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Privacy Evaluation for Example of Better Practices with Warning Rating

Last updated July 31, 2020

Overview

This is an example of a full privacy evaluation that transparently answers all of our full evaluation questions with better responses, except all the rating criteria questions have transparently worse answers which results in a Warning rating.

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.
  • Interactions, behaviors, or usage analytics data are not collected.
  • Sensitive data are not collected.
  • Data is automatically 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 data are indicated.
  • Data are not 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 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.
  • 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.
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 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.
Data Sold
SCORE: 95%

Is the data sold?

  • Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is not shared in an anonymous or de-identified format.
  • The company describes their de-identification process of user information.
  • Data are not shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 100%

How safe is this product?

  • Users can interact with trusted users.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information must be not shared for social interactions.
  • Personal information can be not displayed publicly.
  • Users can control how their data are displayed to others.
  • User-created content is reviewed, screened, or monitored by the company.
  • 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: 75%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are not 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.
  • Data profiles are created and used for personalised advertisements.
  • The company cannot send marketing messages.
  • The company does not provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised 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.
  • Intended for parents or guardians.
  • Company does have 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.
  • 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: 94%

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 not transferred to the school or district.
Individual Control
SCORE: 100%

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.
  • Company will not combine data with additional data from third-party sources.
  • Combined information is treated 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.
  • Notice is provided in the event the company receives a government or legal request for a user's 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.