Overview
i-Ready is an online assessment and instruction tool that helps teachers provide all students a path to proficiency and growth in reading and mathematics. The terms say that student information is not visible publicly, and is only accessible to authorized teachers, administrators, and parents. The terms also say that the service collects student information directly from the school districts, including sensitive information such as ethnicity and free-lunch status. In addition, the terms say student information will not be sold, nor will identifiable student information be shared with third parties, and no advertising is displayed in i-Ready. The terms say that reasonable security is used, data in transit and at rest is encrypted, and users will be notified in the case of a data breach. The terms say that children under 13 are not allowed to register for an account, and if any information is collected from a child without verifiable parental consent, it will be deleted. Authorized users can access, correct, or delete personal information at any time through the service.
iReady can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on iReady’s website. Additionally, other policies used for this evaluation include: Your Rights under the California Consumer Privacy Act. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
i-Ready is an online assessment and instruction tool that helps teachers provide all students a path to proficiency and growth in reading and mathematics. The terms say that student information is not visible publicly, and is only accessible to authorized teachers, administrators, and parents. The terms also say that the service collects student information directly from the school districts, including sensitive information such as ethnicity and free-lunch status. In addition, the terms say student information will not be sold, nor will identifiable student information be shared with third parties, and no advertising is displayed in i-Ready. The terms say that reasonable security is used, data in transit and at rest is encrypted, and users will be notified in the case of a data breach. The terms say that children under 13 are not allowed to register for an account, and if any information is collected from a child without verifiable parental consent, it will be deleted. Authorized users can access, correct, or delete personal information at any time through the service.
iReady can be accessed through its website. The Privacy Policy and Terms of Use accessed for this evaluation can be found on iReady’s website. Additionally, other policies used for this evaluation include: Your Rights under the California Consumer Privacy Act. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms state that student information is not visible publicly, and is only accessible to authorized teachers, administrators, and parents. The terms state that there are no user interactions between users, and there is no ability for users to upload user content created outside of i-Ready. In addition, other than responses to questions or instructional prompts, students cannot create content within i-Ready and user information does not involve the creation of a profile.
Privacy
The terms state that i-Ready collects student information directly from school districts, including: student name, birth date, gender, ethnicity or race, school enrollment, grade level, teacher, English language learner status, and eligibility for free- or reduced-price lunch. User behavioral and usage data is also collected. The service has taken the Student Privacy Pledge, and the terms disclose student information is not sold, behaviorally targeted advertising is not used, and collected information is used only for authorized purposes, with student data only used for education-related purposes.
The terms also state the service may share personal information with third-party service providers to support their business, and also share de-identified data for research purposes, but they will not share identifiable student data with third parties. In addition, the terms say no student data collected in connection with i-Ready is shared with third parties for any advertising, marketing, or tracking purposes.
Security
The terms state that accounts with passwords are required for use of the website. Reasonable security is taken with personal information, and data—both in transit and at rest—is encrypted. The service puts limits on employee access to personal data, none of which is stored outside the control of the vendor. In the event of a data breach, impacted users will be notified and the data that has been compromised will be specified, if known. In addition, the terms state schools are responsible for notifying teachers and parents of any breach, but the vendor will provide reasonable help if requested, along with reimbursing schools for reasonable expenses for providing these notices. Lastly, the terms say an annual security audit is completed by a third party, and the vendor implements recommended security changes, if practical.
Compliance
The terms are not clear regarding use of the product by children under 13. However, children may not register for an account or provide any information directly to the vendor, but the terms also specifically discuss students using the product. The terms state that the service does not knowingly collect personal information from children under 13 and will delete it if it is found to have been collected without verifiable parental consent, but parental consent methods are not clear. The terms clearly state that personal information about students is collected directly from school or districts and not from students themselves, and users are not to upload any material that could be considered an education record.
In addition, the terms say authorized individuals are able to access, correct, or delete personal information that they have provided, but no specific time period is given for how long the vendor has to make changes or deletions. The terms state that to delete a user's personal information, their user account will also be deleted. The service has taken the Student Privacy Pledge and the terms state they will not sell student information or engage in any behaviorally targeted advertising.
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 | 84 | 58 |
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 | 25 | 45 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 100 | 90 |
| Data Rights: Controlling rights to data | 88 | 75 |
| Data Sold: Preventing sale of data | 75 | 60 |
| Data Safety: Promoting responsible use | 50 | 60 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 100 | 65 |
| Parental Consent: Protecting children’s personal information | 67 | 60 |
| School Purpose: Following student data privacy laws | 100 | 65 |
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) | 92 | 69 |
| Children's Online Privacy Protection Act (COPPA) | 78 | 64 |
| Family Educational Rights and Privacy Act (FERPA) | 83 | 71 |
| Student Online Personal Information Protection Act (SOPIPA) | 96 | 76 |
| General Data Protection Regulation (GDPR) | 89 | 63 |
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
- 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: Policy Contact
- Users can 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.
- 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.
- Geolocation data are not collected.
- Unclear whether this product collects biometric or health data.
- Behavioral data are collected.
- Sensitive data are collected.
- Non-personally identifiable information is collected.
- 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.
- 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.
- Data are shared for analytics.
- 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
- Specific categories of information 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
- 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
- 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.
- 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
- 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.
- Personal information from social or federated login providers is not collected.
- Personal Information is not 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 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
- Combined information is not treated 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
- Users can create or upload content.
5.2: User Consent
- Unclear whether 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 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.
- Notice is not 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
- 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.
- The time period for the vendor to modify inaccurate data is indicated.
6.4: Data Retention
- A data-retention policy is available.
- 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.
- 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.
- Unclear whether notice is 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
- Unclear whether third-party transfers are 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.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
8.3: Third-Party Security
- 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 cannot interact with trusted users and/or students.
- Users cannot interact with untrusted users, including strangers and/or adults.
- Profile information is not shared for social interactions.
9.2: Data Visibility
- Personal information is not displayed 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.
- 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
- 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.
- 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
- Vendor does 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.
- Unclear whether this product provides notification of a contract or additional rights.
- 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.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Directory information is not disclosed.
- Unclear whether this product transfers parental consent obligations to the school or district.
11.4: Legal Requirements
- The legal jurisdiction that applies to the laws governing any dispute is not 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.