Privacy Evaluation for Branching Minds
Branching Minds is a paid service that supports personalized learning interventions for students. Branching Minds collects a broad range of potentially sensitive information about students, and can be used to track contacts with families about a child's learning. The terms of Branching Minds clearly define the data they collect, and how they handle it. In addition, the terms say Branching Minds does not sell data to third parties and they do not allow third party advertising networks to collect information about users or display any targeted advertisements.
The terms of Branching Minds say that data are encrypted both in transit and at rest. The terms also specify that Branching Minds conducts regular security audits and code reviews, and that their software developers are aware of secure programming practices. The terms of Branching Minds say that Branching Minds is authorized by schools to act as a school official under FERPA. The terms also specify that Branching Minds is used exclusively for an educational purpose, so that schools or districts can provide consent as permitted under COPPA.
Branching Mind's terms say they collect a broad range of potentially sensitive information about students, and the data can be used to track contacts with families about a child's learning. However, the terms do not contain details about whether social interactions are permitted, who can see personal information within the service, or how access within the service is limited.
The terms of Branching Minds clearly define the data they collect, and how they handle it. Branching Minds manages learning interventions between students, so the system may contain sensitive information. The terms specify that Branching Minds does not rent or sell information for marketing purposes and third party advertisers are not permitted to collect any data from users. The terms also specify that data collected within the platform is primarily used for delivering the service, with a small amount of de-identified data used to improve the service. In addition, the terms say that personal information shared with the service will be destroyed when the relationship with the school is terminated, or when it is no longer needed.
The terms of Branching Minds say data are encrypted both in transit and at rest. The terms also specify that Branching Minds conducts regular security audits and code reviews, and that their software developers are aware of secure programming practices. The terms also describe physical and procedural safeguards used to protect the locations where data are housed, including intrusion detection systems and multiple forms of identity verification required to access the server facilities. The terms also specify that access to personal information is limited only to Branching Minds employees who need that data to do their job.
The terms of Branching Minds state the service is authorized by schools to act as a "school official" under FERPA. The terms also specify that Branching Minds is used exclusively for an educational purpose, so that schools or districts can provide consent as permitted under COPPA. The terms also specify that parents can review, edit, and delete educational data collected by Branching Minds by contacting Branching Minds. The terms specify that a teacher or school district official may provide consent for a child under the age of 13 to use Branching Minds when they create a Branching Minds account for that child.
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 not collected.
- Biometric or health data are not collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- Data is automatically collected.
- Unclear whether opt-in consent is requested from users at the time personal information is collected.
- Unclear whether personal information of users is collected by a third party.
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.
- Unclear whether the categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Data are not 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.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
- 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.
- Notice is provided in the event of a data breach.
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.
- Unclear whether the product provides a data-retention policy.
- 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.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
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.
- Unclear whether the company describes their de-identification process of user information.
- Data are not shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Unclear whether personal information can be displayed publicly.
- Unclear whether this product allows users to 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.
- Unclear whether social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company cannot send marketing messages.
- The company does not provide promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Unclear whether users can opt out or unsubscribe from marketing communications.
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.
- Unclear whether company has 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.
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.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- Unclear whether 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.
- Combined information is treated 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.
- Unclear whether 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.