Privacy Evaluation for Bark
Overview
Bark continuously monitors online interactions to provide parents, guardians, and teachers with email and/or text alerts when potential online dangers (such as cyberbullying) or potential signs of trouble (such as depression) are identified in email or text messages and/or interactions with designated social media sites or websites involving registered children or students. Bark's terms require parents and teachers to authorize Bark to access, monitor, review, and store all online interactions and other communications to and from registered child and student accounts. Bark's terms state they may collect all personal and non-personal usage information provided by the registered child or student account that includes, but is not limited to first and last name, email address, contacts, connections, payments, messages, location information, and other communications.
In addition, Bark's terms state they have adopted technical and organizational measures to preserve and protect users' personal information that the service monitors from unauthorized use or access and from being altered, lost or misused. Lastly, the terms state users have the right to access, rectify, erase, block and oppose any processing of their personal data that Bark has collected.
Bark can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. In addition, Bark is available through the Google G-Suite Marketplace. The Privacy Policy and Terms of Use used for this evaluation can be found on Bark’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Terms of Service, and Bark School Monitoring Terms of Service. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Bark's terms require parents and teachers to authorize Bark to access, monitor, review, and store all online interactions and other communications to and from registered child and student accounts. An educator, parent, or a school has the ability to filter or block inappropriate content or social interactions and determine whether abusive behavior, or cyberbullying has occurred.
Privacy
Bark's terms state they may collect all personal and non-personal usage information provided by the registered child or student account that includes, but is not limited to first and last name, email address, scontacts, connections, payments, messages, location information, and other communications. When users register for a Bark account they must also provide the names of their third-party services (such as Gmail, Microsoft Office 365, Facebook or Twitter) and the user name and password for each account to be connected to the Bark service for monitoring purposes.
The terms state Bark may allow third party service providers to place cookies on the service to provide behavioral advertising and to perform analytic or marketing functions where users are notified of them and have have provided consent. Furthermore, the terms state third parties may collect information about a user's online activities over time and across different websites when they use the services. However, the terms indicate that a user's personal information may be sold to third parties.
Lastly, the terms state Bark may provide de-identified user data on an anonymous aggregate basis to third party business partners, including for conducting academic research and surveys or commercial analytics, and to publish periodic sector or segmented information and reports about behavior patterns and tendencies of children and student's online behavior.
Security
Bark's terms state they have adopted technical and organizational measures to preserve and protect users' personal information that the service monitors from unauthorized use or access and from being altered, lost or misused. The terms also state Bark takes into account the technological state of art, the features of the information stored and the risks to which information is exposed. In addition, the terms state the service limits access to user data only to employees who need to know it to enable Bark to perform the services. However, the terms indicate that encryption of user data in transit or while at rest implemented. The terms state that if Bark learns of a security breach, then they will attempt to notify users electronically as soon as reasonably possible so that they can take appropriate steps.
The terms of Bark state the school or district is responsible for setting the default configuration of the services that controls the supervision and monitoring of activities, and determines the personal data to be monitored and collected from children and students. The setting of those configurations constitutes instructions for Bark to process user data on their behalf as necessary to provide the services. The level and degree of user data surveillance and monitoring is entirely under a school or district's control.
Compliance
The terms state users have the right to access, rectify, erase, block and oppose any processing of their personal data that Bark has collected. In addition, users can update, amend or delete their contact information at any time by visiting the settings page on the service. However, any requests to access, modify, or delete user information must be sent to the school or district because the terms state Bark will forward any such requests received by them to the respective school or district who is responsible for responding to any user requests.
The terms state the service is designed to be a tool for parents and others to use to facilitate safe online interactions for children. However, the terms state the service is neither designed nor intended to be attractive to children under the age of 13. While the Bark service includes analysis of online interactions by children, the terms state Bark does not knowingly collect data from children under the age of 13 without first receiving verified parental consent. Lastly, the terms state user data from students may include personally identifiable information from education records that are subject to FERPA and Bark is to be considered a "School Official" and will comply with FERPA.
Rating
- Data are not sold or rented to third parties.
- Data are shared for third-party advertising and/or marketing.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
Data Collection
SCORE: 50%
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is not limited to product requirements.
- Geolocation data are collected.
- Biometric or health data are collected.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
Data Sharing
SCORE: 80%
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- The categories of third parties that receive personal information are indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports social or federated login.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 75%
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data at rest are encrypted.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 80%
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access and review user data are available.
- Processes to modify inaccurate data are available.
- A data-retention policy is available.
- Processes for the school, parents, or students to delete data are available.
- A user's data are not deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%
Is the data sold?
- Data are not sold or rented to third parties.
- Users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party.
- Unclear whether users are notified if their information is transferred to a third party.
- Unclear whether user information can be deleted prior to its transfer to a third party.
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
- Unclear whether user information is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 80%
How safe is this product?
- Users can interact with trusted users and/or students.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is not displayed publicly.
- Users cannot control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Social interactions of users are logged.
- Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 45%
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Behavioral or targeted advertising is displayed.
- Data are collected by third-party advertising or tracking services.
- Data are used to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Users cannot opt out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 80%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- Intended for parents or guardians.
- Vendor does have actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Parental consent is required.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Children's personal information is not deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
School Purpose
SCORE: 70%
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Intended for teachers.
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is designated as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Directory information is not disclosed.
Common Sense Standard Privacy Report (SPR)
The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.
About Privacy Evaluations
The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.
Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.