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Privacy Evaluation for Facebook Portal

Last updated October 7, 2019

Overview

Portal is a device that helps you connect with family and friends, share content and experiences with the people you care about, and discover photos, music, videos, and other content. Facebook is a social media and social networking service that allows users to connect with friends, family and other people they know and share photos and videos, send messages and get updates. The terms state Facebook allows users to communicate with other users with messages or posts. For example, when users post on Facebook, they select the audience for the post, such as a group, all of their friends, the public, or a customized list of people. The terms state Facebook does not sell users' data to advertisers which includes personal information like a user’s name or the content of their Facebook posts. However, the terms state Facebook may use the information they collect about a user-including information about their interests, actions and connections-to select and personalize ads, offers and other sponsored content. The terms state Facebook is broadly available to everyone, but a child cannot register an account to use Facebook if they are under 13 years old.

Facebook Portal can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Facebook’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Additionally, other policies used for this evaluation include:

Safety

The terms state Facebook allows users to communicate with other users with messages or posts. For example, when users post on Facebook, they select the audience for the post, such as a group, all of their friends, the public, or a customized list of people. Similarly, when users use Facebook's Messenger or Instagram to communicate with people or businesses, those people and businesses can see the content they share. In addition, the terms state that a user's social network can also see actions they have taken on the service, including engagement with ads and sponsored content. Facebook also lets other accounts see who has viewed their Facebook or Instagram stories.

The terms state that information made public on the service can be seen by anyone, including if they don't have an account. This includes a user's username, any information they share with a public audience, any information in their public profile on Facebook, and any content they share on a Facebook Page. In addition, if users are uncomfortable with what others have shared about them on the service, they can report that content to Facebook. Moreover, Facebook's terms state they content moderate and block content and harmful conduct towards others. The terms state that if Facebook learns of inappropriate content or conduct, they will take appropriate action - for example, offering help, removing content, blocking access to certain features, disabling an account, or contacting law enforcement.

Privacy

Facebook's terms state the types and amount of personal information collected from users depend on how they use the service. For example, the terms state Facebook collects a user's contact information if they choose to upload, sync or import it from a device such as an address book or call log or SMS log history, which Facebook may use for things like helping users and others find people they may know. In addition, the terms state Facebook collects location-related information from users such as their current location, where you live, the places you like to go, and the businesses and people they are near-to provide, personalize and improve their service, including displaying ads to users and others. Also, if users have it turned on, Facebook may use face recognition technology to recognize a user in photos, videos, and camera experiences on the service.

Facebook's terms state they collect information about the people, Facebook pages and groups a user is connected to and how they interact with them across the service, such as people they communicate with the most or groups they are part of. In addition, the terms state Facebook may collect behavioral information about how a user uses the service, such as the types of content they view or engage with; the features they use; the actions they take; the people or accounts they interact with; and the time, frequency and duration of their activities. Facebook may combine this behavioral information with other personal information collected from users across different devices or applications.

The terms state Facebook does not sell users' data to advertisers which includes personal information like a user’s name or the content of their Facebook posts. However, the terms state Facebook may use the information they collect about a user-including information about their interests, actions and connections-to select and personalize ads, offers and other sponsored content. Third-party partners may track users and provide information to Facebook about their activities off Facebook—including information about a user's device, other websites they visit, purchases they make, the ads they see, and how they use their services—whether or not they have a Facebook account or are logged into Facebook. The terms also state a user could see ads served by Facebook on other websites, apps and connected TVs if they use our advertising products. The Facebook Audience Network is a collection of third-party publishers who support their businesses by displaying ads to Facebook users. Lastly, the terms state users give Facebook permission to use their name and profile picture and information about actions they have taken on Facebook with ads, offers, and other sponsored content that they may display to other users.

Security

Facebook's terms state they use reasonable security practices to protect users' personal information such as encryption. In addition, the terms state that in order to operate their global service, they need to store and distribute a user's content and data in our data centers and systems around the world. However, the terms do not provide any additional details about their security practices and do not disclose whether they provide notification to users in the event of a data breach.

Compliance

The terms state Facebook is broadly available to everyone, but a child cannot register an account to use Facebook if they are under 13 years old. To protect minors, Facebook may put special safeguards in place (such as placing restrictions on the ability of adults to share and connect with them), recognizing this may provide minors a more limited experience on Facebook. The terms also state Facebook provides users with the ability to access, rectify, delete, and export their information by visiting their Facebook Settings. Lastly, the terms state users own the content they create and share on Facebook and the service stores data until it is no longer necessary to provide the services.

Data Collection
SCORE: 50%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • 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 not 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.
  • Unclear whether 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.
  • Social or federated login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 45%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether 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.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • 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: 85%

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.
  • 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.
  • Unclear whether the school, parents, or students can delete data.
  • Processes to delete user data are available.
  • Processes to download user data are available.
Data Sold
SCORE: 30%

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.
  • 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.
  • User information is shared in an anonymous or deidentified format.
  • Unclear whether 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: 85%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
  • Personal information is 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: 55%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are displayed.
  • Behavioral or targeted advertising is displayed.
  • Data are collected by third-party advertising or tracking services.
  • Data are used to track and target advertisements on other third-party websites or services.
  • Data profiles are created and used for data enhancement, and/or targeted advertisements.
  • The 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: 10%

Can I provide parental consent?

  • Not intended for children under 13.
  • 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 indicates COPPA parental consent exceptions.
  • 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.