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Privacy Evaluation for Edthena

Last updated January 11, 2018

Overview

Edthena provides video tools designed to enhance professional development for teachers through classroom observation and online collaboration. The terms state the service allows user submissions to be shared between users to facilitate feedback and training between teachers to improve learning outcomes. Edthena's terms state they collect Personally Identifiable Information from a teacher or school and may collect analytics data, or use third-party analytics tools, to help them measure traffic and usage trends for the Service. In addition, Edthena's terms state they have implemented commercially reasonable administrative, physical, and technical safeguards designed to secure Personal Information, including student data, from unauthorized access, disclosure and use. Lastly, Edthena's terms state that it complies with the Children’s Online Privacy Protection Act (COPPA) and Family Educational Rights and Privacy Act (FERPA).

Edthena can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Edthena’s website, and iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Edthena's terms state they allow user submissions to be shared between users to facilitate feedback and training between teachers to improve learning outcomes. The terms state the Edthena Service is a communication tool that permits and encourages data sharing and communication between users, and a user may control which other users may access their submissions, and may invite and authorize non-users to access their submissions.

By default every video in the system can only be seen by the user who uploaded the content. The only way to let others view a user's content is by sharing it to a group through the service. Group membership is controlled by a group admin and that person is clearly identified to the members of any group and is responsible for approving requests to join the group.

Privacy

The terms of Edthena state they collect Personally Identifiable Information from a teacher or school and may collect analytics data, or use third-party analytics tools, to help them measure traffic and usage trends for the Service. The terms state that users, including teachers and teachers-in-training, may upload User Submissions that contain videos, images or personal information of K-12 students, teachers, or other non-users of the Service. Edthena's terms state they agree to treat student data and user submissions as confidential and not to share, use, or sell data to third parties for marketing or targeted advertising purposes. However, Edthena states that any personal information related to non-users that may be provided in user submissions is not strictly subject to its privacy policy.

In addition, Edthena's terms state they may use or share information from user content in an aggregated or anonymous form with third parties that does not personally identify any individual. The terms also state they may share aggregated data with educational institutions to provide feedback to its users or to measure certain metrics over time. Edthena's terms specify they may use aggregate or anonymized data to study and improve their Service, user functionality, and product offerings. Although Edthena may permit third party advertising partners to collect information about a visitor's use of their services over time for the purpose of sending targeted advertisements, Edthena does not allow third party advertising networks to collect information about students or teachers who are logged into the service.

Security

Edthena's terms state they have implemented commercially reasonable administrative, physical, and technical safeguards designed to secure personal information, including student data, from unauthorized access, disclosure and use. Edthena's terms state they use a sophisticated library which looks for things like keyboard patterns, industry terms, and known passwords to help ensure a sufficiently strong phrase for each of its users.

Edthena's terms state they utilize 128-bit encryption to ensure that information is protected against unauthorized access and transmitted over a secure connection. In addition, the terms state that every time a user watches a video in Edthena, their browser is making a request to a content delivery network using a single-use URL. In the event that any information under Edthena's control is compromised as a result of a breach of security, they will take reasonable steps to investigate the situation and where appropriate, notify those users whose information may have been compromised.

Compliance

Edthena's terms state that it complies with the Children’s Online Privacy Protection Act (COPPA) and Family Educational Rights and Privacy Act (FERPA) where use or access to its service by anyone under 13 is strictly prohibited. In addition, Edthena's terms state they do not knowingly collect personal information through the service from a child under 13, unless a user has affirmed that they has obtained appropriate consent from the child’s school or teacher to post such information to the service. A user should contact Edthena if they believe the service has inadvertently collected personal information from a child under 13 without proper consent so that they may delete the information as soon as possible.

Edthena's terms state they consider student data to be highly confidential, and if student data is collected through the Service, Edthena may access, collect and process student data as a school official with a legitimate educational interest under FERPA. A user agrees that when Edthena is acting as a school official, the educational institution or authorized user of that educational institution owns and controls all student data. Furthermore, Edthena users are solely responsible for assuring compliance with FERPA and COPPA for the collection of personal information of non-users, including, K12 students that may be contained in the user submissions. If a user records video of their work in a classroom at a local K-12 school, the video may contain images of children, teachers, or other individuals who are not covered by the terms. The terms state a parent, teacher, or school administrator can contact Edthena to request access to information relating to a student or minor who may appear in user submissions that has been posted on the Service.

Lastly, the terms state if a user provides content information collected from a student under 13, they are required to be the student’s school or teacher and have received consent from parents, or have the authority to provide consent on behalf of parents. The terms state that providing consent on behalf of the student allows Edthena to collect information from the students before providing user content of a child under 13 to the service. Edthena recommends that all schools and teachers provide appropriate disclosures to students and parents regarding their use of the services and that they provide a copy of the Privacy Policy to parents and guardians.

Data Collection
SCORE: 30%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Unclear whether the collection or use of data is limited to product requirements.
  • Geolocation data are collected.
  • Unclear whether this product collects biometric or health data.
  • Unclear whether this product collects behavioral data.
  • 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 supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 50%

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.
  • Unclear whether two-factor account protection is available.
  • Unclear whether third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Employee or physical access to user information is limited.
  • Unclear whether this product encrypts all data in transit.
  • Unclear whether this product encrypts all data at rest.
  • 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: 80%

Is the data sold?

  • Data are not sold or rented to third parties.
  • 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 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: 50%

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 shared for social interactions.
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
  • Unclear whether 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 moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether 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 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 provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of traditional, contextual, or behavioral advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 70%

Can I provide parental consent?

  • Not intended for children under 13.
  • Not intended for parents or guardians.
  • Vendor does not 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.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 70%

Is the product intended for school?

  • Not intended for students.
  • Personal information or education records are collected from preK-12 students.
  • Intended for teachers.
  • Product is not 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 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.