Thumbnail

Privacy Evaluation for Blackboard Learn

Last updated December 19, 2018

Overview

Blackboard Learn provides instructors with the ability to provide students with course documents, online assignments and assessments, individual grades, and other learning materials in a single environment. Blackboard learn term's state users can provide comments in discussion forums and chats and can send messages to trusted peers and instructors. The terms state Blackboard will not sell or rent users' data. However, Blackboard may share users' personal information with re-sellers and other partners, who may use users' personal information for third-party marketing.

Blackboard’s terms state they employ a variety of physical, administrative, and technological safeguards designed to protect users' personal information against loss, misuse, and unauthorized access or disclosure. Lastly, Blackboard's terms state their collection, use, and sharing of student data is governed by their contracts with the educational institutions, the provisions of FERPA, the Children’s Online Privacy Protection Act (“COPPA”), and other applicable laws that relate to the collection and use of personal information of students.

Blackboard Learn can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and the Microsoft Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Blackboard Learn’s website, iOS App Store, the Google Play Store, and the Microsoft Store. Additionally, other policies used for this evaluation include: Cookie Statement, Privacy Center, Privacy Shield, and Security Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Blackboard learn term's state users can provide comments in discussion forums and chats and can send messages to trusted peers and instructors. However, if users use Behind the Blackboard, Blackboard Community, or other websites with logins, the terms state Blackboard may use the contact details they provide to communicate with those users and to let users communicate with other Blackboard untrusted users. In addition, any content that users submit, post, or display may be viewed by other users, and the terms state Blackboard may monitor or control user content, but does not take any responsibility for posting of user content.

Privacy

Blackboard’s terms state they care about privacy and believe that privacy is a fundamental right for all individuals. The terms state Blackboard collects device, usage, and personal information from users that depends on the type of service used which can include: first name, last name, email address, student ID, account credentials, courses a student is enrolled in, credentials, audio and video recordings, and any other information including personal information users provide. In addition, Blackboard’s terms state they may collect data about student’s responses to quizzes, assignments and other course work, and files they submit or upload as well as their activity and actions within Blackboard.

The terms state Blackboard will not sell or rent users' data. However, Blackboard may share users' personal information with re-sellers and other partners, who may use users' person information for third-party marketing. The terms also indicate educational institutions may enable cloud profiles or social profiles, which allow students to connect their Blackboard profile with their Facebook and Twitter account and use information from those accounts for their Blackboard profile. Educators should be aware these social media companies may recognize users and collect information about their visit to Blackboard, and they may use cookies or other tracking technologies.

Blackboard’s terms specify they may use third-party cookies from services such as Google AdWords, Facebook Business, LinkedIn Campaign Manager, and Twitter Ads to show users relevant ads. Blackboard also allows third-parties to access users’ personal information to make sure they see relevant ads and campaigns on other websites. Blackboard receives information from third-party services about which of their ads or campaigns users have interacted with. In addition, Blackboard's terms state they may display advertising and other advanced features through Google Analytics, such as Remarking with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. The terms state these third party advertising tools allow Blackboard to collect information about users’ visits in order to serve them targeted advertisements based on their browsing history and interests on other websites across the Internet, and on other devices they may use. However, the terms clearly state Blackboard does not use or disclose personal or usage information about students that they collect for behavioral targeting of advertisements to students.

Security

Blackboard’s terms state they employ a variety of physical, administrative, and technological safeguards designed to protect users' personal information against loss, misuse, and unauthorized access or disclosure. The terms also state Blackboard has dedicated information security programs and works hard to continuously enhance their technical and operational security measures. In addition, Blackboard’s terms specify they have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Blackboard's terms further state they use firewalls, data use, and access limitations for their personnel and vendors and physical access controls to their facilities.

Lastly, Blackboard’s terms state personal information will be accessed only by those who have a need to know to provide the products and services to educational institutions and improve them. For instance, the terms state Blackboard's technical teams and client support teams may have access to user's information when they set up the product for a educational institution or when software or database changes are required for support and maintenance purposes.

Compliance

The terms state Blackboard provides educational products and services to schools and other educational institutions. Through the provision of these products and services, Blackboard's terms state they collect personally identifiable information from or about students. Blackboard's terms specify that they consider student data to be strictly confidential and in general do not use student data for any purpose other than improving and providing our products and services to the educational institution or on the educational institution’s behalf. In addition, Blackboard's terms state their collection, use, and sharing of student data is governed by their contracts with the educational institutions, the provisions of FERPA, the Children’s Online Privacy Protection Act (“COPPA”), and other applicable laws that relate to the collection and use of personal information of students. Lastly, because contracts may exist between Blackboard and educational institutions, if users have any questions about reviewing, modifying, or deleting personal information of a student, they should contact their educational institution directly.

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 limited to product requirements.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Non-personally identifiable information is collected.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 90%

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.
  • Use of information is limited to the purpose for which it was collected.
  • 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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 70%

How does it secure data?

  • Unclear whether 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.
  • 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.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 95%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Users can control their information through privacy settings.
  • 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.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 60%

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.
  • Third-party transfer is contractually required to use the same privacy practices.
  • User information is shared in an anonymous or deidentified format.
  • 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: 55%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 65%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is not 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.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether 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.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • 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 deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 50%

Is the product intended for school?

  • Intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Product does create education records.
  • Notification of a contract or additional rights is provided.
  • Unclear whether this product designates the vendor as a school official.
  • Parental consent obligations are transferred to the school or district.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.

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.