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Privacy Evaluation for Facing History and Ourselves

Last updated July 22, 2020

Overview

Facing History and Ourselves is a website focussed on helping students learn about hatred and bigotry so they can stop them from happening in the future. The terms for Facing History and Ourselves state that accounts are available but that most of the website is accessible without one. They further state that they do collect personal information from users who create accounts, donate money, or sign up for programs. The terms state that they do not share donors' personal information, but they do share user information with third-party service providers, who are required to maintain confidentiality of that information and not use it for other purposes. The terms also state that they do not sell or rent its customer lists. Facing History and Ourselves' terms state that advertising is shown based on a user's online behavior, demographics, and location, but do not state that it is based on personal information. The terms state that third parties track user activities across third-party sites. The terms state that they use security to protect personal information, including encrypting confidential information in transit, but make no reference to other encryption. The terms do not make it clear whether users can interact with other users, nor references to uploading any content to the product. The terms state that for users for whom the GDPR applies, they can access, modify, or delete their information. Finally, the terms state that they do not intentionally collect information from children under 16, but it is not clear whether the site in general is intended for use by children or students, however the terms do refer to teachers using the site.

Facing History and Ourselves can be accessed through its website. The Privacy Policy used for this evaluation can be found on Facing History and Ourselves’ website. Additionally, other policies used for this evaluation include: Cookie Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Data Collection
SCORE: 50%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Collection or use of data is not limited to product requirements.
Not yet answered
  • Did not evaluate whether the categories of collected personally identifiable information are indicated.
  • Did not evaluate whether this product collects geolocation data.
  • Did not evaluate whether this product collects biometric or health data.
  • Did not evaluate whether this product collects behavioral data.
  • Did not evaluate whether this product collects sensitive data.
  • Did not evaluate whether this product collects non-personally identifiable information.
  • Did not evaluate whether this product treats combined information as personally identifiable information (PII).
  • Did not evaluate whether this product collects personal information online from children under 13 years of age.
Data Sharing
SCORE: 50%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether the categories of information shared with third parties are indicated.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are placed on third-party data use.
Not yet answered
  • Did not evaluate whether the purpose for sharing a user's personal information with third parties is indicated.
  • Did not evaluate whether use of information is limited to the purpose for which it was collected.
  • Did not evaluate whether data are shared for analytics.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate whether data are shared with third-party service providers.
  • Did not evaluate whether the roles of third-party service providers are indicated.
Data Security
SCORE: 42%

How does it secure data?

  • Account creation is not required.
  • Unclear whether parental controls or managed accounts are available.
  • Industry best practices are used to protect data.
  • All data in transit are not encrypted.
  • Unclear whether this product encrypts all data at rest.
  • Unclear whether this product provides notice in the event of a data breach.
Not yet answered
  • Did not evaluate whether a user's identity is verified with additional personal information.
  • Did not evaluate whether two-factor account protection is available.
  • Did not evaluate whether third-party contractual security protections are required.
  • Did not evaluate whether this product limits employee or physical access to user information.
Data Rights
SCORE: 75%

What rights do I have to the data?

  • Unclear whether users can create or upload content.
  • Processes to access and review user data are available.
  • Processes to modify inaccurate data are available.
  • Processes for the school, parents, or students to delete data are available.
Not yet answered
  • Did not evaluate whether opt-in consent is requested from users at the time personal information is collected.
  • Did not evaluate whether users can control their information through privacy settings.
  • Did not evaluate whether users retain ownership of their data.
  • Did not evaluate whether the product provides a data-retention policy.
  • Did not evaluate whether a user can delete all their data.
  • Did not evaluate whether this product provides users the ability to download their data.
Data Sold
SCORE: 50%

Is the data sold?

  • Data are not sold or rented to third parties.
  • Unclear whether user information can be transferred to a third party.
Not yet answered
  • Did not evaluate whether users can opt out from the disclosure or sale of their data to a third party.
  • Did not evaluate whether users are notified if their information is transferred to a third party.
  • Did not evaluate whether user information can be deleted prior to its transfer to a third party.
  • Did not evaluate whether third-party transfers are contractually required to use the same privacy practices.
  • Did not evaluate whether user information is shared in an anonymous or deidentified format.
  • Did not evaluate whether the vendor describes their deidentification process of user information.
  • Did not evaluate whether data are shared for research and/or product improvement.
  • Did not evaluate 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 this product displays personal information publicly.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
Not yet answered
  • Did not evaluate whether users can interact with untrusted users, including strangers and/or adults.
  • Did not evaluate whether profile information is shared for social interactions.
  • Did not evaluate whether this product allows users to control how their data are displayed.
  • Did not evaluate whether user-created content is reviewed, screened, or monitored by the vendor.
  • Did not evaluate whether social interactions of users are logged.
  • Did not evaluate whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 25%

Are there advertisements or tracking?

  • Data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays behavioral or targeted advertising.
  • 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.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
Not yet answered
  • Did not evaluate whether this vendor can send marketing messages.
  • Did not evaluate whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Did not evaluate whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Did not evaluate 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 requires parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
Not yet answered
  • Did not evaluate whether intended for parents or guardians.
  • Did not evaluate whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Did not evaluate whether children's privacy is applicable.
  • Did not evaluate whether this product discloses COPPA parental consent exceptions.
  • Did not evaluate whether this product limits parental consent with respect to third parties.
  • Did not evaluate whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Did not evaluate whether this product deletes children's personal information if collected without parental consent.
School Purpose
SCORE: 50%

Is the product intended for school?

  • Unclear whether intended for students.
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
Not yet answered
  • Did not evaluate whether personal information or education records are collected from preK-12 students.
  • Did not evaluate whether intended for teachers.
  • Did not evaluate whether the product creates education records.
  • Did not evaluate whether this product provides notification of a contract or additional rights.
  • Did not evaluate whether this product designates the vendor as a school official.
  • Did not evaluate whether this product transfers parental consent obligations to the school or district.
  • Did not evaluate whether the vendor indicates FERPA parental consent exceptions.
  • Did not evaluate 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.