Privacy Evaluation for Turnitin
Turnitin provides instructors with the tools to engage students in the writing process, provide personalized feedback, and assess student progress over time. Turnitin merges originality checking, online grading, and peer review into a single service. Turnitin's policy notes that it may (but is not obligated to) monitor areas of the site for user communications, such as chat rooms, bulletin boards, and other user forums. Turnitin explains that it does partner with a third party to manage its advertising on other sites, and that its third-party partner may use technologies such as cookies to gather information about user activities on this site in order to provide targeted advertising based upon the user's browsing activities and interests. On a positive note, Turnitin's policy claims that it complies with the relevant security standards of the US, EU and Switzerland. Lastly, Turnitin's policy states COPPA’s requirements do not apply to its services and therefore it is not required to get prior verifiable parental consent before collecting or maintaining personal data.
Turnitin's policy indicates that it includes social media features, such as the Facebook “Like” button, the “Share This” widget, or interactive mini-programs that run on its site. Publicly visible personal information is possible, as Turnitin reserves the right to reproduce, transmit, display, disclose, and otherwise use user communications on the site or elsewhere for its business purposes. The company states that it retains the right to remove, at its discretion, communications that include any material deemed abusive, defamatory, obscene, or otherwise inappropriate. Turnitin's policy notes that it may (but is not obligated to) monitor areas of the site for user communications, such as chat rooms, bulletin boards, and other user forums.
Turnitin's policy claims that it complies with the relevant security standards of the US, EU and Switzerland. The program requires users to log into an account using a username and password for security purposes. Turnitin's policy states that if they transfer personal data to a third party, they will require that the third party agree to confidentiality requirements, and applicable legal requirements. The policy doesn't specifically address transit encryption, but says that data is stored in the EU or USA with robust physical, digital, and procedural safeguards in place to protect users' personal data, including the use of SSL encryption, redundant servers and data centers, and sophisticated perimeter security. Turnitin's policy also claims that its data breach notification policy is GDPR compliant.
Turnitin's policy notes that parental consent or the consent of a guardian is required for a minor to set up an account with Turnitin, and that COPPA does not apply to its product because COPPA’s requirements do not apply to sites that contract with schools to offer online programs for the benefit of the schools and their students, and collect personal data only for these purposes. Therefore, Turnitin states that its services are not required to get prior verifiable parental consent before collecting or maintaining personal data.
Turnitin explains that at any time, a user can access, update, rectify or erase any personal data by logging into the user's account and clicking “User Info” or contacting Customer Support. According to its policy, universities are free to inspect or audit Turnitin's services any time. Lastly, Turnitin's terms state they are obligated under FERPA to remain under the direct control of the education institution with respect to their use and maintenance of student data that is part of a student's education record.
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.
- Unclear whether this product collects geolocation data.
- 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 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.
- 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.
- Unclear whether this product supports social or federated login.
- 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.
- 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.
- 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.
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.
- Unclear whether 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.
- Unclear whether third-party transfers are 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.
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 cannot control how their data are displayed.
- Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
- User-created content is not 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.
- 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.
- Unclear whether this product displays behavioral or targeted advertising.
- 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 created and used for data enhancement, and/or targeted advertisements.
- Unclear whether this 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 cannot opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- 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.
- Unclear whether children's privacy is applicable.
- COPPA parental consent exceptions are indicated.
- 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.
- 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.