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Privacy Evaluation for Summit Learning

Last updated October 15, 2020

Overview

The Summit Learning Program's website describes its product as a personalized approach to teaching and learning inspired by the vision to equip every student to lead a fulfilled life. The services are designed to facilitate strong relationships between teachers and students through real­time data about progress towards goals, access to ongoing feedback, and access to a wide range of learning resources that enable students to build on what they learn from the teacher by self­ directing some of their learning, too. The terms state the service does not include features that make student personally identifiable. The terms state the service collects different personal information depending on whether the user is a teacher, school administrator, parent, or student and how the user uses the learning services. Summit Learning's terms state they employ administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing personal information. Lastly, the terms state that prior to a student accessing the service, the child’s teacher or school administrator must create the student’s account on the service.

Summit Learning can be accessed through its website. Policies used for this evaluation include: Privacy Policy, Security White Paper, User Agreement, Partner Terms of Service, the Data Privacy Addendum, and Program Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms state the service does not include features that make student personally identifiable information publicly available. However, a student may choose to share coursework through certain non-Summit Learning features. The service also limits access to each student’s account to the student’s parents, legal guardians, teachers, school administrators, and other teachers in the student’s school (depending on the setting selected by the school’s administrator). Accordingly, the terms state the service does not permit any student’s account or the content and grades to be viewed or accessed by the general public. Summit Learning's policy notes that it contains third-party links to educational content available online which may allow students to view, and be exposed to, inappropriate content outside of the service.

Privacy

The terms state the service collects different personal information depending on whether the user is a teacher, school administrator, parent, or student and how the user uses the learning service. The terms state the service limits and uses the personal information they collect only for the educational purposes as directed by Partner Schools. The terms state the service does not seek to make money from students or their schools, teachers, or parents. In addition, the terms specify they will not sell or rent (or authorize Service Providers to sell or rent) any personal information they collect from students to any third party for any purpose – including prohibiting the creation of a profile of a student for any commercial purpose. Lastly, Summit learning's terms state they do not use personally-identifiable information to serve behaviorally targeted advertising to students or their families. They do not sell or share personal information.

Security

Summit Learning's terms state they employ administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing personal information. The terms state Summit Learning implements effective identification and authentication methods using multi-factor authentication with strong password complexity and a mobile security application based on two­-factor authentication. The terms also require service providers to implement reasonable security practices in accordance with the Data Privacy Addendum. The terms specify the service uses strong encryption technologies to securely transmit and store all sensitive data. These procedures include data ­in ­transit is secured with encrypted transportation protocols and when at rest sensitive data is encrypted. Lastly, the terms state that in the event that Summit Learning becomes aware of any actual or reasonably suspected unauthorized disclosure of, or access to, student data they will provide notice.

Compliance

Summit Learning's terms state they collect information from students only where a Partner School has entered into a signed Program Agreement with Summit Learning and accepted a Data Privacy Addendum. Licensed Users of the learning Services are also governed by the Summit Learning Platform User Agreement. The terms state that prior to a student accessing the service, the child’s teacher or school administrator must create the student’s account on the service. When the school administrator or teacher registers its students for accounts, Summit Learning relies on consent obtained from Partner Schools acting as an agent of the student’s parent or legal guardian. In addition, the terms state that parents, legal guardians, and students may at any time make a request to access, review, correct, or delete their personal information by contacting the appropriate official at the student’s school or school district. If the school determines that the request should be implemented, the school may either make the change themselves or submit the request to Summit Learning.

Furthermore, the terms state that Summit Learning depends on Partner Schools to ensure they are complying with FERPA provisions regarding the disclosure of any student information that is shared with Summit Learning and to any school officials with a legitimate educational interest. In addition, the terms note that the service complies with COPPA provisions for children's privacy by applying the same policy provisions to adults and children's privacy.

Data Collection
SCORE: 70%

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 not collected.
  • Biometric or health data are collected.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • Non-personally identifiable information is collected.
  • Combined information is treated as personally identifiable information (PII).
  • Personal information from children under 13 years of age is collected online.
Data Sharing
SCORE: 90%

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 not supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 90%

How does it secure data?

  • Unclear whether 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.
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.
  • Processes for the school, parents, or students to delete data are available.
  • Processes to delete user data are available.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 60%

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.
  • 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.
  • Contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 45%

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.
  • Unclear whether profile information is shared for social interactions.
  • Personal information is displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • User-created content is not reviewed, screened, or monitored by the vendor.
  • User-created content is filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
  • Unclear whether social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 85%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are not 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.
  • The vendor can send marketing messages.
  • The vendor does not provide promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 90%

Can I provide parental consent?

  • Intended for children under 13.
  • Unclear whether 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.
  • COPPA parental consent exceptions are not indicated.
  • 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.
  • Children's personal information is deleted if collected without parental consent.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 65%

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 not 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.

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.