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Overview

Gaggle safety and tracking software combines machine learning technology with safety representatives who review student content. Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Lastly, Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA).

Gaggle 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 Service accessed for this evaluation can be found on Gaggle’s website, iOS App Store, and the Google Play Store. Additionally, other policies used for this evaluation include: Student & Staff Data Privacy Notice, and a Gaggle Service Level Agreement. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. However, because Gaggle has unrestricted and unlimited access to all students' private or sensitive information within a classroom or all students within an entire school, there exist inherent safety and privacy concerns. Administrator accounts for this service should be managed with extreme caution, and students should be aware of the types of content that could appear "suspicious". In addition, the terms state that in order to protect schools or districts against the risks involved in handling child pornography, Gaggle registers incidents containing pornographic videos and images with the appropriate law enforcement authorities.

Privacy

Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. In addition, Gaggle's terms state that it will not sell student or school staff information, and will not share or reuse Personally Identifiable Information from education records for any purpose, unless instructed to do so by the School or District. Gaggle's terms state they do not behaviorally target advertising or show advertising to any user, and does not use student information to target students or their families for advertising or marketing efforts.

Although Gaggle may permit educators and parents to access Gaggle's Service through links provided on the Company Site, visitors should be aware Gaggle's Company Site and Service solutions are governed by two separate policies. The Company Site may work with third parties when visitors use the Company Site, but Gaggle does not control these third parties’ marketing or tracking technologies or how they may be used to track visitors on other third-party websites or services.

Lastly, Gaggle's terms state they may use de-identified information to improve its products and services, and use reasonable de-identification approaches to ensure they are not compromising the privacy or security of the personal information a user entrusts to Gaggle. In addition, Gaggle's terms state they will not attempt to re-identify de-identified data and will not transfer de-identified data to any third party unless they agree not to attempt re-identification.

Security

Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Gaggle's terms state they ensure personal information is encrypted in transit to and from Gaggle using SSL technology, and all personal information is stored in multiple databases with extensive redundancy and failover while maintained at data centers located in two geographically dispersed states.

In addition, the terms specify that Gaggle implements strict restrictions on how data may be accessed, and by whom, and that audit logs are kept to be able to track data modification. Additional security measures are in place to prevent and identify data tampering. In the case of a data breach, Gaggle's terms state they will immediately notify all customers affected using the primary email address specified in their accounts. Lastly, Gaggle's terms state it is the responsibility of all schools to contact parents or legal guardians in the event of a data breach.

Compliance

Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA). Individual children are not allowed to sign up for any Gaggle product and the only way a child may obtain access to a Gaggle product is through their school. In addition, the terms state each school is responsible for creating student accounts for any Gaggle product and they may choose to provide a student's full name, grade level, and ID number.

Gaggle's terms specify it considers all school and district data to be confidential and does not use student data for any purpose other than to provide services. Gaggle's terms reiterate that Student data are the property of the school or district and remain in the school or district’s control throughout the duration of any agreement or contract, and access to student information remains the legal responsibility of the applicable school.

The terms state that before a teacher or school enters, uploads, or access any data concerning a minor student, they must confirm that they have obtained appropriate consent from the parent or guardian of that student, or determined that one of the limited exceptions to the consent requirement applies. Gaggle's terms state they will not distribute to third parties any staff or student data without the consent of either a parent/guardian or a qualified educational institution.

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 Assessment7856

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 information2535
Data Sharing: Protecting data from third parties6360
Data Security: Protecting against unauthorized access10080
Data Rights: Controlling data use7570
Data Sold: Preventing sale of data7575
Data Safety: Promoting responsible use5030
Ads & Tracking: Prohibiting the exploitation of users' decision making process10075
Parental Consent: Protecting children’s personal information6760
School Purpose: Following student data privacy laws10080

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)9265
Children's Online Privacy Protection Act (COPPA)7662
Family Educational Rights and Privacy Act (FERPA)7861
Student Online Personal Information Protection Act (SOPIPA)9269
General Data Protection Regulation (GDPR)8663

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 not 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
  • Not 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.
  • 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.
  • Personal information from children under 13 years of age is not collected online.
2.3: Data Exclusion
  • Unclear whether specific types of personal information are not collected.
  • 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.
  • Unclear whether data are shared for research and/or product improvement.
  • Data are not shared for third-party advertising and/or 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
  • Data are not 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
  • 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 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
  • 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
  • Unclear whether this product supports social or federated login.
  • 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
  • User information is shared in an anonymous or deidentified format.
  • The vendor describes their deidentification process of user information.
3.16: Third-Party Contractual Obligations
  • Contractual limits are not placed on third-party data use.
  • 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
  • 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
  • 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
  • Unclear whether 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.
  • 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.
  • Unclear whether 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
  • The vendor does maintain 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.
  • 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.
  • Parental controls or managed accounts are available.
  • 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
  • Notice is provided in the event of a data breach.
8.8: Data Oversight
  • Data-privacy and security-compliance audits are performed.

9: Responsible Use

9.1: Social Interactions
  • Users can interact with trusted users and/or students.
  • Unclear whether users can interact with untrusted users, including strangers and/or adults.
  • Unclear whether profile information is shared for social interactions.
9.2: Data Visibility
  • Unclear whether this product displays personal information publicly.
  • Unclear whether this product allows users to control how their data are displayed.
9.3: Monitor and Review
  • 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.
  • 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
  • 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
  • Traditional or contextual advertisements are not displayed.
10.3: Behavioral Advertising
  • Behavioral or targeted advertising is not displayed.
10.4: Ad Tracking
  • Data are not collected by third-party advertising or tracking services.
  • Data are not used to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for data enhancement, and/or targeted advertisements.
10.5: Filtered Advertising
  • Unclear whether children may receive inappropriate advertisements.
10.6: Marketing Communications
  • The 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.
  • 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 vendor provides a method for users to opt-out from third-party tracking.

11: Compliance

11.1: Children Under 13
  • Vendor does not have actual knowledge that personal information from users under 13 years of age is collected.
  • Children's privacy is applicable.
  • Account creation is restricted 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.
  • Product does create education records.
  • Notification of a contract or additional rights is provided.
  • Vendor is designated 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.
  • Children's personal information is deleted if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
  • 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.
  • FERPA parental consent exceptions are indicated.
  • 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.
  • 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.