Data ethics have emerged as an essential topic in education. Educators must know how to use data effectively and responsibly. This is a complex and systemic issue that involves bringing awareness to all stakeholders, building human capacity, modifying policy, and considering equitable solutions to data use. This article posits an initial framework that lays out responsible data use grounded in the concepts of transparency in and the consequences of the decision-making process, noting competing factors that influence decision making. Examples illustrate the complexity of ethical decision making and how it is manifested in practice. Suggestions on how to use the framework are posed.