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Privacy Evaluation for Moodle

Last updated August 10, 2021

Overview

Moodle LMS allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimized for collaborative learning. The Moodle software is free and open source, and this evaluation is based only on the terms for the installation hosted at Moodle.org, and this evaluation does not apply to other third-party installations of Moodle.

The terms of Moodle do not disclose whether any social interactions are available between users, or whether any personal information or content may be made publicly visible to others beyond the use of optional forms to ask questions. Moodle's terms state the service may collect personal information such as first and last name, email address, and other information automatically when users visit the service. The terms state that any third parties that Moodle may share user data with are obliged to keep information securely, however, no other details are provided. Lastly, Moodle's terms disclose that users can access, correct, delete, and export their personal information at any time. However, the policies do not disclose any details about use by students or children under 13 years old, or whether verifiable parental consent is required.

Moodle can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy 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: Site Policy, and 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 of Moodle do not disclose whether any social interactions are available between users, or whether any personal information or content may be made publicly visible to others.

Privacy

Moodle's terms state the service may collect personal information such as first and last name, email address, and other information automatically when users visit the service. The terms state Moodle has no interest in collecting data beyond what is needed to make the service work. In addition, the terms state any third parties that Moodle may share data with are obligated to keep user information securely, and to only use data only to provide the service. The terms also state Moodle is committed to ensuring that the personal information they collect and use is appropriate for the purpose in which it was collected. However, the terms state they engage in third-party tracking of users, but do not disclose whether personal information may be used for third-party marketing purposes, or whether personal information may be sold to third parties.

Security

The terms state that any third parties that Moodle may share user data with are obliged to keep information securely, however, no other details are provided. Moodle's terms do not disclose what reasonable security measures are used to protect user information such as encryption and the terms do not disclose whether notice is provided to users in the event of a data breach.

Compliance

Moodle's terms disclose that users can access, correct, delete, and export their personal information at any time. However, the policies do not disclose any details about use by students or children under 13 years old, or whether verifiable parental consent is obtained.

Data Collection
SCORE: 55%

What data does it collect?

  • Personally identifiable information (PII) is not collected.
  • The categories of collected personally identifiable information 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.
  • Unclear whether this product collects interactions, behaviors, or usage analytics data.
  • 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: 75%

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 the categories of third parties that receive data are indicated.
  • Data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Third-party services are used to support the product.
  • The roles of third-party service providers are indicated.
  • Third-party login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 25%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • 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.
  • Unclear whether this product uses reasonable security 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 all data are stored in an encrypted format.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 60%

What rights do I have to the data?

  • Unclear whether 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.
  • Data are deleted when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Processes to download user data are available.
Data Sold
SCORE: 10%

Is the data sold?

  • Unclear whether personal information is 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.
  • Unclear whether 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: 40%

How safe is this product?

  • Users can interact with trusted users.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
  • 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: 25%

Are there advertisements or tracking?

  • Unclear whether personal information are shared for third-party marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • 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.
  • Data profiles are created and used 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.
  • Unclear whether users can 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 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 not 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: 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.
  • Processes to enter education records into the product are not described.
  • Unclear whether 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: 50%

Can I control the use of my data?

  • Users can control the use of their information through privacy settings.
  • Unclear whether 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).
  • Notice is provided if the context in which data are collected changes.
  • Consent is obtained if the practices in which data are collected change.
  • A grievance or remedy mechanism is available for users to file a complaint.
  • Unclear whether 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.