This PIA addresses the use of the BC Digital Classroom as identified above. Any add-on and/or á la carte items do not fall within the scope of this PIA.


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<This PIA describes the implementation of BC Digital Classroom by the recommended method of embedding the iframe widget into a district or school website. Districts should revise wording as needed to accurately describe their circumstances. Alternative implementation methods are identified in the BC Digital Classroom Implementation and Support Technical Guide in Appendix C.>

This PIA applies to the use of BC Digital Classroom resources by students within school settings and at home, as well as by teachers within the classroom.

To enable access to resources, our district embeds the BC Digital Classroom iframe widget into our district website. The iframe widget uses a service called EZproxy to deliver resources to users.

EZproxy is a web proxy server which allows users to access BC Digital Classroom via the EZproxy server and gain access to the resources to which our district subscribes. EZproxy works as an intermediary between users and the resources. It confirms that users are authorized to access subscriptions and delivers the digital content to them.

On school premises, when a student or teacher visits our district website and selects a resource within the BC Digital Classroom they would like to access, EZproxy uses IP authentication to authenticate access.

Outside of schools, generic, anonymous login credentials set up by our school district are used for accessing the BC Digital Classroom. (Our School District and school personnel are responsible for distributing generic login credentials to staff and students for accessing BC Digital Classroom from home.)

Once a user is authenticated, EZproxy then passes the access request on to the vendor(s) with EZproxy's IP address attached instead of the user’s IP address. The vendor then matches the EZproxy IP address within its list of registered IP addresses and delivers the content.

3. Related Privacy Impact Assessments

At the writing of this PIA, our school district has no applicable PIAs for this initiative. This PIA addresses our school district’s responsibilities in relation to BC Digital Classroom Core Collection.

4. What are the elements of Information or data in this initiative?


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For resources provided by the following vendors, users can log in and access content through the iframe widget, either through IP authentication (at school) or through generic, anonymous login credentials (outside of school premises):

EBSCO, Gale Cengage, KnowBC and World Book

Through accessing the BC Digital Classroom, certain (non-identifying) information may be collected by vendors, including:

IP Addresses Date and times the resource was accessed Information about the type of web browser used Information about type of computer used Which pages or lessons within the resource were visited Cookies / Flash Cookies Pixel Tags and Web Beacons

Vendors state that they do not combine this data with any personally identifiable information, and use this data for the purposes of tracking usage, monitoring trends, collecting analytics data and improving services.

Teacher Resources

Products provided by the following vendors are for use by teachers to deliver lessons within the classroom:

Magic Lantern - Teens 101 & Twig Education - Tigtag

Teachers can log in to Magic Lantern’s Teens 101 using generic, anonymized credentials to present videos, lessons and other materials to students to enhance in-class lessons. Teens 101 has one generic login for all BC teachers.

For Twig Education (Tigtag), teachers use their school email address (which is considered business contact information) as their login credential. Twig holds a list of participating schools so that teacher email addresses can be used to create login accounts. Designated school district staff for BC Digital Classroom have information about the account creation process for teachers.

myBlueprint (within BC Digital Classroom Core Collection)

In the case of myBlueprint (within BC Digital Classroom) the following personal information is collected by the vendor for students to create an account to access the program:


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First and Last name Email address Password

Only students have access to their myBlueprint accounts, and the personal data stored within, such as details about educational and career goals as well as interests. Students may invite their parents to have access to their accounts to support them in exploring post-secondary and career options. In this case, parents will have “view-only” access and cannot make changes to the information within their child’s account.

In a student’s myBlueprint account, no personal information can be entered by teachers nor do they have access to view the student’s entries. myBlueprint states that it will not use student personal information for any secondary purposes without consent (unless they are required to do so by law).

myBlueprint creates a customized link for our districts which allows students to select their school and create their accounts.

NOTE: For the full edition of myBlueprint, which falls outside of the scope of this PIA, myBlueprint integrates with MyEdBC and collect student PEN or Number, and Date of Birth. In this case, districts should assess the use of the full myBlueprint separately.

Part 2 – Protection of Personal Information

In the following questions, delete the descriptive text and replace it with your own.

5. Storage or Access outside Canada?


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If personal information is involved in your initiative, please continue to the next page to complete your PIA.

If no personal information is involved, please submit Parts 1, 6, and 7 to your privacy office(r). They will guide you through the completion of your PIA.


myBlueprint is the only program within the BC Digital Classroom that requires the collection of personal information to create student accounts, and to store personal information within the platform.

myBlueprint’s privacy pledge states that all data is stored on dedicated servers located within Canada. Servers are located in Toronto, Ontario, Canada.

6. Data-linking Initiative?* – No.

7. Common or Integrated Program or Activity? – No.


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In FIPPA, "data linking" and “data-linking initiative” are strictly defined. Answer the following questions to determine whether your initiative qualifies as a “data-linking initiative” under the Act. If you answer “yes” to all 3 questions, your initiative may be a data linking initiative and you must comply with specific requirements under the Act related to data-linking initiatives.

1. Personal information from one database is linked or combined with personal information from another database;

No

2. The purpose for the linkage is different from those for which the personal information in each database was originally obtained or compiled;

No

3. The data linking is occurring between either (1) two or more public bodies or (2) one or more public bodies and one or more agencies.

No

If you have answered “yes” to all three questions, please contact your privacy office(r) to discuss the requirements of a data-linking initiative.


In FIPPA, “common or integrated program or activity” is strictly defined. Answer the following questions to determine whether your initiative qualifies as “a common or integrated program or activity” under the Act. If you answer “yes” to all 3 of these questions, you must comply with requirements under the Act for common or integrated programs and activities.

1. This initiative involves a program or activity that provides a service (or services);

Yes

2. Those services are provided through:(a) a public body and at least one other public body or agency working collaboratively to provide that service; or (b) one public body working on behalf of one or more other public bodies or agencies;

No

3. The common or integrated program/activity is confirmed by written documentation that meets the requirements set out in the FIPPA regulation.

No

Please check this box if this program involves a common or integrated program or activity based on your answers to the three questions above.

8. Personal Information Flow Diagram and/or Personal Information Flow Table

The following chart identified the flow of personal information within myBlueprint.

Personal Information Flow TableDescription/Purpose Type FIPPA


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Authority1. Students click a customized link created by myBlueprint

(specific to their school district) to create an account.

myBlueprint collects students’ full names and email addresses to create personalized accounts and grant access to the system.

Collection 26(c)

2. Students enter personal information about career and educational goals within the myBlueprint tool.

Collection 26(c)

3 Personal information of students is stored on myBlueprint servers in Toronto, Ontario, Canada.

Storage & Access

30.1

9. Risk Mitigation Table

Examples can be removed and additional lines added as needed.

Risk Mitigation TableRisk Mitigation Strategy Likelihood Impact

1. Students access resouces from home over non-secure network connections.

Our district provides generic, non-personalized log in credentials for access from home and no personal information is transferred through the login process (with the exception of myBlueprint).

Medium Low

2. A student’s myBlueprint account is compromised (the password becomes known by another user).

Students are familiarized with our district’s technology use policy, including direction on protecting login information.

Low High


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3. Student personal information stored by myBlueprint is breached.

Our district ensures through contractual wording that vendors utilize appropriate levels of technical and physical security, as well as employee access controls for their data storage.

Low High

10. Collection Notice

<If your initiative is collecting personal information directly from individuals you must ensure that all individuals involved are told the following:

1. The purpose for which the information is being collected2. The legal authority for collecting it, and3. The title, business address and business telephone number of an officer or employee who

can answer questions about the collection.

Please include your proposed wording for a collection notice and where it will be located for individuals to read before collection takes place. You can also attach a screen shot or a copy of your form where the collection notice would be located. For further help with collection notices please see the “Collection Notice Tip Sheet” located on the CIO’s website.>

To enable student use of myBlueprint, a component of the BC Digital Classroom Core Collection being implemented by our district, the following information is collected:

Name, email address and password

This information is collected directly from students by myBlueprint (provided by Doublethink Inc.) when they create their own personal accounts through a customized link distributed by our district. When students use myBlueprint, the vendor will also collect information about school attended, (including the city and province in which the school is located). Additionally, students enter information related to their educational and career goals and pursuits within the platform. This information is collected under the authority of section 26(c) of the Freedom of Information and Protection of Privacy Act (FIPPA).

myBlueprint may also collect usage information when students use the resources, such as:

Type of device used; IP address; date / time of access; areas and functions of the resource used.


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http://www.cio.gov.bc.ca/cio/priv_leg/foippa/guides_forms/guide_index.page?


This usage information is generally non-identifying. If any usage information is attached to a specific student user, myBlueprint will treat it as personally identifiable information.

Questions regarding the collection of personal information can be addressed to the contacts below:

myBlueprint

310 Davenport Rd Suite 200Toronto, OntarioM5R 1K6Email: [email protected]: 1-416-901-5555

School District

Name:Title:Email:Phone:

Part 3 – Security of Personal Information

If this PIA involves an information system, or if it is otherwise deemed necessary to do so, please consult with your public body’s privacy office(r) and/or security personnel when filling out this section. They will also be able to tell you whether you will need to complete a separate security assessment for this initiative.

<Responses are provided for myBlueprint, which collects and stores personally identifiable information. Additionally, districts should provide responses that identify their own policies and practices around protecting information.>

11. Please describe the physical security measures related to the initiative (if applicable).

myBlueprint

myBlueprint uses the following physical security measures at their data facility:

24/7/365 manned security, closed circuit TV of the entire building, man-trap entrance, three point Radio Frequency Identification (RFID) access card entry (to the building, elevator, data center), and code locks on server cages.


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mailto:[email protected]


Electrical - Redundant 13.8KV feeders provided by Toronto Hydro, two Uninterruptible Power Supply (UPS) units, two diesel generators with 165,000 litres on-site storage in a diesel farm.

Environmental - three 30 ton chilled water down flow heating, ventilation, and air conditioning (HVAC) units, fire suppression system tied to base building alarm system.

School District

<For example: locked cabinets, securely stored laptops, or key card access to the building.>

12. Please describe the technical security measures related to the initiative (if applicable).

myBlueprint

The myBlueprint application and database are located in a private octal cabinet in a highly secure data warehouse facility. All access to myBlueprint.ca uses High-Grade Secure Socket Layer (SSL) Encryption (AES-128) verified by Equifax to ensure secure transfer of data between school district / student computers and myBlueprint servers. All URLs (web addresses) that users visit while using in the program are Hypertext Transfer Protocol Secure (HTTPS) which is used for secure communication over computer networks.

Microsoft Active Directory security is used to isolate the application and provide end-to end security throughout to ensure data safety and integrity.

myBlueprint servers are protected by a professional level Sophos Unified Threat Management (UTM) device. The UTM provides network firewall, intrusion prevention, and advanced threat protection.

School District

<For example: use of firewalls, document encryption, or user access profiles assigned on a need-to-know basis.>


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13. Does your branch/department rely on any security policies?

myBlueprint

myBlueprint’s privacy protection and security measures are included within its:

Privacy Pledge (effective as of Sept. 1, 2019) - https://myblueprint.ca/privacy

Terms of Use - https://myblueprint.ca/terms

School District

<Please describe any specific policies and procedures and provide contact details for someone who could answer further questions regarding these policies and procedures.>

14. Please describe any access controls and/or ways in which you will limit or restrict unauthorized changes (such as additions or deletions) to personal information.

myBlueprint

myBlueprint states that they take reasonable steps to ensure that their employees maintain the confidentiality of personal information and unauthorized persons do not gain access to personal information that has been disposed of or destroyed.


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https://myblueprint.ca/terms

https://myblueprint.ca/privacy


myBlueprint verifies each person’s identity before providing any personal information they hold about that individual.

School District

<For example: role-based access.>

15. Please describe how you track who has access to the personal information.

School District

<For example: audit trails or physical sign-in and sign-out of files.>

Part 4 – Accuracy/Correction/Retention of Personal Information

16. How is an individual’s information updated or corrected? If information is not updated or corrected (for physical, procedural or other reasons) please explain how it will be annotated? If personal information will be disclosed to others, how will the public body notify them of the update, correction or annotation?

myBlueprint

Students may request to update and change personal information by using the contact information below. myBlueprint states that they will correct or complete any personal information which users advise them is either inaccurate or incomplete.

Contact:Doublethink Inc. a/o myBlueprintat [email protected] call 1-416-901-5555.

Mailing address:myBlueprint


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mailto:[email protected]


310 Davenport Rd Suite 200, Toronto, OntarioM5R 1K6

School District

<For example: users have access to update their own information or, notes will be made on a case file.>

17. Does your initiative use personal information to make decisions that directly affect an individual(s)? If yes, please explain.

<Example: Information entered into myBlueprint helps guide future decisions about career and educational paths in a student’s life. Parents and/or teachers may view this information, by invitation from the student, and provide guidance to that student about educational and career choices.>

<District to identify other relevant uses.>

18. If you answered “yes” to question 17, please explain the efforts that will be made to ensure that the personal information is accurate and complete.

myBlueprint

Students (or any other users) may request to update and change personal information by contacting myBlueprint. myBlueprint states that they will correct or complete any personal information which users advise them is either inaccurate or incomplete.

School DistrictPlease note: the comments and opinions expressed in this document are to help show Districts and Schools the considerations taken in completing the PIA for School/District educational use and does not cover personal subscription entered into with vendors. This information does not constitute OIPC approval of the initiative being consulted on or fetter the Commissioner’s discretion should the initiative later be the subject of a complaint or investigation. It remains the responsibility of public bodies to ensure that they comply with their duties and obligations under applicable law.

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<District response.>

19. If you answered “yes” to question 17, do you have a records retention and/or disposition schedule that will ensure that personal information is kept for at least one year after it is used in making a decision directly affecting an individual?

myBlueprint

myBlueprint states that they retain personal information only for as long as is needed to fulfill the purposes for which it was collected (e.g. providing access to and using the program), to ensure compliance with their Terms of Service, and to comply with legal obligations.

Prior to the start of each academic year, myBlueprint reviews user account activity to confirm that each user has accessed their account in the preceding 18 months. If a user has not accessed their account during this period, myBlueprint will delete the personal information associated with that account, unless prevented by legal or contractual requirements.

School District

<District response.>

Part 5 – Further Information20. Does the initiative involve systematic disclosures of personal information? If yes, please explain.

No.

Please check this box if the related Information Sharing Agreement (ISA) is attached. If you require assistance completing an ISA, please contact your privacy office(r).

21. Does the program involve access to personally identifiable information for research or statistical purposes? If yes, please explain.

No.


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Please check this box if the related Research Agreement (RA) is attached. If you require assistance completing an RA please contact your privacy office(r).

22. Will a personal information bank (PIB) result from this initiative? If yes, please list the legislatively required descriptors listed in section 69 (6) of FIPPA. Under this same section, this information is required to be published in a public directory.

<A personal information bank means a collection of personal information that is organized or retrievable by the name of an individual or by an identifying number, symbol, or other particular assigned to an individual.>

No.


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Please ensure Parts 6 and 7 are attached to your submitted PIA.


Part 6 – Privacy Office(r) Comments

This PIA is based on a review of the material provided to the Privacy Office(r) as of the date below. If, in future any substantive changes are made to the scope of this PIA, the School District will complete a PIA Update and submit it to our Privacy Office(r).

Privacy Officer/Privacy Office Representative

Signature Date


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Part 7 – Program Area Signatures

Program/Department Manager Signature Date

Contact Responsible for Systems Maintenance and/or Security (Signature not required unless they have been involved in this PIA.)

Signature Date

Head of Public Body, or designate Signature Date

A final copy of this PIA (with all signatures) must be kept on record.

If you have any questions, please contact your public body’s privacy office(r) or call the OCIO’s Privacy and Access Helpline at 250 356-1851.


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Appendix A – BC Digital Classroom Core Collection for 2019-08-01 to 2022-07-31


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https://bcerac.ca/agreements/bc-digital-classroom-new/#core_collection


Appendix B – Reference Documents

BC Digital Classroom:

EBSCOhttps://www.ebsco.com/company/privacy-policy

Gale https://www.cengage.com/privacy/

KnowBChttp://knowbc.com/Terms-of-Use

myBlueprinthttps://myblueprint.ca/privacy

Twig Education – Tigtag Privacy Policyhttps://www.tigtagworld.com/privacy-policy/

Teens 101http://teens101.ca/Privacy

World Bookhttps://www.worldbook.com/privacy.aspx

Canoe Kids in PDF can be downloaded through the BC Digital Classroom access page https://bcerac.ca/bcdc-access/

Others:

Freedom of Information and Protection of Privacy Acthttp://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/96165_00


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http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/96165_00

https://bcerac.ca/bcdc-access/

https://www.worldbook.com/privacy.aspx

http://teens101.ca/Privacy

https://www.tigtagworld.com/privacy-policy/

https://myblueprint.ca/privacy

http://knowbc.com/Terms-of-Use

https://www.cengage.com/privacy/

https://www.ebsco.com/company/privacy-policy


Appendix C – BC Digital Classroom Implementation Guides

BC Digital Classroom Getting Started Guidehttps://bcerac.ca/wp-content/uploads/2018/08/Getting-Started-2019-06-27.pdf

BC Digital Classroom Implementation and Support Technical Guidehttps://bcerac.ca/wp-content/uploads/2019/09/BCDC-Implementation-and-Support-Technical-Guide-v1-2019-08-21-1.pdf

Widget Guide https://bcerac.ca/wp-content/uploads/2019/08/Access-Page-Code-2019-08-27-1.pdf


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https://bcerac.ca/wp-content/uploads/2019/08/Access-Page-Code-2019-08-27-1.pdf

https://bcerac.ca/wp-content/uploads/2019/09/BCDC-Implementation-and-Support-Technical-Guide-v1-2019-08-21-1.pdf

https://bcerac.ca/wp-content/uploads/2019/09/BCDC-Implementation-and-Support-Technical-Guide-v1-2019-08-21-1.pdf

https://bcerac.ca/wp-content/uploads/2018/08/Getting-Started-2019-06-27.pdf