Privacy Evaluation for Padlet
Padlet is a digital canvas where users can add photos, videos, audio, text, drawings, graphs, charts, and more. The terms state padlets can be saved with a range of privacy settings, ranging from private, to password protected, to fully visible to anyone with the URL. The terms state that the service may automatically collect information, including personal information, about users and how they use the service. In addition, the terms state Padlet maintains administrative, technical and physical safeguards to protect against loss, theft, unauthorized use, disclosure, or retrieval of personal information. Lastly, the terms of service specify that the school, teacher, or district is responsible for any parental consent requirements or obligations covered under COPPA or FERPA.
The terms state padlets can be saved with a range of privacy settings, ranging from private, to password protected, to fully visible to anyone with the URL. The ability to leave comments with pictures, video, or audio can be toggled alongside visibility settings. The most permissive settings allow for anonymous comments on public posts. Padlet also offers a school-specific, paid offering called Backpack, that provides additional teacher and student features and privacy protections. In the default Padlet account, profiles are publicly visible to anyone with the URL. The terms warn users that if they are contributing to a padlet, they should exercise caution when sharing personal information regardless of the privacy level. The owners of a padlet could change its privacy visibility settings at any time; a padlet you thought was private today may become totally public tomorrow.
The terms state that the service may automatically collect information, including personal information, about users and how they use the service. If Padlet shares user data with third parties as part of providing the service, these third parties will be contractually required to only use the shared data to support Padlet. In addition, the terms state that Padlet will not sell user data and will not user personal information for third-party marketing purposes. However, the terms do not state whether Padlet may display third-party ads to users on its service, or display ads about Padlet outside of the service by tracking users.
The terms state Padlet maintains administrative, technical and physical safeguards to protect against loss, theft, unauthorized use, disclosure, or retrieval of personal information. In addition, Padlet ensures passwords are stored and transferred securely using encryption and salted hashing. The terms state the service is hosted on servers at a third-party facility, with whom Padlet has a contract providing for enhanced security measures. For example, personal information is stored on a server equipped with industry standard firewalls and the hosting facility provides a 24x7 security system, video surveillance, intrusion detection systems and locked cage areas. Lastly, the terms state that if Padlet learns of a security breach, they will attempt to notify users electronically so that they can take appropriate protective steps.
The terms of service specify that the school, teacher, or district is responsible for any parental consent requirements or obligations covered under COPPA or FERPA. The terms also specify that Padlet is not intended to be used by people under the age of 13 without the guidance, supervision and consent of their parents, guardians and/or authorized school officials. The terms specify that schools or teachers using the site with children are expected to get parental consent before sharing student information on the site. Lastly, Padlet's terms specify that users may request to access, modify, delete, or export their personal information.
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.
- 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.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is 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 personal information are indicated.
- Data are shared for analytics.
- Unclear whether 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.
How does it secure data?
- 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.
- 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.
What rights do I have to the data?
- 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.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Permissions, roles, or access controls are available to restrict who has access to data.
- Processes to download user data are available.
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.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
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 shared for social interactions.
- Personal information is displayed publicly.
- Users can 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.
- Unclear whether social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
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.
- Unclear whether this product displays behavioral or targeted advertising.
- 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 cannot 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.
- Unclear whether this product provides users the ability to 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 online.
- Unclear whether intended for parents or guardians.
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- 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.
- 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.
Is the product intended for school?
- Unclear whether intended for students.
- Personal information or education records are collected from preK-12 students.
- Unclear whether 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.