This is a fine start. Substantively, there are some issues to address:

1. Using curricular delivery software as a surveillance tool is an extraordinary step that demands extraordinary justification. Instead, as you say, there is nothing in the professional literature that justifies this intrusion of surveillance capitalism into learning. So you need to show your claim is correct. Don't stop research with the tertiary journalistic sources. Get the underlying papers. If you don't use research software of your own (that should respect your privacy completely), learn to use Zotero now. You could attach the results of your literature search as a Zotero database or as Bibtex to this topic. Then anyone who wants to follow your research can do so.
2. You don't need to recapitulate the possible harms to privacy of individuals resulting from de-anonymization or other misuses of aggregate data. A couple of links to wellp-chosen secondary sources will get the reader started on learning more if she wants to. You can use that space instead to set up the underlying question: If there is no proven benefit to spying on learning, while there are reasons both practical and normative to put all information about students' learning under students' control, why are we doing what we are doing instead of whatever would be better?
3. Merely proposing rules that will not be followed when there is so much money to be made is perhaps not the most efficient way to use our time on the mudball we are making out of the miracle that is Earth. The root of the "learning management software" problem is that it does the wrong thing. I hate content management systems because all they do is manage content. I hate learning management systems even more because all they do is manage learning, and learning is of all human processes that one that doesn't need management. Human curiosity, the desire to learn, which peaks in childhood, needs nurturing in the context of human relationship, of dialogue, of mutual empowerment. That processes of teaching and learning in relationship has made the human race what it is, and can still save it. Management is the antithesis of assisting learning.

   So we want instead of this learning management stuff to use technology that enacts our educational philosophy. The wiki is a fundamental tool for social constructionist education: we make the course by writing it. Students control whether they use it minimally or maximally to support their learning, individually or collectively, as they choose. People can comment or edit as they please, and can both learn and teach as they do. Everyone has equal access to all the data, and equally complete control over access to their work. The public has access to that which is published, but no third party has preferential access to anything, and all non-public data is under the instructor's, and only the instructor's, control.

   Making such educational enablement software is easy: you are, after all, living with me in it right now. It is made of free software parts anyone can put together freely and share as widely as they like. It's all operated and maintained by one person: me. It runs in virtual machines sitting on servers in my apartment and my office that I assembled from loose parts with my own hands. The education was in this literal, technical sense constructed out of the learning that goes into it, including mine.

So in substance, we are choosing between software that does the wrong thing, with no demonstrable benefit, at immense cost to a fundamental value, freedom of thought, once learning becomes a comprehensively surveilled activity; and software that embodies our educational philosophy and preserves our values, for whose educational benefits we have at minimum our own experience in doing what we say we want society to be able to do. Proof of concept plus running code equals revolution.

These may not be your conclusions, of course, though they are mine. But your own l,earning should be in dialogue with them.