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Privacy Evaluation for Example of Better Practices with Pass Rating

Last updated August 4, 2020

Overview

This is an example of a full privacy evaluation that transparently answers all of our full evaluation questions with better responses to illustrate the best privacy practices a company's policies should include if the product is collecting personal information from children and education records or student data from students in K-12 schools or districts.

Products that receive a high overall score are not necessarily problem-free, because they can receive either a "pass" or "warning" rating depending on how they answer the most important rating criteria questions. Similarly, products with a low overall score are not necessarily unsafe, because they can receive either a "pass" or "warning" rating.

Each privacy evaluation contains concern categories (below) that are organized by the most important and easy-to-understand privacy practices to quickly evaluate how an application or service compares to similar products. Each privacy evaluation concern consists of ten evaluation questions to provide a comprehensive analysis of the most important strengths and weaknesses of a product. A green check mark indicates a product's policies disclose that they engage in a better privacy practice, and an yellow alert icon indicates that the particular practice is risky or unclear and that users should investigate further prior to use.

Data Collection
SCORE: 90%

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 not collected.
  • Sensitive data are not collected.
  • Non-personally identifiable information is collected.
  • Opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is not collected by a third party.
Data Sharing
SCORE: 100%

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 personal information are indicated.
  • Data are not 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 not supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 100%

How does it secure data?

  • A user's identity is not 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.
Data Rights
SCORE: 100%

What rights do I have to the data?

  • Users cannot 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.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 100%

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 cannot 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 not shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 100%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is not shared for social interactions.
  • Personal information is not displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • User-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 100%

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.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 95%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected online.
  • 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.
  • Parental consent is required.
  • Parental consent is limited with respect to third parties.
  • Parents can 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: 95%

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 not transferred to the school or district.
  • FERPA parental consent exceptions are indicated.
  • Directory information is not disclosed.

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.