Common Sense Privacy Program

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Standard Privacy Report for e-hallpass

Last updated
Applications and services with a Warning rating do not meet our recommendations for privacy and security practices. Applications and services with a Warning rating have issues narrowly focused around data use related to creating profiles that are not associated with any educational purpose, selling data, and/or using data to target advertisements.

56%

Warning

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Overview

e-hallpass allows teachers and administrators to provide hallway pass permissions to students on their devices and track their activity in a school's hallways. The terms of e-hallpass disclose user data can be accessible from within the software to anyone they are instructed to give access to via user credentials of specified administrative types including teachers, staff, and other administrators. In addition, when e-hallpass is instructed to create these login credentials, then they can be used to see student information from the relevant system including information such as student schedules, attendance, hall pass usage, or other items.

E-hallpass' terms state they collect personal information such as first and last names, user email addresses, user graduation years, and other information collected automatically when users visit the service. However, the terms do not disclose whether e-hallpass sells personal data to third parties or displays targeted advertising to users on the service. In addition, e-hallpass' terms state they take reasonable steps to protect the confidentiality and security of personal information collected from users of the service. Lastly, the terms of e-hallpass state there are processes in place for parents, educators, and administrators to access, modify, or delete personal information of students. The terms also require schools and districts to provide parental notification and consent mechanisms for students, teachers, and staff.

e-hallpass can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms of Use used for this evaluation can be found on e-hallpass’ website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

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 Assessment5637

Concerns

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 information2520
Data Sharing: Protecting data from third parties10070
Data Security: Protecting against unauthorized access8360
Data Rights: Controlling data use7570
Data Sold: Preventing sale of data2525
Data Safety: Promoting responsible use2535
Ads & Tracking: Prohibiting the exploitation of users' decision making process00
Parental Consent: Protecting children’s personal information6730
School Purpose: Following student data privacy laws10040

Statutes

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)5856
Children's Online Privacy Protection Act (COPPA)4337
Family Educational Rights and Privacy Act (FERPA)7238
Student Online Personal Information Protection Act (SOPIPA)5041
General Data Protection Regulation (GDPR)6844

Privacy Policy Details

1: Transparency

1.1: Policy Version
  • Privacy policies do indicate a version or effective date.
  • Privacy policies do not indicate a changelog 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: Policy Contact
  • Users cannot contact the vendor about any privacy policy questions, complaints, or material changes to the policies.
1.6: Policy Principles
  • Privacy policies do indicate any privacy principles, layered notices, or a table of contents.
1.7: Policy Language
  • Privacy policies are not available in multiple languages.
1.8: Intended Use
  • Unclear whether intended for children under 13.
  • Unclear whether intended for teens.
  • Unclear whether intended for adults over 18.
  • Unclear whether 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.
  • Unclear whether this product collects geolocation data.
  • 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.
  • Unclear whether free or reduced lunch status is collected.
2.2: Data Source
  • Personal information or education records are collected from preK-12 students.
  • Unclear whether this product collects personal information online from children under 13 years of age.
2.3: Data Exclusion
  • Unclear whether specific types of personal information are not collected.
  • Unclear whether specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
  • Unclear whether the 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.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether data are shared for third-party advertising and/or 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
  • Unclear whether data are sold or rented to third parties.
3.5: Third-Party Data Acquisition
  • Unclear whether personal information from users is acquired from third parties.
3.6: Third-Party Links
  • Unclear whether links to third-party external websites are 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
  • Unclear whether 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 if found to be misused.
3.10: Third-Party Service Providers
  • Data are shared with third-party service providers.
  • Unclear whether the roles of third-party service providers are indicated.
3.11: Third-Party Affiliates
  • Unclear whether the categories of third parties that receive personal information 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 data can be combined with data from third-party sources.
  • Unclear whether data shared with third parties can be combined by third parties for their own purposes.
3.14: Third-Party Authentication
  • Social or federated login is supported.
  • Unclear whether personal information from social or federated login providers is collected.
  • Unclear whether personal Information is shared with social or federated login providers.
3.15: De-identified or Anonymized Data
  • Unclear whether user information is shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification 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 deidentified information.

4: Respect for Context

4.1: Data Use
  • Use of information is limited to the purpose for which it was collected.
  • The purpose for which data atr collected is indicated.
4.2: Data Combination
  • Unclear whether this product treats combined information 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
  • Unclear whether accounts may be terminated if users engage in any prohibited activities.

5: Individual Control

5.1: User Content
  • Unclear whether 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
  • Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
5.4: Data Settings
  • Unclear whether users can control 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 for commercial purposes.
  • Unclear whether notice is provided in the event the vendor receives a government or legal request for a user’s information.
5.6: Intellectual Property
  • Users retain ownership of their data.
  • Unclear whether 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.
  • Unclear whether notice is provided to users when their content is removed or disabled because of an alleged copyright violation.

6: Access and Accuracy

6.1: Data Access
  • Processes to access and review user data are available.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Processes to review data are available for the school, parents, or students.
6.2: Data Integrity
  • Unclear whether the vendor maintains the accuracy of data they collect.
6.3: Data Correction
  • Processes to modify inaccurate data are available.
  • Processes for the school, parents, or students to modify data are available.
  • Unclear whether the time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
  • A data-retention policy is available.
  • Unclear whether the retention time period of a user's data can be changed upon a valid inspection request.
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 the school, parents, or students to delete data are available.
  • Unclear whether the time period for the vendor to delete data is indicated.
6.6: Data Portability
  • Unclear whether this product provides users the ability to download their data.
  • 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.
  • Notice is not provided to users if the vendor 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.
  • Parental controls or managed accounts are available.
  • Unclear whether two-factor account protection is available.
8.3: Third-Party Security
  • Unclear whether third-party contractual security protections are required.
8.4: Data Confidentiality
  • Industry best 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 at rest are encrypted.
  • Personal information of users is not stored with a third party.
8.7: Data Breach
  • Unclear whether this product provides notice in the event of a data breach.
8.8: Data Oversight
  • Unclear whether this product performs data-privacy and security-compliance audits.

9: Responsible Use

9.1: Social Interactions
  • Users can interact with trusted users and/or students.
  • Users cannot interact with untrusted users, including strangers and/or adults.
  • Profile information is shared for social interactions.
9.2: Data Visibility
  • Unclear whether this product displays personal information publicly.
  • Users can control how their data are displayed.
9.3: Monitor and Review
  • Unclear whether user-created content is reviewed, screened, or monitored by the vendor.
  • 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.
  • Unclear whether users can report abuse or cyberbullying.
9.5: Internet Safety
  • Unclear whether the vendor provides links to tools or processes that support safe and appropriate social interactions.

10: Advertising

10.1: Vendor Communications
  • Unclear whether a user can receive service- or administrative-related communications from the vendor.
10.2: Traditional Advertising
  • Unclear whether this product displays traditional or contextual advertisements.
10.3: Behavioral Advertising
  • Unclear whether this product displays behavioral or targeted advertising.
10.4: Ad Tracking
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
  • Unclear whether this product creates and uses data profiles for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
  • Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
  • Unclear whether this vendor can send marketing messages.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
10.7: Unsubscribe
  • 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.
10.8: Do Not Track
  • Unclear whether this product responds to Do Not Track or other opt-out mechanisms.
  • Unclear whether the vendor provides a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is applicable.
  • Unclear whether this product restricts account creation for users under 13 years of age.
  • Unclear whether this product restricts in-app purchases for users under 13 years of age.
  • Unclear whether the vendor participates in an FTC-approved COPPA safe harbor program.
11.2: Students in K–12
  • Product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
  • Parental consent is required.
  • 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.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Parental consent notice and method for submission are provided.
  • Unclear whether the vendor can use collected information to support the “internal operations” of the product.
  • Unclear whether this product indicates COPPA parental consent exceptions.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.
  • Parental consent obligations are transferred to the school or district.
11.4: Legal Requirements
  • The legal jurisdiction that applies to the laws governing any dispute 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.
  • Unclear whether a vendor will disclose personal information to law enforcement.
11.5: Certification
  • The vendor has signed a privacy pledge or received a privacy certification.
11.6: International Laws
  • Unclear whether a user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
  • Unclear whether the vendor has indicated it is a Data Controller or Data Processor.
Return to Privacy Evaluation
Common Sense Media provides this standard privacy report for use by the general public for research and education purposes only. The accuracy, completeness, or adequacy of the content provided or evaluation results derived from a product’s policies is not warranted or guaranteed.