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, and the policy warns about sharing by screenshots.
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). Social login is provided via Google 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 may be kept private. Policies state that publicly available Journals may contain PII on the teacher from an Author Profile; the teacher has limited control over what information is made publicly visible. 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 behavior.
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; information on deletion of data if requested is provided. Policies clearly state that no forms of advertising are used on the site. 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. Federated social login (Google) 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)and indicate 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 centers. 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. 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 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. There is an indication in the policies that Seesaw will delete data no longer required, and that notice will be given first. Policies state that data privacy and security practices are routinely third party audited. Terms reference education records entered into Seesaw by school / teacher but do not specify content. The policy oes 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.
- Interactions, behaviors, or usage analytics data are not collected.
- Sensitive data are not collected.
- Data is automatically collected.
- Unclear whether 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.
- 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.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Third-party 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.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Unclear whether 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Unclear whether this product deletes data 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.
- 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 that is shared is not shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- Unclear whether user-created content is reviewed, screened, or monitored by the company.
- 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?
- 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 can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- Users can 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.
- Company does not have 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.
- 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.
- Processes to enter education records into the product are described.
- Unclear whether 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?
- Unclear whether 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.
- Unclear whether company may 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.
- A grievance or remedy mechanism is available for users to file a complaint.
- Users can not 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.