The Metamorphosis Foundation for Internet and Society, responding to a public invitation from the Ministry of Education and Science from 6 July 2020 for Public Consultation on the draft version of the Concept for Distance Education, prepared the following opinion based on previous experiences and specialist expertise developed through projects and initiatives such as the National Strategy for Development of Information Society (2004-2005), CRISP (Children’s Rights on the Internet – Safe and Protected)! (2007-present) ), Free Culture – Creative Commons, Open Access to Academic Content and the European Network Commune (2007-present), the research Using Computers in Education (2010), Open Educational Resources (2012-present), Critical Thinking for Mediawise Citizens – CriTink (2018-today), Increasing Civic Engagement in the Digital Agenda – ICEDA (started in 2020) and several other previous and current activities.


Procedural remarks

First of all, Metamorphosis procedurally indicates that the deadline for submission of proposals and suggestions until 10 July is too short (4 days only) to make a sound analysis of the published draft of the Concept and to obtain opinions from all stakeholders. That is why we propose that the deadline is prolonged and that state institutions offer more forms of consultation, including the use of digital communication tools such as online meetings. The use of the ENER system as an electronic forum should also be considered because due to the situation with COVID-19 there are no conditions for physical meetings and round tables.

Development of state policies in this field is necessary because, despite the crisis with COVID-19, there are children who (sometimes temporarily and sometimes long-term) can not attend school for various reasons (health, economic), and because there are children with disabilities, who live in rural areas and belong to other marginalized groups.

The given time frames are of great importance and should be reconsidered. According to the draft Action Plan, the Concept is not planned to be implemented this school year, but in the following ones. However, it is necessary to pay immediate attention to the current needs, given that the new school year begins in less than 2 months. That is why it is important, in addition to the full reform, which is a long-term process, to launch an urgent public debate on draft solutions in the short term.

Solving new and accumulated problems requires developing at least two different approaches/plans: a crisis management plan and a long-term plan. Distance education is certainly a very useful form that should exist for children who need such support in the long run ( after the crisis with COVID-19). Thus, the development of Distance Education Policy should be approached with two different plans:

(1) short-term crisis management and rapid mobilization plan; and

(2) a multi-year plan aimed at creating conditions for successful implementation of the overall policy.


The need for decision-making based on empirical research

The Draft-Concept of the Ministry of Education and Science states that so far there aren’t any published research to identify the situation. The Metamorphosis Foundation, in partnership with the Open Society Foundation – Macedonia, is currently conducting such research, which aims to detect the challenges of elementary school staff across the country. The findings will be available to the MES, the BDE and the public.

The research is ongoing, but, from our preliminary findings, in addition to the challenges that the Ministry of Education and Science highlights in the first place, at least one key element is missing – resources, i.e. online learning materials. This problem is especially prominent in rural areas, in areas where, in addition to Macedonian, teaching is conducted in another language, as well as for subjects for which there is no textbook at all. Because of all this, the individual teacher is the one to decide in what manner he/she will impart knowledge to students.

Assessing needs and analyzing the situation must be comprehensive and fact-based because education and all public policies that have a direct impact on children are very sensitive. Experience has shown that slower but more thoughtful changes yield better results than fast but unsustainable policies. An accurate assessment of the problems and needs should be made (especially for the successful implementation of the long-term plan) by pointing out in which environments/communities there is a greater need for support so that actions can be adapted to these needs.


The necessity of applying world experiences for open educational resources

The Concept needs to define digital learning, e-learning and distance learning as three similar, yet mutually different aspects of the educational process, given that each has its specifics and any terminological misunderstanding in the future can serve as a basis for slowing down the practical application. The clear and unambiguous message from the institutions will enable the teaching process in the following school years not to be based on spontaneous solutions, leaving the teaching process in the hands of individual teachers, i.e. their (non)creativity and digital skills. This will prevent discrepancies in the knowledge of the generations forced to receive their education at home.

The document repeatedly mentions “e-contents”, “other resources, such as didactic support”, “updated teaching resources”, “e-textbooks”, and the like. Without wasting time on each term separately, and how they should not be used as synonyms (e.g. e-textbook is not a classic textbook attached online in a PDF format), we will address one major drawback: open educational resources. The benefits of this type of learning resource are enormous, especially in a situation like the current one, and these resources (most often) allow the sharing and modification of a single, quality resource for each teacher, regardless of the place of residence, the language of instruction, socio-economic status, etc.


Textbooks, other e-content and copyright

In terms of promoting open educational resources (OER), it is extremely important to clarify at the highest legal level the copyright aspects of the contents of the education system according to the best practices that have been applied for years in the most scientifically advanced countries of the European Union such as The Cape Town Open Education Declaration of 2007, the Paris OER Declaration 2012 of the UNESCO, Ljubljana OER Action Plan from 2017, the UNESCO Recommendations on OER of 2018 as well as the benefits of the practice of providing free access to educational e-content through the Creative Commons system.

As a future member of the European Union, the Republic of North Macedonia must be included in the European Agenda for stimulating high quality and innovative ways of learning and teaching defined by the concept Opening up education: Innovative teaching and learning for all through new Technologies and Open Educational Resources adopted by the European Commission back in 2013.

It is especially important to unequivocally enable the free use of resources such as textbooks for which the state has already purchased the copyrights and for which citizens do not need to pay a second time to have access to their digital forms.

The concept pays attention to this issue mentioning e-textbooks, in PDF format, and in e-book format that should be approved by the MES. This leads to the conclusion (although not explicitly stated) that the copyrights of all resources published on the national platform would belong to the Ministry.

In the section “organization of distance education,” it is stated that the teacher alone “can prepare/adapt content for the subject they are teaching”. The question must be clarified as to whether these created, or modified, educational resources will be considered copyrighted works of the teacher, whether they are subject to verification by the institutions, or whether they will be legally free for re-use by others.

On the other hand, this verification and approval of all materials that would be used in the national platform by the Ministry of Education and Science draws the need to mobilize additional material and human resources and indicates the need to unequivocally ensure the availability of content at the very beginning of its use. Taking into account previous experiences of creating, printing, and designing certain textbooks for end-users, especially textbooks in the languages ​​of smaller communities, the question of providing the necessary technical and human resources to meet the goals of the national platform emerges.

In the section „Pedagogy“, “learning through computer games” is also mentioned, with the English term gamification. In this case, too, it is important to precisely define the concepts and terminology, because gamification is not learning by playing computer games at all. This topic is too broad to be properly addressed briefly, but it is important to note that although there are “a large number of digital resources with game elements”, the level of incorporation, i.e. the use of games by students in our country is a huge challenge. Namely, most of these resources are in English, and with contents that are sociologically, pedagogically, but also culturally inappropriate for our education. In other words, it is not possible to use them properly, and it is necessary to create gaming activities and classes “from scratch”, according to the needs of our students and teachers.


Child safety and privacy protection

Protecting the safety of children is crucial to the success of the whole reform, which is based on the promotion of many basic human rights.

The increasing use of Internet-based technologies also carries increased risks in the areas of cybersecurity, peer-to-peer cyberbullying, and Internet addiction. Facing these risks should begin with their inclusion in the debate which will result in future strategic documents that will be a framework for organizing distance education.

From the aspect of privacy protection, the published draft does not cover the specifics of the manner of inclusion of each student in distance education, i.e. what will be their identifier, e-name, e-mail address and the like. This is a particularly important point, especially since it is an interaction in which the primary target group is minors. Experience to date indicates the absence of a unified process: some schools have insisted on opening e-mail addresses of children’s names, while others have agreed to register children with parents’ addresses. This process should be further unified since it is inevitable to create a completely new electronic collection of personal data, and therefore the rules for privacy protection should be properly reflected.

The draft Concept lists several distance learning platforms, some of which are owned by the BDE, and some by the relevant ministries, while in practice over the past 4 months many schools have used other platforms, such as Zoom, Google Classroom, Moodle and the like. The recording of classes as well as all the data required for the use of different platforms, under the European regulation GDPR to which our legal system is adapted, is very often treated as a transfer of personal data to other countries. For this, the laws require open information to the parents and even their consent. For schools, this can be an additional administrative burden for which additional resources need to be provided, as well as ensuring uniform use in all schools.

The document itself indicates the need to amend the laws in the field of education, but in the process of changes what should be taken into account is how the principles of personal data protection of all involved individuals will be respected. It is necessary to define exactly who will be the controller, who will be the processor, and who will be the user of all that data, then the timeframe for their storage, technical protection measures, etc. This means that Privacy Impact Assessment procedures will need to be implemented, and given the short time leading up to the start of the school year, these issues require immediate resolution at the global (state) level, as a prerequisite for implementation in individual institutions (schools).


The importance of the roles of parents, educators, psychologists and other stakeholders

The Draft-Concept includes a list of human resources that provides for the involvement of the parent/guardian, which in many families creates additional challenges because not all parents have the time, readiness, knowledge and skills to be constantly at home and fully involved in their child’s education. This especially refers to parents/guardians with more than 1-2 children, single parents/guardians with more children in the education system, parents/guardians who do not have the option to work from home, etc. The role of parents versus professionals must be elaborated in detail as part of support through knowledge checklists and tools, but in the current context, they cannot be expected to leave current jobs to devote themselves solely to home education.

In this context, it is important to provide additional support for children from marginalized communities: parents are a prerequisite for the successful implementation of this policy. In addition to supporting the development of parents’ digital skills and familiarization with the tools, it is necessary to plan specific measures that will provide the same access to children whose parents do not have the will or time to be directly involved in their children’s education (e.g. children from marginalized communities). Failure to pay conscious attention to this aspect will lead to the consequences of the effects of the crisis affecting more marginalized communities in education as they are more economically affected. This is especially important to address with the distance education plan in times of crisis.

It is also important to define the role of the school pedagogue and psychologist in this concept of distance education, starting from the possibilities for online counseling (e-counseling) to the full conceptual rethinking of the educational process not only in terms of its educational component but also the pedagogical. The function of the pedagogical service is to monitor the progress of students, as well as to advise parents, so in the current conditions, it is important to consider the option of group consultation sessions with parents about their challenges in implementing all forms of distance education.

The Concept is important to include additional extracurricular activities that allow students to acquire new skills and develop their creativity. For this aspect, it is important to consult and involve youth workers (at least for students over 15 years) and youth centers, in support of this process and as part of the human resources, which are officially recognized by the Law on Youth Participation and Youth Policies from 2020.


The necessity of promoting digital citizenship and media literacy

The experiences of Metamorphosis from all projects related to the field of ICT indicate that it is extremely important to strengthen the capacities in the field of digital citizenship and media literacy of all involved in educational reforms, such as decision-makers, management staff and teachers who will have to implement them in practice.

Digital citizenship includes several elements, the most important of which is increasing the knowledge of citizens to use new technologies (digital literacy) as well as awareness of the social implications of using it, especially in the direction of promoting their civil rights and opportunities to get involved in decision-making processes at all levels.

Broader media literacy, which often overlaps with parts of the digital literacy field, is one of the priority areas Metamorphosis is working on as part of the Working Group on Introducing Media Literacy into the Formal Education System, the National Coalition for Media Literacy and the Media Literacy Network.

Based on the Survey on critical thinking and media literacy among young people (2019), Metamorphosis and Eurothink pointed out that the problem of media literacy should become a state priority and that raising the level of media literacy should be treated as a strategic goal. In the new conditions, an even more comprehensive reform of the educational programs is needed for these values to be integrated into the development of all forms of education, where remote education and e-education are critical.

The abovementioned remarks are just some of the open questions related to the challenges faced by institutions, organizations, experts and all other stakeholders whose work should be assisted by the Concept of Distance Education. It is therefore extremely important that the consultation process continues in an expanded form, which will increase the inclusiveness and effectiveness of the ongoing comprehensive reforms of the education system.