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Privacy Evaluation for FreshGrade

Last updated January 10, 2020

Overview

FreshGrade empowers schools, school districts, teachers, parents, and students to be partners in the education journey. The terms of FreshGrade state parents can track the progress of their child’s learning and students are empowered to take greater ownership of their learning. FreshGrade's terms state they collect Personal Information from students authorized to use the service, such as information that can identify a specific individual, such as a name, address, telephone number, email address, or other information linked to that personal information. The terms specify that FreshGrade has implemented commercially reasonable administrative, physical, and technical safeguards designed to secure Personal Information, including student data, from unauthorized access, disclosure and use. Lastly, the terms of FreshGrade state they do not knowingly collect personal information through the FreshGrade service from a child under 13 until a school or parent has provided appropriate consent and authorization for a student under 13 to use the service and for FreshGrade to collect information.

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

Safety

The terms of FreshGrade state parents can track the progress of their child’s learning and students are empowered to take greater ownership of their learning. The terms specify that students can log-in and view their digital portfolio, self-reflect on their work and work collaboratively with their teachers and parents to achieve their learning goals, as well as capture moments through videos, pictures, audio clips and notes. The FreshGrade terms specify the service may allow users to use the FreshGrade service to host public forums or messaging boards for online discussion or message posting. These are public forums, and information that parents and teachers should be aware may be available to other members of the FreshGrade service or the public.

In addition, each student and his or her parent will only have access to view or submit information relative to that particular student. Neither students nor their parents will be able to view or otherwise access the personal information of other students, unless it is provided to that student account by the School (for example, a class photo and class roster containing the names and photos of other students may be added by a teacher to a student account).

Privacy

The terms of FreshGrade state they collect Personal Information from students authorized to use the service, such as information that can identify a specific individual, such as a name, address, telephone number, email address, or other information linked to that personal information. In addition, FreshGrade's terms state they collect information only on behalf of the school. The terms also specify that FreshGrade considers student data to be highly confidential and uses this data solely to provide the services to the school. The terms also state FreshGrade may also collect school data which could include school name and location, what grade level and subject matter a teacher's teaches, position within the school, and the type of devices students use in the classroom. FreshGrade's terms specify they collect, store, process, and share student personal information only for the purposes of providing the service, or as authorized by a school or a parent.

The terms of FreshGrade state they do not sell, use, or share student personal information or content for marketing or advertising purposes. However, teachers and parents should be aware that FreshGrade's terms state they may advertise its services to school users and to parents, provided that such advertisements are not be based on student data relating to individually identifiable students. In addition, parents and teachers should be aware FreshGrade's terms state they may permit third party online advertising networks to collect information from visitors. However, although the terms of FreshGrade state they may permit third party advertising partners to collect information on the FreshGrade website for the purpose of sending targeted advertisements, they do not allow third party advertising networks to collect information about students or parents who are logged into the service, or to collect information from our mobile apps.

Security

The terms of FreshGrade state users will need an account in order to use the FreshGrade service. In addition, only students who have been invited and authorized to use the service by a school may register as a student for a FreshGrade account and use the service. The terms also specify that FreshGrade has implemented commercially reasonable administrative, physical, and technical safeguards designed to secure Personal Information, including student data, from unauthorized access, disclosure and use.

The terms of FreshGrade state they will maintain a comprehensive data security program designed to protect the types of student data collected and maintained. FreshGrade's terms state they care about the security of users' personal information and use commercially reasonable physical, administrative and technological safeguards to preserve the integrity and security of all information they collect, transfer, and that they share with service providers. Additionally, the terms specify additional security safeguards that include data and transit encryption, firewalls, and physical access controls to buildings and files. Employees and contractors are bound to uphold the provisions in this Privacy Policy, and violators will be subject to disciplinary action, up to and including termination and further legal action. Lastly, in the event FreshGrade has have a reasonable, good faith belief that an unauthorized party has gained access to personal information, or disclosed Personal Information, including student data they will promptly notify the School.

Compliance

The terms of FreshGrade state they do not knowingly collect personal information through the FreshGrade service from a child under 13 until a school or parent has provided appropriate consent and authorization for a student under 13 to use the service and for FreshGrade to collect information. In addition, the terms of FreshGrade specify that if users are not at least 18, they may use the FreshGrade service only with consent from their school or parent.

FreshGrade's terms state users may access, update, or correct their personal information at any time by logging into their account. A school principal, school or district/board administrator, or other individual authorized by the school to view and access student accounts, may be able to view and access all activity and content associated with the student accounts associated with the school or district. In addition, a school may access, update, and correct the personal information contained in any account under their control by logging into their account, and/or by logging into your school student information management system. However, a parent seeking to modify, correct, or delete personal information in a student account that is connected to an active class profile will be instructed to contact the school to discuss data deletion or modification.

Parents and Teachers should be aware the terms state that at the conclusion of each academic year, FreshGrade may suspend the ability to post new user content to any specific classroom. However, any student or parent will be permitted to review, request to delete or otherwise access the archived user content associated with that student or parent. The terms specify that when a FreshGrade portfolio is no longer in active use by a school, the portfolio will be archived. Archived portfolios are maintained to provide parents indefinite access to the student’s work, and parents and students can access such data at any time. FreshGrade's terms state they maintain this information only for the benefit of the parent and student. Lastly, FreshGrade's terms state as permitted by COPPA and FERPA schools providing the service to children under 13 represent that they have received consent from parents, or have the authority to provide consent on behalf of parents, for us to collect information from students before allowing children under 13 to access the services.

Data Collection
SCORE: 50%

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 collected.
  • Unclear whether this product collects biometric or health data.
  • Interactions, behaviors, or usage analytics data are collected.
  • 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.
Data Sharing
SCORE: 85%

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 data are indicated.
  • 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.
  • Third-party login is supported.
  • Contractual limits are placed on third-party data use.
Data Security
SCORE: 70%

How does it secure data?

  • Unclear whether a user's identity is verified with additional personal information.
  • Account creation is 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.
  • Reasonable security practices are used to protect data.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data are stored in an encrypted format.
  • Notice is provided in the event of a data breach.
Data Rights
SCORE: 85%

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.
  • Data are deleted when no longer necessary.
  • Methods are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 75%

Is the data sold?

  • Personal information is 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 in the event of a merge, acquisition, or bankruptcy.
  • 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 that is shared is shared in an anonymous or de-identified format.
  • 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.
Data Safety
SCORE: 65%

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 not displayed publicly.
  • Users can control how their data are displayed to others.
  • User-created content is reviewed, screened, or monitored by the company.
  • User-created content is not filtered for personal information before being made publicly visible.
  • Unclear whether social interactions between users are moderated.
  • Social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 85%

Are there advertisements or tracking?

  • Personal information is not shared for third-party marketing.
  • Traditional or contextual advertisements are displayed.
  • Personalised advertising is not displayed.
  • Data are not collected by third-parties for their own purposes.
  • Users's information is not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for personalised advertisements.
  • The company can send marketing messages.
  • The company does provide promotional sweepstakes, contests, or surveys.
  • Users can opt out of contextual, or personalised advertising.
  • Users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 75%

Can I provide parental consent?

  • Intended for children under 13.
  • Personal information from children under 13 years of age is collected.
  • 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.
  • Parental consent notice and method for submission are provided.
School Purpose
SCORE: 88%

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.
  • Company is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 55%

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.
  • Unclear whether company may combine data with additional data from third-party sources.
  • Unclear whether this product treats combined information as personally identifiable information (PII).
  • Notice is provided if the context in which data are collected changes.
  • Consent is obtained if the practices in which data are collected change.
  • A grievance or remedy mechanism is not 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.

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.