This is an example of a full privacy evaluation that transparently answers all of our full evaluation questions with better responses to illustrate the best privacy practices a company's policies should include if the product is collecting personal information from children and education records or student data from students in K-12 schools or districts.
Products that receive a high overall score are not necessarily problem-free, because they can receive either a "pass" or "warning" rating depending on how they answer the most important rating criteria questions. Similarly, products with a low overall score are not necessarily unsafe, because they can receive either a "pass" or "warning" rating.
Each privacy evaluation contains concern categories (below) that are organized by the most important and easy-to-understand privacy practices to quickly evaluate how an application or service compares to similar products. Each privacy evaluation concern consists of ten evaluation questions to provide a comprehensive analysis of the most important strengths and weaknesses of a product. A green check mark indicates a product's policies disclose that they engage in a better privacy practice, and an yellow alert icon indicates that the particular practice is risky or unclear and that users should investigate further prior to 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||90|
|Data Sharing: Protecting data from third parties||100||100|
|Data Security: Protecting against unauthorized access||100||100|
|Data Rights: Controlling rights to data||100||100|
|Data Sold: Preventing sale of data||100||100|
|Data Safety: Promoting responsible use||100||100|
|Ads & Tracking: Prohibiting the exploitation of users' decision making process||100||100|
|Parental Consent: Protecting children’s personal information||100||95|
|School Purpose: Following student data privacy laws||100||94|
|Individual Control: Controlling data use||NA||100|
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||96|
|Children's Online Privacy Protection Act (COPPA)||98||98|
|Family Educational Rights and Privacy Act (FERPA)||94||95|
|Student Online Personal Information Protection Act (SOPIPA)||100||97|
|General Data Protection Regulation (GDPR)||97||98|
1.1: Policy Version
- Privacy policies do indicate a version or effective date.
- Privacy policies 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 not effective immediately and continued use of the product requires additional 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.
- 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 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.
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
- Specific types of personal information are 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 not shared for analytics.
- Data are not 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 not obtained from third parties.
3.6: Third-Party Links
- Links to third-party external websites are age-appropriate.
3.7: Third-Party Data Access
- Third parties are not authorized to access a user's information.
3.8: Third-Party Data Collection
- Personal information of users is not 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
- Links to privacy policies of third-party companies are available.
3.13: Third-Party Data Combination
- Company will not combine data with additional data from third-party sources.
- Data shared with third parties cannot be combined with other data.
3.14: Third-Party Authentication
- Third-party login is not supported.
- Personal information from third-party login providers is not collected.
- Personal Information is not 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.
- 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
- 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 cannot 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.
- 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 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.
- A user can assign an authorized account manager or legacy contact.
7: Data Transfer
7.1: Data Handling
- User information cannot be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Notice is not provided to users if the company assigns its rights or delegates its duties to another company.
- Users are notified if their information is transferred to a third party.
7.2: Transfer Request
- 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.
8.1: User Identity
- A user's identity is not 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
- 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
- Notice is provided 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 cannot interact with untrusted users, including strangers and/or adults.
- Profile information must be not 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.
- User-created content is filtered for personal information before being made publicly visible.
- Social interactions between users are moderated.
- Social interactions of users are logged.
9.4: Report Content
- 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.
10.1: Vendor Communications
- A user can receive service- or administrative-related communications from the company.
10.2: Traditional Advertising
- Traditional or contextual advertisements are not 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
- Ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- The company cannot send marketing messages.
- The company does not provide promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Company does respond 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
- 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.
- Parental consent is limited 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.
- Parental consent obligations are not transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies is indicated.
- A user is not required to waive the right to a jury trial, or settle any disputes by arbitration.
- A user is required to waive the right to join a class action lawsuit.
- A company will not disclose personal information to law enforcement.
- 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.