Common Sense has recently updated its privacy notice. We also provide an overview of the entire policy here.

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Privacy Evaluation for Moodle

Last updated November 1, 2022

Overview

Moodle is a learning platform that enables educators, administrators, and learners to create personalized learning environments. The privacy policy clearly states that interactions between users of Moodle on forums will be moderated by forum moderators. The policy clearly states the "special categories" of personal data processed by Moodle, but otherwise fails to disclose other types of personal information collected by Moodle. The Privacy Notice does not disclose what information is shared to third parties and further indicates that users are subject to both contextual ads and personalized ads on Moodle. The policy states that Moodle security measures are compatible with the GDPR, but does not provide more details on compability. The Privacy Notice does not clearly state whether Moodle is directed toward students in K-12 education or whether Moodle or a school obtains parental consent from child users under the age of 13.

Moodle can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Notice and Site Policy used for this evaluation can be found on Moodle’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Cookies Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms are unclear whether Moodle itself monitors user content or whether private individuals monitor specific forums. The terms do not disclose whether users are restricted to interacting with trusted users, or whether any user can interact with any other user. The terms fail to state whether users’ personal information can be displayed publicly or whether a user has any control over how their personal information is displayed to others. The Site Policy provides that users can report spam, unsolicited adverts, or any other content that is inappropriate using a “Report to moderator” link.

Privacy

The Privacy Notice discloses that personal information is collected by Moodle but does not specifically disclose the types of personal information collected, other than “special categories” under article 9 of the GDPR. The Privacy Notice does not clearly disclose whether geolocation data is collected, but discloses that health or biometric information, behavioral or activity related data, sensitive personal information, and usage data are all collected by Moodle. The Privacy Notice says Moodle limits the collection of information to only data specifically required for the product. The Privacy Notice also states that Moodle shares personal information and specifically states under the "Marketing" section: "We love to share." The Privacy Notice further states "you can opt out and we will not sell your information." However, the Privacy Notice states that Moodle does not sell users’ personal information.

The Privacy Notice discloses that third party services are used to support Moodle. The Privacy Notice indicates that information is shared with third parties for analytical, research, and marketing purposes. The Privacy Notice clearly states that third parties with whom Moodle has shared personal data with “are obliged to keep your personal data secure and use it only for necessary service delivery.” The Privacy Notice fails to disclose whether Moodle will transfer user data in the event of a merger, acquisition, or bankruptcy, and further fails to provide whether users will be notified, can request that their data be deleted, or whether the third-party successor will be contractually required to provide the same level of privacy compliance as required by Moodle during such an event. The Cookies Policy discloses that Google Analytics cookies are integrated into Moodle, which indicates that third parties are collecting information of users for their own advertising purposes, including personalized advertisements on other third-party websites or services. The terms do not clearly disclose whether third parties can engage in data enhancement. The Privacy Notice indicates that Moodle will send promotional communications to users, and that users can opt out of such communications.

Security

The Privacy Notice indicates that Moodle implements physical security measures in protecting users’ personal information. However, the Privacy Notice fails to disclose whether Moodle encrypts user information when it is at rest or in transit. The Privacy Notice clearly states that Moodle will verify a user’s identity before Moodle processes a request if the request is not made while a user is logged in to Moodle. The terms do not clearly disclose whether an account is required to use the product or whether a user’s account is protected by multi-factor authentication.

Compliance

While Moodle is advertised as a learning platform, the terms fail to provide any clear information on whether Moodle is intended to be used by a K-12 education institution, or whether Moodle can be directed to students or users under the age of 13 with or without parental consent. The Privacy Notice indicates that organizations can implement a security measure for “their Moodle Installation” including a system to check for users who are under the age of consent. However, nothing in the terms describes whether Moodle or a school will obtain parental consent for users under the age of 13. The Privacy Notice includes a section of “Children and Personal Data” which simply states that “It is not our intention to collect personal data from a child” and provides individuals with a method of contacting Moodle if the individual believes a child has disclosed personal data to Moodle. The Privacy Notice does not clearly disclose if Moodle knowingly collects personal information from children under the age of 13, or whether Moodle will delete the personal information of a child if Moodle discovers that the user is under 13 years of age.

The Site Policy indicates that users can create or upload content to Moodle but fails to provide any information on whether the user retains any ownership over the content posted to the website, or whether Moodle receives any license over the content. While the Privacy Notice provides that, under the GDPR, users have the right to correct their data, the Privacy Notice fails to disclose whether users who are subject to the CCPA, and not the GDPR, have the right to modify their data.

Data Collection
SCORE: 45%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • Unclear if the categories of personally identifiable information collected are indicated.
  • Collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Biometric or health data are collected.
  • Interactions, behaviors, or usage analytics data are collected.
  • Sensitive data are collected.
  • Data is automatically collected.
  • 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: 60%

What data does it share?

  • Collected information is shared with third parties.
  • Unclear whether 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 the categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • Unclear what the roles of third-party service providers are.
  • Third-party login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 35%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Unclear whether this product requires account creation.
  • Managed accounts are available.
  • Unclear whether multi-factor account protection is available.
  • Unclear whether 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.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 45%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether 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.
  • Unclear whether authorzied users 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 methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 25%

Is the data sold?

  • Personal information is not sold or rented to third parties.
  • 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is shared in an anonymous or de-identified format.
  • Unclear whether the company describes their de-identification process of user information.
  • Data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 20%

How safe is this product?

  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • Unclear whether personal information can be displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
  • Unclear whether user-created content is reviewed, screened, or monitored by the company.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 40%

Are there advertisements or tracking?

  • Personal information is shared for third-party marketing.
  • Traditional or contextual advertisements are 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.
  • Unclear whether this product creates and uses data profiles for personalised advertisements.
  • The company can send marketing messages.
  • Unclear whether this company provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 20%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether this product collects personal information from children under 13 years of age.
  • Unclear whether intended for parents or guardians.
  • Unclear whether company has 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.
  • Unclear whether parental consent is required before personal information is collected or disclosed.
  • 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: 13%

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.
  • Processes to enter education records into the product are not described.
  • Additional rights or protections may be provided with an additional school contract.
  • Unclear whether the company is designated as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
Individual Control
SCORE: 30%

Can I control the use of my data?

  • Unclear whether 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.
  • Unclear whether company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Unclear whether notice is provided if the context in which data are collected changes.
  • Unclear whether consent is obtained if the practices in which data are collected change.
  • Unclear whether 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.
  • Unclear whether 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.