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Privacy Evaluation for Example of Worse Practices with Pass Rating

Last updated August 4, 2020

Overview

This is an example of a full privacy evaluation that does not transparently answer any of our full evaluation questions, except all the questions used in our rating criteria are transparently answered with better answers which results in a Pass rating that meets our minimum requirements for privacy and security practices.

A higher score means the product provides more transparent and comprehensive privacy policies with better practices to protect user data. Products that receive a low overall score are not necessarily unsafe, because they can receive either a "pass" or "warning" rating depending on how they answer the most important rating criteria questions.

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: 0%

What data does it collect?

  • Unclear whether the product collects personally identifiable information.
  • Unclear if the categories of personally identifiable information collected are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects behavioral data.
  • Unclear whether this product collects sensitive data.
  • Unclear whether this product collects non-personally identifiable information.
  • 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.
Data Sharing
SCORE: 0%

What data does it share?

  • Unclear whether collected information is shared with third parties.
  • Unclear whether the categories of information shared with third parties are indicated.
  • Unclear whether 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.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
  • Unclear whether this product supports social or federated login.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 0%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • Unclear whether parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
  • Unclear whether third-party contractual security protections are required.
  • Unclear whether this product uses industry best practices to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 0%

What rights do I have to the data?

  • Unclear whether users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Unclear whether this product provides processes to modify inaccurate data.
  • Unclear whether the product provides a data-retention policy.
  • Unclear whether the school, parents, or students can delete data.
  • Unclear whether a user's data are deleted upon account cancellation or termination.
  • Unclear whether this product deletes data when no longer necessary.
  • Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 10%

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.
  • Unclear whether 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.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 0%

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
SCORE: 50%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • 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.
  • 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.
Parental Consent
SCORE: 0%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Unclear whether this product collects personal information online from children under 13 years of age.
  • 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.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product requires parental consent.
  • 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.
  • 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.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • 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.