Apple School Manager is a free web-based service that has everything technology managers need to deploy iPad and Mac in schools. Apple School Manager lets you buy content, configure automatic device enrollment in your mobile device management (MDM) solution, create accounts for your students and staff, set up class rosters for the Schoolwork and Classroom apps, enable progress recording in Schoolwork, and manage apps and books for teaching and learning.
The Schoolwork app allows teachers and students to share instructional materials, review student progress, and provide instant feedback, empowering teachers to personalize instruction. When a school enables progress reporting for Schoolwork in Apple School Manager, student progress data is shared only for activities a teacher specifically assigns, and only when students are using their Managed Apple ID on their device. Parents can view their child’s progress information by opening Schoolwork or visiting Settings on their child’s iPad. The Classroom app enables teachers to manage student iPad devices in the classroom and helps them guide students through a lesson. Classroom manages devices only while students are physically present during class time. It doesn’t store data or allow control after the class ends.
Additionally, other relevant policies used for this evaluation include:
- Welcome To Apple School Manager
- Apple in Education Data and Privacy Overview for Schools
- Privacy Overview for Parents
- Family Privacy Disclosure for Children
- About privacy and security for Apple products in education
- iCloud security overview
- Your California Privacy Disclosures
- Software License Agreement For macOS Mojave
- iOS Software License Agreement
- iTunes Store Terms and Conditions
- Apple tvOS Software License Agreement
The terms state in order to ensure that schools providing devices to students are only enabling use for the purposes of education, Apple disabled certain features and functions of Managed Apple IDs. In addition, FaceTime and iMessage are also disabled by default, but can be enabled by an administrator. The terms also specify that resources are available to help students become good digital citizens and to guide schools and parents. Parents and their students should review their school’s technology policy regarding acceptable use, email, storing and charging devices, accessing content and apps with Apple School Manager.
Apple's terms state they believe privacy is a fundamental human right, and build privacy and security into all their products from the ground up, including their apps and services for education. When schools set up accounts, devices, and apps for their students in Apple School Manager, the terms state they can be sure that Apple will use any data for educational purposes only. The terms specify a school can enable student progress recording with Schoolwork in Apple School Manager, so that app developers can privately and securely share student progress with teachers on activities, like reading a chapter in a book, completing a set of math equations, or taking a quiz, assigned in school managed environments. The terms state this data allows teachers as well as students to better understand learning progress on assigned activities, and enables teachers to provide extension activities or extra help based on student needs.
The terms state that Apple will never sell student information and will never share it with third parties to use for marketing, tracking, or advertising purposes. In addition, Apple's terms state they will never build profiles of students based on their online behavior, and they don’t collect, use, or disclose student information other than to provide relevant educational services. Moreover, Apple's terms state education apps, such as Classroom and Schoolwork, do not contain any ads. However, Apple's "Limit Ad Tracking" control is enabled for all Managed Apple IDs. This means that while students using Managed Apple IDs may see contextual ads while browsing Apple News or the App Store, advertising is never targeted using their information. Lastly, apps in the Kids Category of the App Store and apps that use ClassKit to report student progress in the Schoolwork app are prohibited from serving behavioral advertisements to students.
Apple's terms state that security and privacy are fundamental to the design of all Apple hardware, software, and services. Apple takes an integrated approach to ensure that every aspect of the user's experience has security and privacy built in. The terms state this approach considers the privacy and security of all users, including those within an education setting such as teachers, faculty, staff, and students. Apple's terms state they have created features and services that are designed specifically for education, including Apple School Manager, Managed Apple IDs, and Shared iPad. These capabilities are built with the same integrated approach and with additional consideration for the specific security and privacy needs of students and institutions.
Additionally, the terms state iCloud is built with industry-standard security practices and employs strict policies to protect data. iCloud secures user data by encrypting it when it’s sent over the Internet, storing it in an encrypted format when kept on the server, and using secure tokens for authentication. The terms specify this means that student data is protected from unauthorized access both while it is being transmitted to devices and when it is stored in iCloud. iCloud uses a minimum of 128-bit AES encryption, and never provides encryption keys to any third parties. Lastly, Apple retains the encryption keys in our own data centers and iCloud also stores student passwords and credentials in such a way that Apple cannot read or access them.
Apple's terms state they understand the importance of taking extra precautions to protect the privacy and safety of children using Apple products and services. Children under the age of 13 are not permitted to create their own Apple IDs, unless their parent provides verifiable consent, or their Apple ID is part of the child account creation process in Family Sharing, or they have obtained a Managed Apple ID account through their school. The terms state that in order to provide consent, a parent must review the Apple ID and Family Sharing Disclosure, Use and Disclosure of Your Child’s Information, and the iTunes Store Terms and Conditions, before they can begin the Apple ID account creation process for their child.
Additionally, the Apple School Manager Agreement lays out the terms for collection and storage of student information by Apple, including data privacy provisions specific to education customers. According to the agreement, Apple acts as a data processor with respect to the data that is created in Apple School Manager and Schoolwork. The terms specify that schools can use Apple features and services for education in compliance with their obligations under COPPA and FERPA.
Lastly, Apple's terms state it’s important to be aware that third-party apps may be collecting data about the student. It is the school or district’s responsibility to ensure compliance with all applicable laws when using Apple in Education with third-party apps. The terms recommend schools or districts should review the terms, policies, and practices of third-party apps to understand what data they may collect from students, how such data is being used, and whether parental consent is required before use.
Every privacy rating includes an overall score. A higher score (up to 100%) means the product provides more transparent privacy policies with better practices to protect user data. The score is best used is as an indicator of how much additional work a person will need to do to make an informed decision about a product.
|Basic Score||Full Score|
The privacy evaluation process summarizes the policies of an application or service into concern categories based on a subset of evaluation questions that can be used to quickly identify particular practices of a vendor’s policies. These concerns are composed of evaluation questions that can be used to calculate scores relative to that concern.
|Concern||Basic Score||Full Score|
|Data Collection: Protecting personal information||83||65|
|Data Sharing: Protecting data from third parties||100||90|
|Data Security: Protecting against unauthorized access||67||75|
|Data Rights: Controlling rights to data||88||95|
|Data Sold: Preventing sale of data||75||50|
|Data Safety: Promoting responsible use||83||50|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||86||70|
|Parental Consent: Protecting children’s personal information||100||75|
|School Purpose: Following student data privacy laws||0||0|
|Individual Control: Controlling data use||NA||60|
Each statute or regulation is associated with one or more evaluation questions. As such, we can calculate scores for each statute or regulation using only those questions associated with the statute or regulation. Each specific statute or regulation's score serves as an indirect proxy indicating the likelihood of the application or service satisfying all of its compliance obligations.
|Statute||Basic Score||Full Score|
|California Online Privacy Protection Act (CalOPPA)||93||85|
|Children's Online Privacy Protection Act (COPPA)||88||77|
|Family Educational Rights and Privacy Act (FERPA)||81||62|
|Student Online Personal Information Protection Act (SOPIPA)||83||64|
|General Data Protection Regulation (GDPR)||90||74|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies do not indicate a change log or past policy version is available.
1.2: Policy Notice
- Users are notified if there are any material changes to the policies.
- Privacy policies indicate the method used to notify a user when policies are updated.
1.3: Policy Changes
- Users are notified prior to any material changes to the policies.
- Changes to the policies are effective immediately and continued use of the product indicates consent.
1.4: Policy Coverage
- Privacy policies indicate the products that are covered by the policies.
1.5: Privacy Contact
1.6: Policy Principles
- Privacy policies do indicate privacy principles, layered notices, or a table of contents.
1.7: Policy Language
- Privacy policies are available in multiple languages.
1.8: Intended Use
- Intended for children under 13.
- Intended for teens.
- Intended for adults over 18.
- Intended for parents or guardians.
- Unclear whether intended for students.
- Unclear whether intended for teachers.
2: Focused Collection
2.1: Data Collection
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Geolocation data are not collected.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Unclear whether this product collects sensitive data.
- Data is automatically collected.
2.2: Data Source
- Unclear whether personal information or education records are collected from preK-12 students.
- Personal information from children under 13 years of age is collected.
2.3: Data Excluded
- Unclear whether specific types of personal information excluded from collection.
2.4: Data Limitation
- Collection or use of data is limited to product requirements.
3: Data Sharing
3.1: Data Shared With Third Parties
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
3.2: Data Use by Third Parties
- The purpose for sharing a user's personal information with third parties is indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Personal information is not shared for third-party marketing.
3.3: Data Not Shared With Third Parties
- Specific categories of information are not shared with third parties.
3.4: Data Sold to Third Parties
- Personal information is not sold or rented to third parties.
3.5: Third-Party Data Acquisition
- Personal information about users is obtained from third parties.
3.6: Third-Party Links
- Links to third-party external websites are not age-appropriate.
3.7: Third-Party Data Access
- Third parties are authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is collected by a third party.
3.9: Third-Party Data Misuse
- Unclear whether personal information can be deleted from a third party.
3.10: Third-Party Service Providers
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
- The categories of third parties that receive data are indicated.
3.12: Third-Party Policies
- Links to privacy policies of third-party companies are not available.
3.13: Third-Party Data Combination
- Company may combine data with additional data from third-party sources.
- Unclear whether data shared with third parties can be combined with other data.
3.14: Third-Party Authentication
- Third-party login is not supported.
- Unclear whether personal information from third-party login providers is collected.
- Unclear whether personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- User information that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
3.16: Third-Party Contractual Obligations
- Contractual limits are placed on third-party data use.
- Contractual limits prohibit third parties from reidentifying or de-identified information.
4: Respect for Context
4.1: Data Use
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
4.2: Data Combination
- Combined information is treated as personally identifiable information (PII).
4.3: Data Notice
- Unclear whether notice is provided if the context in which data are collected changes.
4.4: Data Changes
- Unclear whether consent is obtained if the practices in which data are collected change.
4.5: Policy Enforcement
- Accounts may be terminated if users engage in any prohibited activities.
5: Individual Control
5.1: User Content
- Users can create or upload content.
5.2: User Consent
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- A grievance or remedy mechanism is not available for users to file a complaint.
5.4: Data Settings
- Users can control the use of their information through privacy settings.
5.5: Data Disclosure
- Users can opt out from the disclosure or sale of their data to a third party.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Notice is provided in the event the company receives a government or legal request for a user's information.
5.6: Intellectual Property
- Users retain ownership of their data.
- A copyright license is claimed to data or content collected from a user.
- Unclear whether any copyright license to a user's data is limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- Methods are available to restrict who has access to data.
- Processes to review student data are available for the school, parents, or students.
6.2: Data Integrity
- The company attempts to maintain the accuracy of data they collect.
6.3: Data Correction
- Processes to modify data are available for authorized users.
- Processes for the school, parents, or students to modify inaccurate student information are available.
- The time period for the company to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- Exceptions to the data retention policy exist.
6.5: Data Deletion
- Data are deleted when no longer necessary.
- A user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Processes for authorized users to delete data are available.
- The time period for the company to delete data is indicated.
6.6: Data Portability
- Processes to download user data are available.
- Unclear whether a user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Unclear whether notice is provided to users if the company assigns its rights or delegates its duties to another company.
- Unclear whether users are notified if their information is transferred to a third party.
7.2: Transfer Request
- Unclear whether user information can be deleted prior to its transfer to a third party.
7.3: Onward Contractual Obligations
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
8.1: User Identity
- A user's identity is verified with additional personal information.
8.2: User Account
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
8.3: Third-Party Security
- Unclear whether third-parties with access to information are required to provide the same security protections as the company.
8.4: Data Confidentiality
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
8.5: Data Transmission
- All data in transit are encrypted.
8.6: Data Storage
- All data are stored in an encrypted format.
- The company is clear what jurisdiction a user's personal information is subject to.
8.7: Data Breach
- Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
- Data-privacy and/or security-compliance audits are performed.
9: Responsible Use
9.1: Social Interactions
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
9.2: Data Visibility
- Personal information can be not displayed publicly.
- Users can control how their data are displayed to others.
9.3: Monitor and Review
- 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.
9.4: Report Content
- Users can filter or block inappropriate content.
- Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
- The company provides links to resources that support safe and appropriate social interactions.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are displayed.
10.3: Behavioral Advertising
- Personalised advertising is not displayed.
10.4: Ad Tracking
- 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.
10.5: Filtered Advertising
- Unclear whether ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- 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.
- Unclear whether users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Unclear whether this product responds to "Do Not Track" or other opt-out mechanisms.
- The company does provide a method for users to opt-out from third-party tracking.
11.1: Children Under 13
- Company does 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.
- Account creation is restricted or prohibited for users under 13 years of age.
11.2: Students in K–12
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
11.3: Parental Consent
- Parental consent is required before personal information is collected or disclosed.
- 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.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- Unclear whether a user is required to waive the right to a jury trial, or settle any disputes by arbitration.
- Unclear whether a user is required to waive the right to join a class action lawsuit.
- A company will disclose personal information to law enforcement.
- Unclear whether the company has signed a privacy pledge or received a privacy certification.
11.6: International Laws
- A user's data are subject to International data transfer or jurisdiction laws.
- The company has indicated it is a Data Controller or Data Processor.