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Privacy Evaluation for Achieve3000 Literacy Solutions

Last updated February 20, 2019

Overview

Achieve3000 provides a cloud-based service for nonfiction reading and writing that maps student work to that student's reading level. The terms of Achieve3000 specify that users can access "interactive services" that include chat rooms and online bulletin boards. The terms also specify that Achieve3000 does not rent or sell data to third parties. In addition, Achieve3000 may work with business partners to improve their services and that these business partners may receive aggregate or anonymized data. Achieve3000 makes reasonable efforts that include physical, administrative, and technical safeguards to keep data secure. In addition, the terms state personal information is protected by the most current version of Transport Layer Security (TLS) encryption and data are stored in encrypted file systems with the encryption keys stored and maintained in separate secured systems. As noted in the Security section and in the terms, accounts are only available via participating schools, districts, or educational agencies. The terms also specify that schools and districts often sign a "School District Agreement" that contains additional provisions governing the use of the service.

Achieve3000 can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Achieve3000’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Data Processing Addendum, and Technical and Organizational Measures. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms of Achieve3000 specify that users can access "interactive services" that include chat rooms and online bulletin boards. Use of these interactive services is governed by a code of conduct that is included in the terms. Achieve3000 is not obligated to monitor any social interactions, but may monitor interactions at their discretion. The terms also specify that the code of conduct is based on state and federal laws, and Achieve3000 states that they have "the right at all times to disclose information it deems necessary to satisfy any applicable law."

Privacy

The terms specify that Achieve3000 does not rent or sell data to third parties. The terms also state that Achieve3000 can work with business partners to improve their services and that these business partners can also receive aggregate or anonymized data. However, the terms do not specify limits placed on partners receiving this data.

The terms also state that the service can be connected with third party providers such as Facebook or Google, and that Achieve3000 can receive information from these services. However, the terms do not provide details about what information could be collected from these services. The terms also state that Achieve3000 may allow third-party service providers to place and read their own cookies, web beacons, and similar technologies to track users and collect information.

Security

Achieve3000's terms specify that student data should be provided in an "electronic form (.CSV comma separated values or .XLS Excel format) regarding each student who will utilize each Service." The pre-set sample rosters used to generate these lists include fields for student IDs, student first and last name, email address, password, gender, and grade level.

The terms also state that Achieve3000 makes reasonable efforts that include physical, administrative, and technical safeguards to keep data secure. In addition, the terms state personal information is protected by the most current version of Transport Layer Security (TLS) encryption and data are stored in encrypted file systems with the encryption keys stored and maintained in separate secured systems. The terms contain detailed information about regular security audits additional security protections. Lastly, the terms contain an up-to-date incident response plan that includes responsibilities, how information security events are assessed and classified as incident, and notification of users without undue delay after becoming aware of the security breach.

Compliance

As noted in the Security section and in the terms, accounts are only available via participating schools, districts, or educational agencies. The terms also specify that schools and districts often sign a "School District Agreement" that contains additional provisions governing the use of the service. The contents of different School District Agreements are outside the scope of this evaluation as they are not publicly available, and can vary between districts. Ideally, these agreements would be publicly available, consistent across districts, and address requirements and responsibilities under FERPA and COPPA. However, Achieve3000 does include a Data Processing Addendum (“DPA”) as part of its Terms of Service.

Data Collection
SCORE: 45%

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.
  • Unclear whether this product collects sensitive data.
  • 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.
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: 95%

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.
Data Rights
SCORE: 35%

What rights do I have to the data?

  • Unclear whether 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.
  • Unclear whether users retain ownership of their data.
  • Processes to access and review user data are available.
  • Unclear whether this product provides processes to modify inaccurate data.
  • Unclear whether the product provides a data-retention policy.
  • Processes for the school, parents, or students to delete data are available.
  • Unclear whether a user can delete all their data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%

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.
  • 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.
  • 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.
Data Safety
SCORE: 25%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are not moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 10%

Are there advertisements or tracking?

  • Unclear whether data are shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Unclear whether this product displays behavioral or targeted advertising.
  • Data are collected by third-party advertising or tracking services.
  • Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
  • Unclear whether this vendor can send marketing messages.
  • The vendor does provide promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 60%

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.
  • 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.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 40%

Is the product intended for school?

  • Intended for students.
  • Unclear whether 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.
  • Unclear whether the product creates education records.
  • Notification of a contract or additional rights is provided.
  • Unclear whether this product designates the vendor as a school official.
  • Unclear whether this product transfers parental consent obligations 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.