This dependency on quantitative data to know and report is tied to neoliberal tendencies to view technology as a superior objective mechanism for improving organizations (Harvey, 2007).LA initiatives are data hungry, pushing institutions towards new and expanding data collection activities. Institutions can now collect data beyond classroom and learning management systems (LMS) to include tracking of student interaction locations, campus services and resource use, and co-curricular engagement (e.g. Bowman et al., 2019). Information systems, by their nature, implicate organizations and their actors in the process of data collection and analysis in order to "monitor, regulate, and sanction" individual and institutional action and outcomes (Rutledge, 2013, p. 215). This big data approach to managing the educational enterprise potentially underestimates the social context of education and the complexity of student lives (Selwyn, 2019). Data driven systems may "exacerbate discriminatory decision-making in favor of those social groups most represented in the systems' datasets" (Selwyn, 2019, p. 13).This expansive accumulation of data about students and their contexts plays into an age-old dilemma in American civil society over the struggle between the rights of the individual and the needs of social institutions: how one should be known and what of ourselves we have the autonomy to reveal and conceal (Igo, 2018). How students become known by the institution and what institutions do with those representations occurs with little student engagement (Johnson, 2018), and few privacy policies exist that specifically address what data are being collected from students and how that data are being used to inform organizational processes and outcomes. Rather, data privacy policies governing student data collection and use have lagged behind technological and cultural changes in higher education (Prinsloo & Slade, 2016), perhaps in part because of decreased participation in institutional governance (Kezar & Eckel, 2004) and an increase in the managerial class in higher education who rely upon data (Slaughter & Rhoades, 2004).Given the changing nature of modern data collection toward LA technologies and the movement by higher education institutions toward the investment of time, energy, and capital in LA initiatives, a better understanding of the scope, protections, limitations, and potential harm of current privacy policies in the age of datafication is needed Steiner, Kickmeier-Rust, & Albert, 2016). The purpose of this study is to understand how postsecondary institutional data privacy policies conceptualize and create discourses that represent data and privacy.