Privacy Evaluation for Educreations Interactive Whiteboard
Educreations is an interactive whiteboard and screencasting tool. The tool is intended for students and teachers, and is used with students under 13 years of age. The terms state that the only users who may view a student's profile are those who belong to that student's Limited-access User Group or class. The terms also specify that aggregate, non-identifiable data may be shared broadly, because the terms state they in no way restrict or limit the collection and use of aggregate information. In addition, the policies do not provide sufficient details on the confidentiality, security, or integrity of a student's personal information. Lastly, Educreations' terms state they require schools, districts, and/or teachers to obtain parental consent from students' parents before collecting any information.
As part of creating an Educreations user profile on the site, students can add their name and photograph. The terms state that the only users who may view a student's profile are those who belong to that student's Limited-access User Group or class. An individual with a teacher's account and a student connected to their classroom via a unique pin number can see that student's first and last name, email, and last time active (e.g. X minutes ago, etc.). In addition, the terms state a student's lessons are stored privately on educreations.com and are only visible to the student and that student's teachers. Any content a student contributes to their Limited-access User Group will only be displayed to other members of that class.
The terms also state that if a User Submission is published using the "public" setting, that the person is "allowing everyone, including people off of Educreations, to access and use that content."
Educreations's terms claim broad rights to reuse user data. As defined in the terms, the act of uploading or creating data within the site gives Educreations and its subsidiaries, affiliates, and/or successors a perpetual and transferable license to reuse and access user data. However, the rights claimed by Educreations to use and share data widely with affiliates appear to contradict other parts of their policy, where they state, "Personal Information and Children's Personal Information collected through the Site may be shared with companies and organizations ... that have agreed not to disclose it to others." Possibly, this indicates that PII is treated differently than other submissions uploaded to the site.
The terms also specify that aggregate, non-identifiable data may be shared broadly, because the terms state they in no way restrict or limit the collection and use of aggregate information. Educreations's terms state they may collect personal information from students including name, email address, photo, date of birth, school name, audio recordings, videos, photos, online activity, and persistent identifiers. Lastly, Educreations' terms state they may also collect information the student provides to Facebook, Google, or Dropbox if the student links their Educreations account to those third-party authentication providers.
The policies do not provide details on the confidentiality, security, or integrity of a student's personal information. From a brief examination, SSL encryption is required on the login page. However, schools and districts are encouraged to request a more thorough description of the security practices and protections in place.
Educreations' terms state they require schools, districts, and/or teachers to obtain parental consent from students' parents before collecting any information. If a student under 13 years of age attempts to create an account on their own, or enters their birth date, Educreations will not let that student create an account, and will provide notice to the student that they will either have to sign-up with a class code from their teacher or have a parent create an account for them. In addition, it is not clear from the terms if Educreations or third parties can use student data collected from the Service to target advertisements to users on other websites, or on other applications or 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.
- Unclear whether this product collects geolocation data.
- 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.
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.
- Unclear whether 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.
- Unclear whether this product supports social or federated login.
- 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 not 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.
- Unclear whether this product uses industry best practices to protect data.
- Unclear whether this product limits employee or physical access to user information.
- Unclear whether this product encrypts all data in transit.
- 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?
- 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.
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.
- 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 can 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.
- 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.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
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.
- Unclear whether this product allows data collection 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.
- The 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.
- Users can opt out or unsubscribe from marketing communications.
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.
- 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.
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.
- 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.