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 interactions, behaviors, or usage analytics data.
- Unclear whether this product collects sensitive data.
- 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.
- Unclear whether the categories of third parties that receive data are indicated.
- Unclear whether data are shared for analytics.
- Unclear whether 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.
- Unclear whether this product supports third-party 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.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Unclear whether third-parties with access to information are required to provide the same security protections as the company.
- Unclear whether this product uses reasonable security 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 all data are stored in an encrypted format.
- 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 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.
- Unclear whether this product deletes data when no longer necessary.
- Unclear whether methods 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?
- 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.
- 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 that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be 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.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Unclear whether personal information are shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Unclear whether this product displays personalised advertising.
- Unclear whether data are collected by third-parties for their own purposes.
- Unclear whether this product uses a user's information to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- The company can send marketing messages.
- The company does 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.
- Unclear whether 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.
- 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.
- Processes to enter education records into the product are described.
- Additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is 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.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether 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 available for users to file a complaint.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Unclear whether notice is provided in the event the company receives a government or legal request for a user's information.