Privacy Evaluation for Google Classroom
Google Classroom is a free web service developed by Google and part of the G Suite for Education to help schools streamline the process of sharing files between teachers and students. Students using Google Classroom can view assignments, submit homework, and receive grades from teachers to help them stay on track and organized. The G Suite for Education core services are the heart of Google’s educational offering to schools. The core services include Gmail, Calendar, Classroom, Contacts, Drive, Docs, Groups, Sheets, Sites, Slides, Talk/Hangouts and Vault. More than 50 million students, teachers and administrators in almost every country in the world rely on G Suite to learn and work together.
Google’s terms state they use information to help improve the safety and reliability of the services. G Suite for Education requires users create a Google Account which is created and managed by a school for use by students and educators. Google’s terms state they are fully committed to the security and privacy of users’ data and protecting users and schools from attempts to compromise it. Lastly, Google’s terms state they make contractual commitments in their G Suite for Education agreement and commit to comply with privacy and security standards.
Additionally, other relevant policies used for this evaluation include:
- G Suite Service Specific Terms
- G Suite for Education: Privacy and Security
- Google Education Privacy and Security
- Our Privacy and Security Principles
- Data Processing Amendment to G Suite and/or Complementary Product Agreement
- G Suite Service Level Agreement
- G Suite Technical Support Services Guidelines
- G Suite Services Summary
- G Suite for Education Core and Additional services
- Communicating with Parents and Guardians about G Suite for Education
- Notice template for schools when gathering parent or guardian consent
- Legal Frameworks For Data Transfers
- Google’s Partners
- Google's subprocessors
- Google Advertising
- Type of cookies used by Google
- Export your organization's data
- Compliance amendments for G Suite and Cloud Identity
- Google Cloud Privacy
- Google Cloud Security
Google’s terms state they use information to help improve the safety and reliability of the services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Google, its users, or the public. A school may allow students to access Google services such as Google Docs, Sheets, Slides and Sites. These services enable students to collaborate with their peers and teachers in real-time, allowing them to share their work, get feedback, and make edits instantaneously. They can be kept private, shared with others (such as a parent, or the entire class), or even made public. When users share information publicly, it may be indexable by search engines, including Google. The services provide users with various options for sharing and removing content.
G Suite for Education requires users create a Google Account which is created and managed by a school for use by students and educators. The terms state when creating this account, the school may provide Google with certain personal information about its students and educators, which includes a user’s name, email address, and password in most cases, but could also include secondary email, phone, and address if the school chooses to provide that information. Google may also collect personal information directly from users of G Suite for Education accounts, such as telephone number, profile photo or other information they add to a G Suite for Education account.
The G Suite for Education core services include Gmail, Calendar, Classroom, Contacts, Drive, Docs, Forms, Groups, Sheets, Sites, Slides, Talk/Hangouts, Vault, and Chrome Sync. These services are provided to a school under its G Suite for Education agreement. Besides the Core Services, G Suite for Education users may have access to other Google services that are generally available for consumers, such as Google Maps, Blogger, and YouTube. The terms call these “additional services” since they are outside of the G Suite for Education core services.
For G Suite for Education users in primary and secondary (K-12) schools, Google does not collect or use any user personal information (or any information associated with a G Suite for Education Account) for advertising purposes or to create advertising profiles, whether in core services or other google services accessed while using a G Suite for Education account. However, parents and educators should be aware Google may serve ads to G Suite for Education users in the “additional services,” but administrators have the ability to restrict access to those additional services. Lastly, Google’s terms state they do not assume ownership of any user data in the G Suite core services, and do not share or sell users’ G Suite data to third parties.
Google’s terms state they are fully committed to the security and privacy of users’ data and protecting users and schools from attempts to compromise it. Google claims its systems are among the industry’s most secure and they vigorously resist any unlawful attempt to access customers’ data. Google’s terms state all facilities used to store and process user data adhere to reasonable security standards no less protective than the security standards at facilities where Google stores and processes its own information of a similar type. Google’s terms further describe it has implemented industry standard systems and procedures to ensure the security and confidentiality of user data, protect against anticipated threats or hazards to the security or integrity of user data, and protect against unauthorized access to or use of user data.
In addition, Google’s data centers use custom hardware running a custom hardened operating system and file system. Each of these systems has been optimized for security and performance. The terms state that because Google controls the entire hardware stack, they are able to quickly respond to any threats or weaknesses that may emerge. Google’s terms specify they will take appropriate steps to ensure compliance with all security measures by its employees, contractors and subprocessors to the extent applicable to their scope of performance, including ensuring that all persons authorized to process personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
Google’s terms also state they encrypt Gmail (including attachments) and Google Drive data. In addition, user data that is uploaded or created in G Suite services is encrypted at rest. The terms state data is encrypted at several levels. Google forces HTTPS (Hypertext Transfer Protocol Secure) for all transmissions between users and G Suite services and uses Perfect Forward Secrecy (PFS) for all its services. Google also encrypts message transmissions with other mail servers using 256-bit Transport Layer Security (TLS) and utilizes 2048 RSA encryption keys for the validation and key exchange phases. This protects message communications when users send and receive emails with external parties also using TLS. PFS requires that the private keys for a connection are not kept in persistent storage. Anyone who breaks a single key can no longer decrypt months’ worth of connections; in fact, not even the server operator is able to retroactively decrypt HTTPS sessions.
Lastly, if Google becomes aware of a unauthorized data breach, the terms state Google will notify users of the data breach promptly and without undue delay, and promptly take reasonable steps to minimize harm and secure user’s data.
Google’s terms state they make contractual commitments in their G Suite for Education agreement and commit to comply with privacy and security standards. Whether it’s real time dashboards to verify system performance, ongoing auditing of Google’s processes or sharing the location of Google’s data centers, the terms state Google is committed to providing all its users with utmost transparency.
G Suite for Education’s terms state its core services comply with the Family Educational Rights and Privacy Act (FERPA) and if user data includes FERPA Education Records, Google will be considered a "School Official" (as that term is used in FERPA and its implementing regulations) and will comply with FERPA. Additionally, if schools allow users under the age of 13 to use G Suite for Education, Google’s terms state they contractually require schools using G Suite for Education to obtain parental consent as required by COPPA. Schools are also required to obtain parental consent for the collection and use of personal information in the “additional products” that the school may choose to use with students allows End Users to access before allowing any End Users under the age of 18 to use those services.
The parents of G Suite for Education users in Primary/Secondary (K-12) schools can access their child’s personal information, export the data, or request that it be deleted through the school administrator. School administrators can provide for parental access, export, and deletion of personal information consistent with the functionality of the services. The terms further state if a parent wishes to stop any further collection or use of the child's information, the parent can request that the administrator use the service controls available to them to limit the child’s access to features or services, or delete the child’s account entirely.
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 collected.
- Unclear whether this product collects biometric or health data.
- 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 collected online.
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.
- 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.
How does it secure data?
- A user's identity is 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.
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.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- Processes to download user data are available.
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 can 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 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.
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 not filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are 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.
- Unclear whether this 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.
- Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- 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.
- Unclear whether this product indicates COPPA parental consent exceptions.
- 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.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Parental consent notice and method for submission are provided.
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 transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.