The Summit Learning Program's website describes its product as a personalized approach to teaching and learning inspired by the vision to equip every student to lead a fulfilled life. The services are designed to facilitate strong relationships between teachers and students through real­time data about progress towards goals, access to ongoing feedback, and access to a wide range of learning resources that enable students to build on what they learn from the teacher by self­ directing some of their learning, too. The terms state the service does not include features that make student personally identifiable. The terms state the service collects different personal information depending on whether the user is a teacher, school administrator, parent, or student and how the user uses the learning services. Summit Learning's terms state they employ administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing personal information. Lastly, the terms state that prior to a student accessing the service, the child’s teacher or school administrator must create the student’s account on the service.

Summit Learning can be accessed through its website. Policies used for this evaluation include: Privacy Policy, Security White Paper, User Agreement, Partner Terms of Service, the Data Privacy Addendum, and Program Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

The terms state the service does not include features that make student personally identifiable information publicly available. However, a student may choose to share coursework through certain non-Summit Learning features. The service also limits access to each student’s account to the student’s parents, legal guardians, teachers, school administrators, and other teachers in the student’s school (depending on the setting selected by the school’s administrator). Accordingly, the terms state the service does not permit any student’s account or the content and grades to be viewed or accessed by the general public. Summit Learning's policy notes that it contains third-party links to educational content available online which may allow students to view, and be exposed to, inappropriate content outside of the service.

Privacy

The terms state the service collects different personal information depending on whether the user is a teacher, school administrator, parent, or student and how the user uses the learning service. The terms state the service limits and uses the personal information they collect only for the educational purposes as directed by Partner Schools. The terms state the service does not seek to make money from students or their schools, teachers, or parents. In addition, the terms specify they will not sell or rent (or authorize Service Providers to sell or rent) any personal information they collect from students to any third party for any purpose – including prohibiting the creation of a profile of a student for any commercial purpose. Lastly, Summit learning's terms state they do not use personally-identifiable information to serve behaviorally targeted advertising to students or their families. They do not sell or share personal information.

Security

Summit Learning's terms state they employ administrative, physical, and technical safeguards designed to protect student data from unauthorized access, disclosure, and use or acquisition by an unauthorized person, including when transmitting and storing personal information. The terms state Summit Learning implements effective identification and authentication methods using multi-factor authentication with strong password complexity and a mobile security application based on two­-factor authentication. The terms also require service providers to implement reasonable security practices in accordance with the Data Privacy Addendum. The terms specify the service uses strong encryption technologies to securely transmit and store all sensitive data. These procedures include data ­in ­transit is secured with encrypted transportation protocols and when at rest sensitive data is encrypted. Lastly, the terms state that in the event that Summit Learning becomes aware of any actual or reasonably suspected unauthorized disclosure of, or access to, student data they will provide notice.

Compliance

Summit Learning's terms state they collect information from students only where a Partner School has entered into a signed Program Agreement with Summit Learning and accepted a Data Privacy Addendum. Licensed Users of the learning Services are also governed by the Summit Learning Platform User Agreement. The terms state that prior to a student accessing the service, the child’s teacher or school administrator must create the student’s account on the service. When the school administrator or teacher registers its students for accounts, Summit Learning relies on consent obtained from Partner Schools acting as an agent of the student’s parent or legal guardian. In addition, the terms state that parents, legal guardians, and students may at any time make a request to access, review, correct, or delete their personal information by contacting the appropriate official at the student’s school or school district. If the school determines that the request should be implemented, the school may either make the change themselves or submit the request to Summit Learning.

Furthermore, the terms state that Summit Learning depends on Partner Schools to ensure they are complying with FERPA provisions regarding the disclosure of any student information that is shared with Summit Learning and to any school officials with a legitimate educational interest. In addition, the terms note that the service complies with COPPA provisions for children's privacy by applying the same policy provisions to adults and children's privacy.