Privacy Evaluation for Securly
Securly is a cloud-based web filtering and parental control service that works across schools and homes. The policies for Securly do not address whether there are any methods for users on the service to interact with one another. The terms state Securly may work with third parties such as network advertisers to display advertisements to users on third-party websites, but also state they do not collect a student’s or a child’s personal information for the purpose of sale, for building student or child profiles, or for commercial purposes not related to the provision of the services. In addition, Securly's policies are clear that the service employs reasonable security measures to protect user data, but are are not clear how the service may utilize encryption to protect data in transit or at rest. Lastly, the policies for Securly are clear that the service is intended to be used by K-12 students and schools.
The policies for Securly do not address whether there are any methods for users on the service to interact with one another. They also do not address any means by which a user may upload or create content on the platform. The polices do make clear that the platform is intended to provide some form of filtering service, but do not provide details on the types of filtering offered or how the content of filtering is determined.
Securly's polices clearly indicate the process by which users are notified in the event of a material change in the policies and provide the opportunity to opt out of the changed policies. They are also clear that the service will not sell any user's personal information to third parties. However, the policies are not clear about how the service may use personal information to display advertising. The terms state Securly may work with third parties such as network advertisers to display advertisements to users on third-party websites, but also state they do not collect a student’s or a child’s personal information for the purpose of sale, for building student or child profiles, o for commercial purposes not related to the provision of the services.
Securly's policies are clear that the service employs reasonable security measures to protect user data, but are are not clear how the service may utilize encryption to protect data in transit or at rest. The policies are clear that whenever data are shared with third party services providers, the service requires those providers to be contractually bound to protect that personal information. Finally, the policies clearly indicate that in the event of a data breach users will be notified.
The policies for Securly are clear that the service is intended to be used by K-12 students and schools. They clearly indicate that schools are able to create administrator and teacher accounts on the service, but do not address how to create student accounts. The policies also indicate that when personal information is collected from students under the age of 13, it is the school's responsibility to obtain verifiable parental consent prior to entering any information about children. However, the policies are not clear how children's information is entered into the product or if children use accounts to access the product. Finally, the policies clearly indicate that the service has mechanisms for schools and parents to access, review, correct, and delete student data.
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.
- Unclear whether this product collects sensitive data.
- Non-personally identifiable information is collected.
- Unclear whether 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.
- The categories of third parties that receive personal information are indicated.
- 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.
- Social or federated login is supported.
- Contractual limits are placed on third-party data use.
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.
- Unclear whether this product encrypts all data in transit.
- Unclear whether this product encrypts all data at rest.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- 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.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether 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.
- 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.
- User information is not 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.
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 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 shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are displayed.
- Behavioral or targeted advertising is not displayed.
- Data are collected by third-party advertising or tracking services.
- Data are 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.
- Users can opt out of traditional, contextual, or behavioral 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 online.
- Intended for parents or guardians.
- Vendor does have 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.
- 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.
- Unclear whether the product creates education records.
- Notification of a contract or additional rights is provided.
- 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.