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Privacy Evaluation for Istation

Last updated January 10, 2020

Overview

Istation is an e-learning platform that provides computer adaptive assessments and defines the different classifications of data collected by its service and the purpose for its collection. The policies do not clearly state if user created content and social interactions are monitored, logged, or moderated. The terms state personal information is collected and shared with third parties, but the policies do not indicate if a user can control their personal information through privacy settings. Also, the policies state that reasonable security measures are used including data encryption during transit and at rest. The polices state that Istation is intended to be used by students in K-12 and teachers. In addition, the policies indicate that personal information on students under 13 years of age is collected and parental consent is required to be obtained by the school or district.

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

Safety

The policies do not clearly state if user created content and social interactions are monitored, logged, or moderated. However, the terms do state that Istation may choose to implement filters or block content, but they are under no obligation to do so. The policies do not indicate if users can interact with either trusted or untrusted users. However, the policies do indicate that personal information is made public, but they do not indicate what information is displayed, how it is controlled, or whether it can be deleted before being publicly displayed. Lastly, there are no processes indicated in the policies for reporting abusive behavior on the service.

Privacy

The terms state personal information is collected and shared with third parties, but the policies do not indicate if a user can control their personal information through privacy settings. In addition, the policies do not indicate if personal information collection is limited to only the specific product use. The policies state personal information is not sold to third parties, and behavioral ads are not displayed, but the terms do not disclose if traditional ads are used and the policies do not indicate whether Istation filters ads for age appropriateness. The terms state that third parties have access to user information and categories of information are listed, however no indication of the role of third parties is disclosed. In addition, the polices state that users will receive service, marketing, and admin related emails, but users can opt-out of promotional, advertising and marketing related communications.

Security

The policies indicate that access to resources on the service requires a subscription and account. In addition, the policies state that third-party contractors are required to provide the same level of security and protection of personal information as Istation. Also, the policies state that reasonable security measures are used including data encryption during transit and at rest. However, the terms do not indicate whether notification is provided to users in the event of a data breach.

Compliance

The polices state that Istation is intended to be used by students in K-12 and teachers. In addition, the policies indicate that personal information on students under 13 years of age is collected and parental consent is required to be obtained by the school or district. The policies state that authorized users, such as schools and school districts, have access to individual personal information of users and that various levels of access exist (teacher, principal, school-district admin). Moreover, the policies state that any requests by parents to access, modify, or delete student personal information must be made through the school or school district and not Istation directly.

Data Collection
SCORE: 40%

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.
  • Behavioral data are collected.
  • Sensitive data are collected.
  • 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 collected online.
Data Sharing
SCORE: 45%

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 use of information is limited to the purpose for which it was collected.
  • Unclear whether data are shared for analytics.
  • 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.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 60%

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.
  • Unclear whether two-factor account protection is available.
  • Third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Unclear whether this product limits employee or physical access to user information.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 55%

What rights do I have to the data?

  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Unclear whether 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.
  • Unclear whether the school, parents, or students can delete data.
  • Processes to delete user data are available.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 30%

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.
  • 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.
  • Unclear whether 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: 10%

How safe is this product?

  • Unclear whether this product supports interactions between 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 not 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 not moderated.
  • Unclear whether social interactions of users are logged.
  • Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 35%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Behavioral or targeted advertising is not displayed.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles 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: 25%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Unclear whether 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 not 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 40%

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.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • 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.