Privacy Evaluation for Edmodo
Edmodo provides a learning network for students, teachers, parents, schools, and districts. Edmodo provides multiple ways for students to interact with one another. The terms state that interactions may occur within classroom spaces, where teachers, parents, and/or school administrators can see interactions that occur between students, messages between students and their teachers, and grades that they receive on assignments. However, the terms further describe that in order for Edmodo to continue to be able to provide the services for free, Edmodo and third-party advertising partners may track and serve advertisements to users. Security protocols include password protection. Edmodo's terms further state that teachers, schools, and/or districts are fully responsible for obtaining parental consent for the collection of personal information from a child under 13 years of age and providing all required notifications to parents under COPPA.
The terms of Edmodo state that student interactions may occur within classroom spaces via limited access codes, where teachers, parents, and/or school administrators can see interactions that occur between students, messages between student’s and their teachers, and grades students receive on assignments. Edmodo's terms specify that parent accounts may see the interactions of their linked child accounts. The policy explains that certain usage-related information may be viewable in the user profile that may be displayed to other users, depending on the User Category; for example, a “badge” may displayed in the profile indicating that a user has added content to the user “library,” or that a user has logged into the Services more than a certain number of times.
The terms of Edmodo state they do not provide any personally-identifying information to advertisers or their advertising partners. The terms further describe that in order for Edmodo to continue to be able to provide the services for free, Edmodo and third-party advertising partners may track and serve advertisements to users. The terms state Edmodo is not creating behavioral profiles of users for advertising or marketing purposes, and are not sharing personally-identifiable information, such as a user’s name, email address, or phone number, with third parties for advertising purposes. However, their terms explain that their partners, affiliates, and service providers, including advertising partners, may also transmit cookies to a user's browser or device when, for example, the user clicks on an advertisement that appears on the Services. The policy notes that referrals to and from the service may result in Edmodo transmitting personal information.
Edmodo's terms state that personal information is protected by a password. Also, when a user enters sensitive information (such as a credit card number) in the credit purchasing process, they state that they encrypt the transmission of that information using secure socket layer technology (SSL). The terms explain that they also use coding practices that take steps to prevent attacks on their services from web browsers and malicious scripts, by processing all actions through several permission verifications checks. The terms do not contain details about any breach notification process, or the time frame in which users will be notified of a data breach.
Edmodo's terms are very clear that teachers, schools, and/or districts are fully responsible for obtaining parental consent for the collection of personal information from a child under 13 years of age (updated to 16 when necessary for EU users) and providing all required notifications to parents under COPPA. However, Edmodo's terms do not disclose its compliance obligations under FERPA with the creation of student records. Edmodo's terms also state clearly that teachers signing up for the service "represent and warrant" that they have the legal authority to agree to "these Terms on behalf of your school and/or district." Accordingly, teachers signing up for Edmodo should verify that they have the ability to create a binding agreement for their school or district.
Edmodo allows parents and teachers to request access, modification, and deletion of student information and Edmodo will retain a user’s personal information for as long as the account is active or as long as needed to provide the services.
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.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is 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 personal information are indicated.
- Data are shared for analytics.
- Unclear whether 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 supported.
- Contractual limits are placed on third-party data use.
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.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- All data in transit are encrypted.
- Unclear whether this product encrypts all data at rest.
- Unclear whether this product provides notice 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 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether permissions, roles, or access controls are available to restrict who has access to data.
- Unclear whether this product provides users the ability to download their data.
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.
- Users are not 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.
- 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.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Users can interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- User-created content is not 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.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Data are shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is not displayed.
- Data are collected by third-party advertising or tracking services.
- Data are 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.
- Unclear whether this vendor provides 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.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected online.
- 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.
- 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.
- Parental consent notice and method for submission are not 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.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor 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.