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Privacy Evaluation for Formative

Last updated April 22, 2018

Overview

Formative allows teachers to create assignments for students and receive personalized feedback on learning outcomes in real time. The terms of Formative state they provide certain features that may allow users to share information with other Users. For example, a teacher may choose to populate their profile with their name, school, and the grades and subjects that they teach. The terms of Formative state that collect “personally identifiable information” or “personal data” from users such as their full name, email address, or a photograph that can be used to identify a user. Formative's terms state that to protect users' privacy and security, they take reasonable steps to verify a user's identity before granting them account access or making corrections to their information. Lastly, the terms of Formative state that if a user registers for the service and provides Personal Information, they can update their account and information at any time by reviewing, modifying, or deleting their profile information.

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

Safety

The terms of Formative state they provide certain features that may allow users to share information with other Users. For example, a teacher may choose to populate their profile with their name, school, and the grades and subjects that they teach. Or teachers may ask questions that are visible to other users of Formative. The terms specify that Formative contains user generated content, and also may contain message boards, personal web pages, forums or other interactive features. However, the terms state Child Users cannot post to public discussion forums and their profile is not shared publicly, and only the Parent and other permitted Teachers can see the User’s profile. Lastly, the terms state that parents and teachers should be aware that a Child User may enter free-form text which could include Personal Information that would be visible to other Users..

Privacy

The terms of Formative state they collect “personally identifiable information” or “personal data” from users such as their full name, email address, or a photograph that can be used to identify a user. In addition, the terms specify they may collect usage information about use of certain features on the service, such as the number of questions students have attempted, the points students have received, and the academic concepts present in the assignments teachers create. Formative's terms also specify that in order to provide a personalized learning and high-quality experience for their users, they may use various technologies that automatically collect certain non-personal information from their browser or device.

The terms state Formative may work with business partners to improve their services or offerings and may disclose automatically collected and other aggregate non-Personal Information to authorized business partners to conduct research on online education or assist in understanding the usage, viewing, and demographic patterns for certain programs, content, services, promotions, and/or functionality. Parents and Teachers should be aware they may withdraw permission for their child or student's data to be used for research purposes at any time by contacting Formative without discrimination of any benefits or ability to use the service.

Formative's terms also state they will never provide behaviorally targeted ads to students and will not rent or sell Personal Information that they collect from users with third parties. Lastly, Formative's terms state they will not share Personal Information or other non-personal technical information with other third-party organizations for their marketing or promotional use without users' consent or except as part of a specific program or feature for which users will have the ability to opt-in.

Security

Formative's terms state that to protect users' privacy and security, they take reasonable steps to verify a user's identity before granting them account access or making corrections to their information. In addition, Formative's terms specify they use certain physical, managerial, and technical safeguards designed to preserve the integrity and security of users' Personal Information. Formative's terms state that its employees, agents, and contractors must have a legitimate business reason to access Personal Information users provide and that Formative is operated and managed on servers located within the United States.

The terms also specify when users enter sensitive information, they encrypt the transmission of that information using secure socket layer technology (SSL) or similar technologies, but do not disclose whether users' information is also encrypted while at rest. Formative's terms state that if they learn of a data security incident that compromises or appears to compromise users' Personal Information, then they will attempt to notify users electronically so that they can take appropriate protective steps. In addition, Formative may also post a notice on their service if a data security incident occurs.

Lastly, if Formative needs to share users' data with a research partner, the terms state they will use encrypted files before transfer and adhere to strong password and password transfer procedures. The terms state they will use a Secure Shell (SSH) or secure file transfer protocols (SFTP) to share the data. Upon completion of the research project, Formative's terms state all personally identifiable data will be destroyed by the independent researchers within 60 days. Any publications (infographics, reports, research papers, etc.) that result from research will not identify a user or their school in any way. Results will be reported in aggregate, and researchers will follow federal masking guidelines. Formative's terms state their research partners will never disclose any personally identifiable information to anyone outside of the project.

Compliance

The terms of Formative state that if a user registers for the service and provides Personal Information, they can update their account and information at any time by reviewing, modifying, or deleting their profile information. In addition, the terms state a parent can modify or delete Child User accounts or remove Child Users from view of any Teachers. Formative's terms specify they also take measures to restrict any collection or disclosure of Personal Information from children less than 13 years of age. A child can be registered to use the service through his or her school, or through an integration with the service that is supported by the child’s school, or by teachers, tutors and other similar adults who assist in the educational process (“Teachers”) who have taken steps to obtain parental consent.

In addition, the terms specify that if a Child User attempts to register for the services, Formative will request the email address of that Child User’s Parent in order to seek consent from their Parent. Child Users' information is restricted during their registration attempt, except the Parent email address for purposes of seeking consent. Formative's terms state that in compliance with COPPA and FERPA, parents have the ability to control information about their Child User and can refuse future collection or use of their child’s Personal Information, or they can delete their Child User’s account or contact Formative to do so on their behalf.

Data Collection
SCORE: 55%

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.
  • Unclear whether this product collects behavioral data.
  • Unclear whether this product collects sensitive data.
  • Non-personally identifiable information is collected.
  • Combined information is treated 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: 75%

How does it secure data?

  • 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.
  • 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: 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: 70%

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.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 60%

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 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 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: 70%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Traditional or contextual advertisements are not 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.
  • 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: 90%

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.
  • COPPA parental consent exceptions are indicated.
  • Parental consent is required.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Parents can 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: 60%

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.

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.