Privacy Evaluation for Gaggle
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 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.
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.
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.
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 fail over 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.
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.
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 not collected.
- Biometric or health data are not collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are not collected.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is not 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.
- Data are shared for analytics.
- Data are not shared for research and/or product improvement.
- Third-party services are used to support the product.
- Unclear what the roles of third-party service providers are.
- Third-party login is not supported.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is not verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- 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.
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.
- Processes to download user data are available.
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.
- Data are not shared for research and/or product improvement.
- Contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be not shared for social interactions.
- Personal information can be not displayed publicly.
- Users cannot control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Social interactions of users are logged.
- Users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not 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 cannot send marketing messages.
- The company does not 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.
- Intended for parents or guardians.
- Unclear whether company has 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.
- Parental consent is limited 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.
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.
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 will not 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.
- Unclear whether 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.
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.