Privacy Evaluation for Seesaw: The Learning Journal
Seesaw provides student driven digital portfolios and simple parent communication. In Seesaw, interactions are originated by and largely mediated through the teacher. This hierarchy provides a relative degree of control over who can work in the website, and who can view student work in the website. Parent accounts can be created in the website, and parent access is restricted to their own child's work. Parents have the ability to share their child's work via social media, however, indiscriminate sharing by parents could potentially pose a privacy concern for the child - schools and teachers are encouraged to speak to parents about responsible sharing.
Seesaw's policies indicate that PII is collected from users under the age of 13 and that parental consent is obtained through the teacher / school. Policies state that no form of advertising is used on the site and that third-party vendors are used for the operations of the website (no data is rented or sold). The policies contain a link to all third-party vendors and their privacy policies. Social login is provided via Google or Clever and some PII is collected from those services. Teachers can share Activity Journals and tag various students in them. These journals can be made public but student information is kept private. Policies state that publicly available Journals will contain PII on the teacher from an Author Profile; the teacher has limited control over what information is made publicly visible. No indication in the policies Policies do not indicate if Seesaw monitors, moderates, audits/reviews, logs, filters or blocks content, nor if there are polices for reporting abusive behavior.
Policies state that “Seesaw is designed for safe sharing”. Teachers can share journals and parents can make them publicly visible / share on social media. Students can also comment on others work but only teachers can share journals (without student information). The terms reference that teachers can make Activity Journals visible but must make their Author Profile visible; including their name, profile picture and other activities posted along with other PII the teacher may choose to share. Policies do not indicate if Seesaw monitors, moderates, audits/reviews, logs, filters or blocks content, nor if there are polices for reporting abusive behaviour.
Policies state that PII is collected of users, automatic tracking (via cookies and analytics services) are used, but no sensitive data is indicated to be collected. The terms reference that some PII is shared with third parties for the operation of the services but data is not sold or rented to third parties and they are contractually limited in their usage of data; informatoin on deletion of data if requested is not provided. Policies clearly state that no forms of advertising are used on the site. The policies include a link to all third-party vendors and their individual privacy policies. Policies indicate that users are notified of material changes to the policies via email and that continued use indicates acceptance. Policies do not contain information on how combined PII is treated or if users are provided notice for changes to how data is collected (or if consent is obtained for changes). Policies include contact information for questions regarding policy changes. While policies do not themselves indicate they are available in languages other than English, links to German, Spanish, French and Dutch are available on their website). Federated social login (Google or Clever) is supported and information is automatically collected. Policies do not indicate if Seesaw shares information with social login providers. Policies do not contain information on de-identified or re-identified information. Policies do not contain information on Do Not Track requests. Terms do make reference to sending marketing emails for Seesaw products to users (teachers) but do not indicate if there is an opt-out option. No information is provided in the terms of deletion request prior to transfer or sale of Seesaw.
According to the policy, authorized users can manage information on students; teachers and parents can also modify, delete or download PII collected by Seesaw. Policies state that PII is used to verify user identity and that PII may be transferred to a different internal account, with authorization from the school. Policies do not clearly state if an account is required to use the product nor if two-factor authentication is required. Policies do indicate that reasonable security measures are in place including data encryption in transit, at rest, and access controlled data centres. In the case of breach, users are notified.
Policies indicate that PII is collected on users, the product is intended for students in K-12 and PII is collected on users under the age of 13, including information from education records. Terms indicate that consent is collected by the school and links are provided on methods of obtaining parental consent; also that students under 13 cannot create an account themselves. Policies state what information is collected on users under 13 but not how it is used and disclosed. Policies do not contain information on parent consent for disclosure to third parties or parental requests limiting further collection of child’s data. Seesaw allows for users to upload content and policies indicate that ownership of content remains with the user, with a limited license being granted to Seesaw for use within the context of the Seesaw service. Policies do not indicate methods of maintaining data accuracy but do indicate that users can modify or correct information in their account. Policies also clearly outline processes for deleting accounts. Policies also state timeframes for deleting abandoned accounts and processes to delete active accounts. No indication in the policies if Seesaw will delete data no longer required or when an account is cancelled or terminated. Policies state that data privacy and security practices are routinely 3rd party audited. Terms reference education records entered into Seesaw by school / teacher but do not specify content. Does make reference that content uploaded by student or teacher may be considered as part of the students education record and that Seesaw is designated as a “School Official” under FERPA.
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is limited to product requirements.
- Geolocation data are not collected.
- Biometric or health data are not collected.
- Behavioral data are not collected.
- Sensitive data are not 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.
What data does it share?
- Collected information is shared with third parties.
- Unclear whether 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.
- 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.
- Unclear whether this product requires account creation.
- Parental controls or managed accounts are available.
- Unclear whether 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.
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.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- 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.
- 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?
- Users can interact with trusted users and/or students.
- Unclear whether 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.
- Unclear whether 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.
- 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.
- 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.
- 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.
- 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.
- Product does create education records.
- Unclear whether this product provides notification of a contract or additional rights.
- Vendor is designated 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.