Overview
Edthena provides video tools designed to enhance professional development for teachers through classroom observation and online collaboration. The terms state that the service allows user submissions to be shared between users to facilitate feedback and training between teachers to improve learning outcomes. Edthena's terms state they collect Personally Identifiable Information from a teacher or school and may collect analytics data, or use third-party analytics tools, to help them measure traffic and usage trends for the Service. In addition, Edthena's terms state they have implemented commercially reasonable administrative, physical, and technical safeguards designed to secure Personal Information, including student data, from unauthorized access, disclosure and use. Lastly, Edthena's terms state that it complies with the Children’s Online Privacy Protection Act (COPPA) and Family Educational Rights and Privacy Act (FERPA).
Edthena can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Edthena’s website, and iOS App Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Edthena's terms state that they allow user submissions to be shared between users to facilitate feedback and training between teachers to improve learning outcomes. The terms state that the Edthena Service is a communication tool that permits and encourages data sharing and communication between users, and that a user may control which other users may access their submissions, and may invite and authorize non-users to access their submissions.
By default, every video in the system can only be seen by the user who uploaded the content. According to the policy, the only way to let others view a user's content is by sharing it to a group through the service. Group membership is controlled by a group admin and that person is clearly identified to the members of any group and is responsible for approving requests to join the group.
Privacy
The terms of Edthena state that they collect Personally Identifiable Information from a teacher or school and may collect analytics data, or use third-party analytics tools, to help them measure traffic and usage trends for the Service. The terms state that users, including teachers and teachers-in-training, may upload User Submissions that contain videos, images or personal information of K-12 students, teachers, or other non-users of the Service. Edthena's terms state they agree to treat student data and user submissions as confidential and not to share, use, or sell data to third parties for marketing or targeted advertising purposes. However, Edthena states that any personal information related to non-users that may be provided in user submissions is not strictly subject to its privacy policy.
In addition, Edthena's terms state they may use or share information from user content in an aggregated or anonymous form with third parties that does not personally identify any individual. The terms also state the company may share aggregated data with educational institutions to provide feedback to its users or to measure certain metrics over time. Edthena's terms specify they may use aggregate or anonymized data to study and improve their Service, user functionality, and product offerings. Although Edthena may permit third party advertising partners to collect information about a visitor's use of their services over time for the purpose of sending targeted advertisements, Edthena does not allow third party advertising networks to collect information about students or teachers who are logged into the service.
Security
Edthena's terms state they have implemented commercially reasonable administrative, physical, and technical safeguards designed to secure personal information, including student data, from unauthorized access, disclosure and use. Edthena's terms state they use a sophisticated library which looks for things like keyboard patterns, industry terms, and known passwords to help ensure a sufficiently strong phrase for each of its users.
Edthena's terms state they utilize 128-bit encryption to ensure that information is protected against unauthorized access and transmitted over a secure connection. In addition, the terms state that every time a user watches a video in Edthena, their browser is making a request to a content delivery network using a single-use URL. In the event that any information under Edthena's control is compromised as a result of a breach of security, they will take reasonable steps to investigate the situation and where appropriate, notify those users whose information may have been compromised.
Compliance
Edthena's terms state that it complies with the Children’s Online Privacy Protection Act (COPPA) and Family Educational Rights and Privacy Act (FERPA) where use or access to its service by anyone under 13 is strictly prohibited. In addition, Edthena's terms state they do not knowingly collect personal information through the service from a child under 13, unless a user has affirmed that they has obtained appropriate consent from the child’s school or teacher to post such information to the service. The terms note that a user should contact Edthena if they believe the service has inadvertently collected personal information from a child under 13 without proper consent so that they may delete the information as soon as possible.
Edthena's terms state they consider student data to be highly confidential, and if student data is collected through the Service, Edthena may access, collect and process student data as a school official with a legitimate educational interest under FERPA. A user agrees that when Edthena is acting as a school official, the educational institution or authorized user of that educational institution owns and controls all student data. Furthermore, Edthena users are solely responsible for assuring compliance with FERPA and COPPA for the collection of personal information of non-users, including K12 students that may be contained in the user submissions. If a user records video of their work in a classroom at a local K-12 school, the video may contain images of children, teachers, or other individuals who are not covered by the terms. The terms state that a parent, teacher, or school administrator can contact Edthena to request access to information relating to a student or minor who may appear in user submissions that has been posted on the Service.
Lastly, the terms state if a user provides content information collected from a student under 13, they are required to be the student’s school or teacher and have received consent from parents, or have the authority to provide consent on behalf of parents. The terms state that providing consent on behalf of the student allows Edthena to collect information from the students before providing user content of a child under 13 to the service. Edthena recommends that all schools and teachers provide appropriate disclosures to students and parents regarding their use of the services and that they provide a copy of the Privacy Policy to parents and guardians.
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 Score | Full Score | |
|---|---|---|
| Comprehensive Assessment | 80 | 66 |
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.
| Concern | Basic Score | Full Score |
|---|---|---|
| Data Collection: Protecting personal information | 50 | 40 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 33 | 50 |
| Data Rights: Controlling rights to data | 88 | 65 |
| Data Sold: Preventing sale of data | 75 | 80 |
| Data Safety: Promoting responsible use | 83 | 50 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 86 | 85 |
| Parental Consent: Protecting children’s personal information | 100 | 75 |
| School Purpose: Following student data privacy laws | 100 | 88 |
| Individual Control: Controlling data use | NA | 60 |
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.
| Statute | Basic Score | Full Score |
|---|---|---|
| California Online Privacy Protection Act (CalOPPA) | 94 | 74 |
| Children's Online Privacy Protection Act (COPPA) | 83 | 69 |
| Family Educational Rights and Privacy Act (FERPA) | 93 | 63 |
| Student Online Personal Information Protection Act (SOPIPA) | 95 | 74 |
| General Data Protection Regulation (GDPR) | 77 | 63 |
| The California Consumer Privacy Act (CCPA) | 75 | 66 |
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 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
- 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 not available in multiple languages.
1.8: Intended Use
- Not intended for children under 13.
- Not intended for teens.
- Intended for adults over 18.
- Not 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.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- 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
- 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.
- 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
- 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
- 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
- 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 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
- 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.
- Unclear whether 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 limited in scope or duration.
6: Access and Accuracy
6.1: Data Access
- Processes to access or review user data are available.
- Unclear whether 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.
- Unclear whether the school, parents, or students can modify inaccurate student information.
- 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
- Unclear whether this product deletes data 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
- 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 in the event of a merge, acquisition, or bankruptcy.
- 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: 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
- 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 shared for social interactions.
9.2: Data Visibility
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
9.3: Monitor and Review
- Unclear whether 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.
- 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 company provides links to resources that support safe and appropriate social interactions.
10: Advertising
10.1: Company 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.
- User'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.
- 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
- Company does not 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: Compliance
11.1: Children Under 13
- Company does not 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 not 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.
- 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.
- 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 indicated.
- A user is 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 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.
- Unclear whether the company has indicated it is a Data Controller or Data Processor.