Engrade by McGraw-Hill Education is a learning management system (LMS) and assessment engine. Engrade empowers educators and unlocks student achievement. Engrade McGraw-Hill Education's policies are not transparent about whether users can interact with trusted or untrusted users. Engrade McGraw-Hill Education's terms state they will not sell users' PII to other organizations or use information from educational records for marketing purposes. In addition, the policies state that Engrade McGraw-Hill Education will establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of users' personally identifiable information. The terms of Engrade McGraw-Hill Education's policies state that they use user information to provide the digital learning solution on behalf of a school in order to meet its contractual obligations with the school or district.

Please Note: The terms state they do not apply to any data submitted to or collected by Engrade - McGraw-Hill Education in connection with the educational or instructional use of their products and services by customers, students, and/or educational institutions. If a user registers to use the services on behalf of an educational institution, they will be required to agree to additional terms and conditions in connection with the registration process that are not used in this evaluation process.

Engrade by McGraw-Hill Education can be accessed through its website. The Privacy Policy and Terms of Use used for this evaluation can be found on Engrade’s website. Additionally, other policies used for this evaluation include: Terms of Service. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.


Engrade McGraw-Hill Education's policies are not transparent about whether users can interact with trusted or untrusted users. In addition, the terms are unclear whether information may be shared or revealed by a user in order to participate in social interactions or that a user's personal information can be displayed publicly in any way. The terms also state Engrade McGraw-Hill Education reserves the right, but not the obligation to remove, to not transmit any user content that they deem to be in violation of their terms. However, Engrade McGraw-Hill Education does not and cannot review all user content or service uploads from users, and their policies state they are not responsible for such content. Engrade McGraw-Hill Education may report communications or materials provided by users to their educational institution if they believe the communications or content are in violation of their terms. Lastly, Engrade McGraw-Hill Education provides external links to resources to learn more about safety.


Engrade McGraw-Hill Education's policies state they are a global organization and follow privacy laws and regulations that are applicable to their company and services in the areas where they do business. Their policies state Engrade McGraw-Hill Education is committed to protecting the privacy of users' personal information, and they regularly review and update their privacy practices as required. In addition, they have recently updated their Privacy Center and Terms of Use to be more transparent about how they collect and use user information, and to provide users with more control over that information.

The policies state Engrade McGraw-Hill Education collects Personally identifiable information, such as contact information and education details, in order to provide users with the product and/or service they requested. When a user registers, or is registered within one of the offered digital learning solutions, Engrade McGraw-Hill Education collects their name, school, instructor, class, and login information. However, the terms also specify Engrade McGraw-Hill Education does not collect, use, or disclose PII that is not reasonably related to a legitimate business purpose necessary to serve its users. When a user visits or make transactions on Engrade McGraw-Hill Education's web sites, they automatically collect certain information from users through the use of cookies, web beacons or other tracking mechanisms. This includes information about users' experience such as their IP address, operating systems, pages viewed, and time spent.

In addition, Engrade McGraw-Hill Education's terms state they purchase and rent marketing lists from various providers including event management companies and education non-profits. Engrade McGraw-Hill Education's policies state they may share user information with third parties to provide users with marketing information. However, McGraw-Hill Education's terms state they will not share users' PII with third parties for them to market to users on their own behalf. McGraw-Hill Education's terms also specify they will not market to students using the information from their educational records, which are records directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution.

Engrade McGraw-Hill Education's terms state they will not sell users' PII to other organizations or use information from educational records for marketing purposes. The terms of Engrade McGraw-Hill Education state they may use users' PII to provide them with materials that they believe are of interest to users. In addition, Engrade McGraw-Hill Education's policy states they may display advertisements to users in connection with user content, and may use user content to advertise and promote Engrade McGraw-Hill Education's products and services. This allows Engrade McGraw-Hill Education to collect information about customer usage and online behavior to tailor marketing to areas that they believe may be more appropriate for the user. Lastly, Engrade McGraw-Hill Education's terms state they allow third parties to collect information automatically from users across websites and over time through the use of their own cookies, web beacons, and tracking mechanisms.


Engrade McGraw-Hill Education's policies state they may collect users' name, initials, and contact information when they create an account. In addition, the policies state Engrade McGraw-Hill Education will establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of users' Personally Identifiable Information. The terms specify Engrade McGraw-Hill Education owns, controls, and operates its services from their offices in the United States. However, the terms do not state whether personal information is encrypted while in transit or while in storage and there is no information provided about notification to users in the event of a data breach.


The terms of Engrade McGraw-Hill Education state they use user information to provide the digital learning solution on behalf of a school in order to meet its contractual obligations with the school or district. In addition, users will also be subject to any additional terms of use, agreements, guidelines or rules provided by Engrade McGraw-Hill Education applicable to the services provided. Engrade McGraw-Hill Education's products are intended for use by parents, students, and teachers. The terms further specify if a user is an educator, parent, or student, Engrade McGraw-Hill Education is a service provider to their school or organization. The service providers parents, students, and teachers with the ability to access, modify, and delete personal information. In addition, the terms state Engrade McGraw-Hill Education will retain users' data for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under McGraw-Hill Education's data retention policies.

Further, the terms specify that due to the increasing focus on the security and protection of personal and student information, Engrade McGraw-Hill Education's privacy practices comply with such federal regulations as COPPA and FERPA. Engrade McGraw-Hill Education acknowledges that it will be considered a "School Official" (as that term is used in FERPA) and agrees that it will comply with the requirements in FERPA concerning the confidentiality and release of Personally Identifiable Information.

Lastly, McGraw-Hill Education has taken a leadership role with Future of Privacy Forum (FPF) and the Software and Information Industry Association (SIIA) in setting the agenda for self-regulatory goals for student privacy in the industry. The terms further specify they have an internal Privacy Council comprised of senior leaders throughout our company that provides the tone at the top to perpetuate best practices across our business.

Overall Score

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 ScoreFull Score
Comprehensive Assessment6260


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.

ConcernBasic ScoreFull Score
Data Collection: Protecting personal information8360
Data Sharing: Protecting data from third parties10090
Data Security: Protecting against unauthorized access040
Data Rights: Controlling rights to data8895
Data Sold: Preventing sale of data7550
Data Safety: Promoting responsible use015
Ads & Tracking: Prohibiting the exploitation of users' decision making process4355
Parental Consent: Protecting children’s personal information10055
School Purpose: Following student data privacy laws10088
Individual Control: Controlling data useNA70


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.

StatuteBasic ScoreFull Score
California Online Privacy Protection Act (CalOPPA)8167
Children's Online Privacy Protection Act (COPPA)6260
Family Educational Rights and Privacy Act (FERPA)8871
Student Online Personal Information Protection Act (SOPIPA)6769
General Data Protection Regulation (GDPR)7074

Privacy Policy Details

1: Transparency

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
  • Users can contact the company about any privacy policy questions, complaints, or material changes to the policies.
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.
  • Intended for students.
  • 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 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
  • 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.
  • Specific types of collected information are excluded from the privacy policy.
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 shared for third-party marketing.
3.3: Data Not Shared With Third Parties
  • Unclear whether there are specific categories of information that 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
  • Unclear whether 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
  • Unclear whether 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
  • 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
  • Unclear whether links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
  • Unclear whether 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 supported.
  • Personal information from third-party login providers is collected.
  • Personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
  • 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.
3.16: Third-Party Contractual Obligations
  • Contractual limits are placed on third-party data use.
  • Unclear whether 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
  • Unclear whether this product treats combined information as personally identifiable information (PII).
4.3: Data Notice
  • Notice is provided if the context in which data are collected changes.
4.4: Data Changes
  • 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 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.
  • Users can 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.
5.6: Intellectual Property
  • Users retain ownership of their data.
  • A copyright license is claimed to data or content collected from a user.
  • Any copyright license to a user's data is not 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.
  • Unclear whether 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.
  • Unclear whether 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.
  • 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
  • Third-party transfer is contractually required to use the same privacy practices.

8: Security

8.1: User Identity
  • Unclear whether a user's identity is verified with additional personal information.
8.2: User Account
  • Account creation is required.
  • Managed accounts are available.
  • Unclear whether 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
  • Unclear whether this product encrypts all data in transit.
8.6: Data Storage
  • Unclear whether 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
  • Unclear whether this product supports interactions between trusted users.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information must be shared for social interactions.
9.2: Data Visibility
  • Unclear whether personal information can be displayed publicly.
  • Unclear whether this product allows users to control how their data are displayed to others.
9.3: Monitor and Review
  • User-created content is not 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
  • Unclear whether users can filter or block inappropriate content.
  • Users can report abuse or cyberbullying.
9.5: Internet Safety
  • The company provides links to resources that support safe and appropriate social interactions.

10: Advertising

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 displayed.
10.4: Ad Tracking
  • Data are collected by third-parties for their own purposes.
  • User's information is used to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles 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.
  • The company does provide promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • Users can opt out of contextual, or personalised advertising.
  • 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.
  • Unclear whether the company provides a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Unclear whether company has 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.
  • Unclear whether this product restricts or prohibits account creation for users under 13 years of age.
11.2: Students in K–12
  • 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.
  • Additional rights or protections may be provided with an additional school contract.
  • 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.
  • Parents can 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.
  • Unclear whether this product provides parental consent notice and method for submission.
  • Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
  • The legal jurisdiction that applies to the laws governing the policies is not indicated.
  • 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.
11.5: Certification
  • 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.