Privacy Evaluation for Engrade
Engrade by McGraw-Hill Education is a learning management system (LMS) and assessment engine. Engrade empowers educators and unlocks student achievement. Engrade McGraw-Hill Education's policies are not transparent about whether users can interact with trusted or untrusted users. Engrade McGraw-Hill Education's terms state they will not sell users' PII to other organizations or use information from educational records for marketing purposes. In addition, the policies state that Engrade McGraw-Hill Education will establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of users' personally identifiable information. The terms of Engrade McGraw-Hill Education's policies state that they use user information to provide the digital learning solution on behalf of a school in order to meet its contractual obligations with the school or district.
Please Note: The terms state they do not apply to any data submitted to or collected by Engrade - McGraw-Hill Education in connection with the educational or instructional use of their products and services by customers, students, and/or educational institutions. If a user registers to use the services on behalf of an educational institution, they will be required to agree to additional terms and conditions in connection with the registration process that are not used in this evaluation process.
Engrade McGraw-Hill Education's policies are not transparent about whether users can interact with trusted or untrusted users. In addition, the terms are unclear whether information may be shared or revealed by a user in order to participate in social interactions or that a user's personal information can be displayed publicly in any way. The terms also state Engrade McGraw-Hill Education reserves the right, but not the obligation to remove, to not transmit any user content that they deem to be in violation of their terms. However, Engrade McGraw-Hill Education does not and cannot review all user content or service uploads from users, and their policies state they are not responsible for such content. Engrade McGraw-Hill Education may report communications or materials provided by users to their educational institution if they believe the communications or content are in violation of their terms. Lastly, Engrade McGraw-Hill Education provides external links to resources to learn more about safety.
In addition, Engrade McGraw-Hill Education's terms state they purchase and rent marketing lists from various providers including event management companies and education non-profits. Engrade McGraw-Hill Education's policies state they may share user information with third parties to provide users with marketing information. However, McGraw-Hill Education's terms state they will not share users' PII with third parties for them to market to users on their own behalf. McGraw-Hill Education's terms also specify they will not market to students using the information from their educational records, which are records directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution.
Engrade McGraw-Hill Education's terms state they will not sell users' PII to other organizations or use information from educational records for marketing purposes. The terms of Engrade McGraw-Hill Education state they may use users' PII to provide them with materials that they believe are of interest to users. In addition, Engrade McGraw-Hill Education's policy states they may display advertisements to users in connection with user content, and may use user content to advertise and promote Engrade McGraw-Hill Education's products and services. This allows Engrade McGraw-Hill Education to collect information about customer usage and online behavior to tailor marketing to areas that they believe may be more appropriate for the user. Lastly, Engrade McGraw-Hill Education's terms state they allow third parties to collect information automatically from users across websites and over time through the use of their own cookies, web beacons, and tracking mechanisms.
Engrade McGraw-Hill Education's policies state they may collect users' name, initials, and contact information when they create an account. In addition, the policies state Engrade McGraw-Hill Education will establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of users' Personally Identifiable Information. The terms specify Engrade McGraw-Hill Education owns, controls, and operates its services from their offices in the United States. However, the terms do not state whether personal information is encrypted while in transit or while in storage and there is no information provided about notification to users in the event of a data breach.
Further, the terms specify that due to the increasing focus on the security and protection of personal and student information, Engrade McGraw-Hill Education's privacy practices comply with such federal regulations as COPPA and FERPA. Engrade McGraw-Hill Education acknowledges that it will be considered a "School Official" (as that term is used in FERPA) and agrees that it will comply with the requirements in FERPA concerning the confidentiality and release of Personally Identifiable Information.
Lastly, McGraw-Hill Education has taken a leadership role with Future of Privacy Forum (FPF) and the Software and Information Industry Association (SIIA) in setting the agenda for self-regulatory goals for student privacy in the industry. The terms further specify they have an internal Privacy Council comprised of senior leaders throughout our company that provides the tone at the top to perpetuate best practices across our business.
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.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- 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.
- 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.
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.
- Unclear whether this product encrypts all data in transit.
- Unclear whether all data are stored in an encrypted format.
- Unclear whether this product provides notice 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.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- 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.
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 not shared in an anonymous or de-identified format.
- Unclear whether 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.
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.
- User-created content is not 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.
- Users can report abuse or cyberbullying.
Ads & Tracking
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.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- 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.
- 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.
- Parents can withdraw consent for the further collection of their child's information.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Unclear whether this product provides parental consent notice and method for submission.
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?
- 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.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- 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.
- 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.