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. The Privacy Policy and Terms and Conditions accessed for this evaluation can be found on Gaggle’s website. Additionally, other policies used for this evaluation include: Student & Staff Data Privacy Notice.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.
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 fail over 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 Score | Full Score | |
|---|---|---|
| Comprehensive Assessment | 91 | 74 |
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 | 75 |
| Data Sharing: Protecting data from third parties | 100 | 75 |
| Data Security: Protecting against unauthorized access | 100 | 90 |
| Data Rights: Controlling rights to data | 88 | 95 |
| Data Sold: Preventing sale of data | 75 | 95 |
| Data Safety: Promoting responsible use | 100 | 95 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 100 | 90 |
| Parental Consent: Protecting children’s personal information | 100 | 85 |
| School Purpose: Following student data privacy laws | 100 | 88 |
| Individual Control: Controlling data use | NA | 40 |
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) | 93 | 75 |
| Children's Online Privacy Protection Act (COPPA) | 90 | 86 |
| Family Educational Rights and Privacy Act (FERPA) | 81 | 83 |
| Student Online Personal Information Protection Act (SOPIPA) | 96 | 87 |
| General Data Protection Regulation (GDPR) | 90 | 80 |
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
- Unclear whether 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: 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
- Intended for children under 13.
- Unclear whether 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 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
- 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 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
- 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.
- Unclear what the roles of third-party service providers are.
3.11: Third-Party Affiliates
- Unclear whether 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
- Company will not 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 not supported.
- Personal information from third-party login providers is not 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.
- 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
- 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
- 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
- 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.
- 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.
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.
- 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.
- 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: Security
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.
- Unclear whether 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 cannot 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: Advertising
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
- Unclear whether 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.
10.7: Unsubscribe
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised 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 company provides a method for users to opt-out from third-party tracking.
11: Compliance
11.1: Children Under 13
- Unclear whether company has 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 transferred to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing the policies 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 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
- Unclear whether 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.