Overview
Seesaw provides student driven digital portfolios and simple parent communication. In Seesaw, interactions are originated by and largely mediated through the teacher. This hierarchy provides a relative degree of control over who can work in the website, and who can view student work in the website. Parent accounts can be created in the website, and parent access is restricted to their own child's work. Parents have the ability to share their child's work via social media, and the policy warns about sharing by screenshots.
Seesaw's policies indicate that PII is collected from users under the age of 13 and that parental consent is obtained through the teacher / school. Policies state that no form of advertising is used on the site and that third-party vendors are used for the operations of the website (no data is rented or sold). Social login is provided via Google and some PII is collected from those services. Teachers can share Activity Journals and tag various students in them. These journals can be made public but student information may be kept private. Policies state that publicly available Journals may contain PII on the teacher from an Author Profile; the teacher has limited control over what information is made publicly visible. Policies do not indicate if Seesaw monitors, moderates, audits/reviews, logs, filters or blocks content, nor if there are polices for reporting abusive behavior.
Seesaw can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and Amazon Appstore. The Privacy Policy and Terms of Use accessed for this evaluation can be found on Seesaw’s website, iOS App Store, the Google Play Store, and Amazon Appstore. Additionally, other policies used for this evaluation include the Copyright & Intellectual Property Policy. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Policies state that “Seesaw is designed for safe sharing”. Teachers can share journals and parents can make them publicly visible / share on social media. Students can also comment on others work but only teachers can share journals (without student information). The terms reference that teachers can make Activity Journals visible but must make their Author Profile visible; including their name, profile picture and other activities posted along with other PII the teacher may choose to share. Policies do not indicate if Seesaw monitors, moderates, audits/reviews, logs, filters or blocks content, nor if there are polices for reporting abusive behavior.
Privacy
Policies state that PII is collected of users, automatic tracking (via cookies and analytics services) are used, but no sensitive data is indicated to be collected. The terms reference that some PII is shared with third parties for the operation of the services but data is not sold or rented to third parties and they are contractually limited in their usage of data; information on deletion of data if requested is provided. Policies clearly state that no forms of advertising are used on the site. Policies indicate that users are notified of material changes to the policies via email and that continued use indicates acceptance. Policies do not contain information on how combined PII is treated or if users are provided notice for changes to how data is collected (or if consent is obtained for changes). Policies include contact information for questions regarding policy changes. Federated social login (Google) is supported and information is automatically collected. Policies do not indicate if Seesaw shares information with social login providers. Policies do not contain information on de-identified or re-identified information. Policies do not contain information on Do Not Track requests. Terms do make reference to sending marketing emails for Seesaw products to users (teachers)and indicate there is an opt-out option. No information is provided in the terms of deletion request prior to transfer or sale of Seesaw.
Security
According to the policy, authorized users can manage information on students; teachers and parents can also modify, delete or download PII collected by Seesaw. Policies state that PII is used to verify user identity and that PII may be transferred to a different internal account, with authorization from the school. Policies do not clearly state if an account is required to use the product nor if two-factor authentication is required. Policies do indicate that reasonable security measures are in place including data encryption in transit, at rest, and access controlled data centers. In the case of breach, users are notified.
Compliance
Policies indicate that PII is collected on users, the product is intended for students in K-12 and PII is collected on users under the age of 13, including information from education records. Terms indicate that consent is collected by the school and links are provided on methods of obtaining parental consent; also that students under 13 cannot create an account themselves. Policies state what information is collected on users under 13 but not how it is used and disclosed. Seesaw allows for users to upload content and policies indicate that ownership of content remains with the user, with a limited license being granted to Seesaw for use within the context of the Seesaw service. Policies do indicate that users can modify or correct information in their account. Policies also clearly outline processes for deleting accounts. Policies also state timeframes for deleting abandoned accounts and processes to delete active accounts. There is an indication in the policies that Seesaw will delete data no longer required, and that notice will be given first. Policies state that data privacy and security practices are routinely third party audited. Terms reference education records entered into Seesaw by school / teacher but do not specify content. The policy does make reference that content uploaded by student or teacher may be considered as part of the students education record and that Seesaw is designated as a “School Official” under FERPA.
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 | 71 |
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 | 83 | 55 |
Data Sharing: Protecting data from third parties | 100 | 90 |
Data Security: Protecting against unauthorized access | 67 | 65 |
Data Rights: Controlling rights to data | 88 | 95 |
Data Sold: Preventing sale of data | 75 | 70 |
Data Safety: Promoting responsible use | 67 | 55 |
Ads & Tracking: Prohibiting the exploitation of users' decision making process | 86 | 80 |
Parental Consent: Protecting children’s personal information | 100 | 65 |
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) | 93 | 75 |
Children's Online Privacy Protection Act (COPPA) | 86 | 69 |
Family Educational Rights and Privacy Act (FERPA) | 94 | 77 |
Student Online Personal Information Protection Act (SOPIPA) | 92 | 73 |
General Data Protection Regulation (GDPR) | 90 | 75 |
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 available in multiple languages.
1.8: Intended Use
- 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.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Interactions, behaviors, or usage analytics data are collected.
- 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.
- Unclear whether specific types of collected information are excluded from the privacy policy.
2.4: Data Limitation
- 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
- 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 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 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.
- 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
- 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 not shared with third-party login providers.
3.15: De-identified or Anonymized Data
- User information that is shared is not 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.
- Unclear whether 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
- 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.
- Users can request to know what personal information has been shared with third parties.
- 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.
- 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
- Unclear whether 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.
- 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
- 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.
- Unclear whether 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 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 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
- All data in transit are encrypted.
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 can 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
- 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.
- Unclear whether social interactions between users are moderated.
- 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 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 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
- Ads displayed to children are filtered for inappropriate content.
10.6: Marketing Communications
- The company can send marketing messages.
- Unclear whether this company provides 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
- 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.
- 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 not 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.
- The company has indicated it is a Data Controller or Data Processor.