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.
- 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.
- 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 personal information are indicated.
- Data are shared for analytics.
- Data are not 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.
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.
- 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.
- 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 and review user data are available.
- Processes to modify inaccurate data are available.
- Unclear whether the product provides a data-retention policy.
- Processes for the school, parents, or students 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 permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
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.
- Unclear whether the vendor describes their deidentification process of user information.
- Data are not shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Unclear whether this product supports interactions between trusted users and/or students.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information is shared for social interactions.
- Unclear whether this product displays personal information publicly.
- Unclear whether this product allows users to control how their data are displayed.
- Unclear whether 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.
- 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?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is not displayed.
- Data are not collected by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
- The vendor cannot send marketing messages.
- The vendor does not provide promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Unclear whether this product provides users the ability to 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 online.
- Unclear whether intended for parents or guardians.
- Unclear whether vendor has 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.
- 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.
- Product does create education records.
- Notification of a contract or additional rights is provided.
- 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.
- Unclear whether this product discloses directory information.