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Privacy Evaluation for EduTone

Last updated June 5, 2019

Overview

EduTone provides a cloud-based identity, access management, marketplace, and data analytics platform designed for educational institutions. EduTone's terms state they do not provide social interactions between students and adults, and do not make a user's information publicly visible. EduTone's terms state they collect personally identifiable information and non-personal information automatically. EduTone's terms state they use strict administrative and technical procedures to keep data safe and secure. In addition, EduTone’s terms state they do not knowingly collect any information from children under the age of 13 years of age, unless the School has obtained appropriate parental consent. EduTone states that COPPA does not apply to its Service, because children under the age of 13 are not the target users of the service, or allowed to register an account, or provide information to the Service.

EduTone can be accessed through its website. The Privacy Policy accessed for this evaluation can be found on EduTone’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of EduTone state that any publicly shared comments or ratings on our Service(s) may remain in view to other subscribers after an account deletion, but that but nobody will be able to see the identity of a deleted account holder.

Privacy

The terms of EduTone state they collect personally identifiable information and non-personal automatically collected information. EduTone's terms state they will not sell, rent, or use student information to target students or their families for advertising or marketing purposes, or allow third party advertising networks to collect any information about the users of the services. EduTone's terms state they do not disclose any personal information relating to students, parents, or school officials to third parties without opt-in consent. Lastly, EduTone's terms state they contractually obligate third-party service providers to keep Student PII confidential and to only use it in order to fulfill their responsibilities.

Security

The terms of EduTone state they use strict administrative and technical procedures to keep data safe and secure. The terms also state that they maintain strict administrative, technical and physical procedures to protect information stored in their servers. The terms state access to information is limited (through multi-factor authentication) to those employees who require it to perform their job functions. In addition, EduTone's terms state that the vendor conducts thorough background checks for employees, as well as conducting comprehensive activity audits and ensuring that their work is entirely separate from the rest of our team.

Moreover, the terms describe multiple measures that EduTone has implemented measures designed to secure PII from accidental loss and from unauthorized access, use, alteration and disclosure. All PII is securely stored behind firewalls in a private cloud environment, and all environments are equipped with intrusion detection systems. The terms state that PII is encrypted at rest and in transit to and from the Service using industry-standard encryption technology. Lastly, Edutone's terms state they follow the Department of Education's recommendations to only store information in jurisdictions specific to their users.

Compliance

EduTone’s terms state they do not knowingly collect any information from children under the age of 13, unless the School has obtained appropriate parental consent. EduTone's terms state that COPPA does not apply to its Service, because children under the age of 13 are not the target users of the service, or allowed to register an account, or provide any information to the Service.

However, under FERPA, EduTone requires access to certain student Information or educational records to remain the legal responsibility of the applicable school. EduTone's terms state they will only use personally identifiable information from student education records to enable school officials and parents access and use the services provided by EduTone. Before a school can upload, access or share any data concerning a student with a third party, the school must confirm that they have obtained verifiable parental consent from the parent or guardian of that student, or determined a limited exception under FERPA.

Moreover, the terms state that before EduTone discloses information in response to a legal request, they will contact the School with notice of the requirement, so the School may choose to seek a protective order or other remedy, if applicable. Lastly, EduTone self certifies with the privacy shield safe harbor and has signed the Student Privacy pledge.

Data Collection
SCORE: 40%

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 behavioral data.
  • Unclear whether this product collects sensitive data.
  • 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: 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.
  • 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.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 80%

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.
  • 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: 75%

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.
  • Unclear whether 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.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 70%

Is the data sold?

  • Data are not sold or rented to third parties.
  • Unclear whether 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.
  • Users are notified if their information is transferred to a third party.
  • 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 not 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: 20%

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 not 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
SCORE: 80%

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.
  • Unclear whether this vendor can send marketing messages.
  • Unclear whether this vendor provides 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.
  • 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.
  • 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.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 80%

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.
  • FERPA parental consent exceptions are indicated.
  • 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.