Privacy Evaluation for Summit Learning
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.
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.
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.
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.
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.
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 not 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.
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.
- 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.
- The roles of third-party service providers are indicated.
- Third-party login is not supported.
- Contractual limits are placed on third-party data use.
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
- 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.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- 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.
- Processes for authorized users to delete data are available.
- 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.
Is the data sold?
- Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
- 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 that is shared is shared in an anonymous or de-identified format.
- The company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be not displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is not reviewed, screened, or monitored by the company.
- 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
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- Users's information is not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for personalised advertisements.
- The company can send marketing messages.
- The company does not provide 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.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Intended for parents or guardians.
- Company does have 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.
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent 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.
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.
- Processes to enter education records into the product are described.
- Additional rights or protections may be provided with an additional school contract.
- Company is not designated as a school official.
- Parental consent obligations are transferred to the school or district.
Can I control the use of my data?
- 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.
- Company may combine data with additional data from third-party sources.
- Combined information is treated as personally identifiable information (PII).
- 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.
- A grievance or remedy mechanism is not available for users to file a complaint.
- Users can request to know what personal information has been shared with third parties.
- Notice is provided in the event the company receives a government or legal request for a user's information.