Overview
Turnitin provides instructors with the tools to engage students in the writing process, provide personalized feedback, and assess student progress over time. Turnitin merges originality checking, online grading, and peer review into a single service. Turnitin's policy notes that it may (but is not obligated to) monitor areas of the site for user communications, such as chat rooms, bulletin boards, and other user forums. Turnitin explains that it does partner with a third party to manage its advertising on other sites, and that its third-party partner may use technologies such as cookies to gather information about user activities on this site in order to provide targeted advertising based upon the user's browsing activities and interests. On a positive note, Turnitin's policy claims that it complies with the relevant security standards of the US, EU and Switzerland. Lastly, Turnitin's policy states COPPA’s requirements do not apply to its services and therefore it is not required to get prior verifiable parental consent before collecting or maintaining personal data.
Turnitin can be accessed through its website, and is available for download at the iOS App Store. The Privacy Policy and Terms of Use used for this evaluation can be found on Turnitin’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
Turnitin's policy indicates that it includes social media features, such as the Facebook “Like” button, the “Share This” widget, or interactive mini-programs that run on its site. Publicly visible personal information is possible, as Turnitin reserves the right to reproduce, transmit, display, disclose, and otherwise use user communications on the site or elsewhere for its business purposes. The company states that it retains the right to remove, at its discretion, communications that include any material deemed abusive, defamatory, obscene, or otherwise inappropriate. Turnitin's policy notes that it may (but is not obligated to) monitor areas of the site for user communications, such as chat rooms, bulletin boards, and other user forums.
Privacy
Turnitin notifies users that among the information processed is personal data such as name, email address, job title, and school. Its policy explains that Turnitin and its partners may use cookies or similar technologies to analyze trends, administer the site, track users’ movements around the site, and gather demographic information about the user base as a whole. Turtitin's policy states that if at any point they decide to use personal data in a manner different from that stated at the time it was collected, they will notify you via e-mail, and then the user will have a choice as to whether or not we use their information in this different manner. Turnitin states that it does not sell user personal data to third parties and they do not serve ads on the site. However, Turnitin explains that it does partner with a third party to manage its advertising on other sites, and that its third-party partner may use technologies such as cookies to gather information about user activities on this site in order to provide targeted advertising based upon the user's browsing activities and interests.
Security
Turnitin's policy claims that it complies with the relevant security standards of the US, EU and Switzerland. The program requires users to log into an account using a username and password for security purposes. Turnitin's policy states that if they transfer personal data to a third party, they will require that the third party agree to confidentiality requirements, and applicable legal requirements. The policy doesn't specifically address transit encryption, but says that data is stored in the EU or USA with robust physical, digital, and procedural safeguards in place to protect users' personal data, including the use of SSL encryption, redundant servers and data centers, and sophisticated perimeter security. Turnitin's policy also claims that its data breach notification policy is GDPR compliant.
Compliance
Turnitin's policy notes that parental consent or the consent of a guardian is required for a minor to set up an account with Turnitin, and that COPPA does not apply to its product because COPPA’s requirements do not apply to sites that contract with schools to offer online programs for the benefit of the schools and their students, and collect personal data only for these purposes. Therefore, Turnitin states that its services are not required to get prior verifiable parental consent before collecting or maintaining personal data.
Turnitin explains that at any time, a user can access, update, rectify or erase any personal data by logging into the user's account and clicking “User Info” or contacting Customer Support. According to its policy, universities are free to inspect or audit Turnitin's services any time. Lastly, Turnitin's terms state they are obligated under FERPA to remain under the direct control of the education institution with respect to their use and maintenance of student data that is part of a student's education record.
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 | 68 | 57 |
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 | 40 |
| Data Sharing: Protecting data from third parties | 100 | 70 |
| Data Security: Protecting against unauthorized access | 100 | 75 |
| Data Rights: Controlling rights to data | 63 | 65 |
| Data Sold: Preventing sale of data | 50 | 35 |
| Data Safety: Promoting responsible use | 50 | 40 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 36 | 40 |
| Parental Consent: Protecting children’s personal information | 100 | 35 |
| School Purpose: Following student data privacy laws | 100 | 75 |
| Individual Control: Controlling data use | NA | 85 |
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) | 79 | 75 |
| Children's Online Privacy Protection Act (COPPA) | 60 | 49 |
| Family Educational Rights and Privacy Act (FERPA) | 75 | 58 |
| Student Online Personal Information Protection Act (SOPIPA) | 50 | 44 |
| General Data Protection Regulation (GDPR) | 87 | 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
- Intended for children under 13.
- 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.
- 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 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
- Personal information about users is obtained 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
- 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
- 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
- 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 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
- Unclear whether this product supports third-party login.
- Unclear whether personal information from third-party login providers is collected.
- Unclear whether personal Information is shared with third-party login providers.
3.15: De-identified or Anonymized Data
- Unclear whether 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.
- 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
- 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
- Unclear whether 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
- 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.
- Unclear whether a user's data are deleted upon account cancellation or termination.
- Processes to delete user data are available.
- Unclear whether authorzied users can delete data.
- Unclear whether 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
- Unclear whether 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
- 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 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
- All data are stored in an encrypted format.
- Unclear 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.
- Unclear whether 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 cannot 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.
- User-created content is not 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 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
- Unclear whether this product displays personalised advertising.
10.4: Ad Tracking
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are 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
- Unclear whether this 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 cannot opt out or unsubscribe from marketing communications.
10.8: Do Not Track
- Company does 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
- Unclear whether company has actual knowledge that personal information from users under 13 years of age is collected.
- The company does not provide a section, heading, or separate policy for children in their policies.
- Unclear whether this product restricts or prohibits account creation 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.
- Unclear whether 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.
- Unclear whether this product deletes children's personal information 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.
- 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
- 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.