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Privacy Evaluation for Gaggle

Last updated January 9, 2020

Overview

Gaggle safety and tracking software combines machine learning technology with safety representatives who review student content. Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Lastly, Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA).

Gaggle 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 Service accessed for this evaluation can be found on Gaggle’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Student & Staff Data Privacy Notice, and a Gaggle Service Level Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. However, because Gaggle has unrestricted and unlimited access to all students' private or sensitive information within a classroom or all students within an entire school, there exist inherent safety and privacy concerns. Administrator accounts for this service should be managed with extreme caution, and students should be aware of the types of content that could appear "suspicious". In addition, the terms state that in order to protect schools or districts against the risks involved in handling child pornography, Gaggle registers incidents containing pornographic videos and images with the appropriate law enforcement authorities.

Privacy

Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. In addition, Gaggle's terms state that it will not sell student or school staff information, and will not share or reuse Personally Identifiable Information from education records for any purpose, unless instructed to do so by the School or District. Gaggle's terms state they do not behaviorally target advertising or show advertising to any user, and does not use student information to target students or their families for advertising or marketing efforts.

Although Gaggle may permit educators and parents to access Gaggle's Service through links provided on the Company Site, visitors should be aware Gaggle's Company Site and Service solutions are governed by two separate policies. The Company Site may work with third parties when visitors use the Company Site, but Gaggle does not control these third parties’ marketing or tracking technologies or how they may be used to track visitors on other third-party websites or services.

Lastly, Gaggle's terms state they may use de-identified information to improve its products and services, and use reasonable de-identification approaches to ensure they are not compromising the privacy or security of the personal information a user entrusts to Gaggle. In addition, Gaggle's terms state they will not attempt to re-identify de-identified data and will not transfer de-identified data to any third party unless they agree not to attempt re-identification.

Security

Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Gaggle's terms state they ensure personal information is encrypted in transit to and from Gaggle using SSL technology, and all personal information is stored in multiple databases with extensive redundancy and failover while maintained at data centers located in two geographically dispersed states.

In addition, the terms specify that Gaggle implements strict restrictions on how data may be accessed, and by whom, and that audit logs are kept to be able to track data modification. Additional security measures are in place to prevent and identify data tampering. In the case of a data breach, Gaggle's terms state they will immediately notify all customers affected using the primary email address specified in their accounts. Lastly, Gaggle's terms state it is the responsibility of all schools to contact parents or legal guardians in the event of a data breach.

Compliance

Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA). Individual children are not allowed to sign up for any Gaggle product and the only way a child may obtain access to a Gaggle product is through their school. In addition, the terms state each school is responsible for creating student accounts for any Gaggle product and they may choose to provide a student's full name, grade level, and ID number.

Gaggle's terms specify it considers all school and district data to be confidential and does not use student data for any purpose other than to provide services. Gaggle's terms reiterate that Student data are the property of the school or district and remain in the school or district’s control throughout the duration of any agreement or contract, and access to student information remains the legal responsibility of the applicable school.

The terms state that before a teacher or school enters, uploads, or access any data concerning a minor student, they must confirm that they have obtained appropriate consent from the parent or guardian of that student, or determined that one of the limited exceptions to the consent requirement applies. Gaggle's terms state they will not distribute to third parties any staff or student data without the consent of either a parent/guardian or a qualified educational institution.

Data Collection
SCORE: 35%

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 not collected online.
Data Sharing
SCORE: 60%

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.
  • Unclear whether data are shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
  • Unclear whether this product supports social or federated login.
  • Contractual limits are not placed on third-party data use.
Data Security
SCORE: 80%

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.
  • 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: 70%

What rights do I have to the data?

  • Opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether users can control their information through privacy settings.
  • Unclear whether 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: 75%

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.
  • 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.
  • The vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 30%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
  • 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: 75%

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.
  • Unclear whether this vendor provides 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.
Parental Consent
SCORE: 60%

Can I provide parental consent?

  • Not intended for children under 13.
  • 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.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 80%

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.
  • Vendor is designated as a school official.
  • Parental consent obligations are transferred to the school or district.
  • FERPA parental consent exceptions are indicated.
  • 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.