Privacy Evaluation for Blackboard Learn
75%
Overview
Blackboard 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 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, but the terms also say Blackboard does sell data to third parties under the California Consumer Privacy Act (CCPA). The terms say Blackboard does not use or disclose information about students for behavioral targeting of advertisements. However, Blackboard may place contextual advertising where permitted by their agreement with the educational institution. In addition, the terms say Blackboard may share users' personal information with re-sellers and other partners, who may use users' personal information for third-party marketing and targeted ads.
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 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’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, Security Policy, and California Privacy Notice. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Blackboard 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, but the terms also say Blackboard does sell data to third parties under the California Consumer Privacy Act (CCPA). The terms say Blackboard does not use or disclose information about students for behavioral targeting of advertisements. However, Blackboard may place contextual advertising where permitted by their agreement with the educational institution. In addition, the terms say Blackboard may share users' personal information with re-sellers and other partners, who may use users' personal information for third-party marketing and targeted ads. 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.
Rating
- Personal information is not sold or rented to third parties.
- Personal information is shared for third-party marketing.
- Personalised advertising is displayed.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
Data Collection
SCORE: 45%
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.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- Sensitive data are collected.
- Data is automatically 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: 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.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Third-party login is supported.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 60%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Unclear whether third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 85%
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 60%
Is the data sold?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- 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 that is shared is shared in an anonymous or de-identified format.
- The company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 45%
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- Unclear whether user-created content is reviewed, screened, or monitored by the company.
- 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: 55%
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is displayed.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
- The company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 65%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Unclear whether intended for parents or guardians.
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent with respect to third parties.
- Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
School Purpose
SCORE: 81%
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.
- Processes to enter education records into the product are described.
- Additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Parental consent obligations are not transferred to the school or district.
Individual Control
SCORE: 45%
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is available for users to file a complaint.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's 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.