Privacy Evaluation for VoiceThread
The terms of VoiceThread state they support different visibility settings. However, the terms are not specific on the mechanics of the settings, but schools and teachers are encouraged to review the settings to ensure that visibility of data to others is set in a way that addresses community norms. In addition, the policies do not contain details on how social interactions could be monitored for inappropriate content, or how a user could report unwanted harassment. While these features may exist within the application, the terms do not provide details on how to access them.
The terms of VoiceThread state they collect a student's name, email address, photos, videos, audio recordings, online activity, persistent identifiers, and information that is linked or linkable to a student. VoiceThread shares non-personally-identifiable information (such as anonymous User usage data, referring pages, exit pages, URLs, platform types, number of clicks, etc.) with third parties to assist them in understanding the usage patterns for certain content, services, and functionality on the Website. Also, VoiceThread may provide personally identifiable information to employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on its behalf. Lastly, the terms state VoiceThread will never sell personal information or use student data for behavioral advertising, tracking, or marketing purposes.
The terms state educators and administrators have access to a broad suite of tools to control the methods by which students use the Service, enabling policies concerning student publishing and student sharing to made by educators and administrators at each school or district. VoiceThread's terms state they work hard to protect their community of users, and they maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information.
The terms state VoiceThread will continually develop and implement features to keep users' personal information safe - for example, when they enter any information anywhere on the Service, VoiceThread encrypts the transmission of that information using secure socket layer technology (SSL) by default. In addition the terms specify they ensure passwords are stored and transferred securely using encryption and salted hashing and provide notification in the event of a data breach.
The terms of VoiceThread state users under 18 years of age cannot register for the Service, but rather a grade-school educator or administrator must register students. The terms specify that student education records are created and protected under FERPA, and teachers or administrators can access, review, modify, or delete student data. Teachers should be aware they are responsible for obtaining verifiable parental consent for use of the Service by students.
Ed.voicethread.com is the part of the Service dedicated for use with grade-school students and educators. It has policies in place to ensure that students have as safe and nurturing a learning environment as possible. The terms state these policies are unique to Ed.VoiceThread, and taken as a whole, provide the transparency and accountability that are the underpinning of all safe and nurturing grade-school learning communities. Because the educational version of VoiceThread is often purchased at the district, agency, or state level, it is possible that an additional data use agreement is in place that would address these compliance issues. Teachers should ask for confirmation of any additional data use agreements.
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 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.
- Unclear whether 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.
- 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.
- 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?
- Users can create or upload content.
- Users retain ownership of their data.
- Unclear whether this product provides processes to access and review user data.
- 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.
- 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.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not shared for social interactions.
- Personal information is displayed publicly.
- Users can control how their data are displayed.
- User-created content is not reviewed, screened, or monitored by the vendor.
- Unclear whether user-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are not 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.
- Unclear whether this vendor can 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.
- Vendor does not 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.
- Product does create 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.