Overview
The educational version of VoiceThread, called Ed.VoiceThread, provides a Terms of Service and Privacy Policy for the grade-school community, and not for higher education, personal, and business communities. Ed.VoiceThread allows users to publish and share media online and add comments. An individual does not need to be registered with the service in order to search or view public media on Ed.VoiceThread. However, an individual must be a registered member of Ed.VoiceThread to post or add comments. In addition, teachers are encouraged to check within their school or district for any data use agreements in place that extend the publicly available terms of Ed.VoiceThread. Teachers and students are also encouraged to review and understand any applicable visibility settings to ensure they understand who can see the content they create.
Ed.VoiceThread 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 Use used for this evaluation can be found on Ed.VoiceThread ’s website, iOS App Store, and the Google Play Store. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms of VoiceThread state they support different visibility settings. However, the terms are not specific on the mechanics of the settings, but schools and teachers are encouraged to review the settings to ensure that visibility of data to others is set in a way that addresses community norms. In addition, the policies do not contain details on how social interactions could be monitored for inappropriate content, or how a user could report unwanted harassment. While these features may exist within the application, the terms do not provide details on how to access them.
Privacy
The terms of VoiceThread state they collect a student's name, email address, photos, videos, audio recordings, online activity, persistent identifiers, and information that is linked or linkable to a student. VoiceThread shares non-personally-identifiable information (such as anonymous User usage data, referring pages, exit pages, URLs, platform types, number of clicks, etc.) with third parties to assist them in understanding the usage patterns for certain content, services, and functionality on the Website. Also, VoiceThread may provide personally identifiable information to employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on its behalf. Lastly, the terms state VoiceThread will never sell personal information or use student data for behavioral advertising, tracking, or marketing purposes.
Security
The terms state educators and administrators have access to a broad suite of tools to control the methods by which students use the Service, enabling policies concerning student publishing and student sharing to made by educators and administrators at each school or district. VoiceThread's terms state they work hard to protect their community of users, and they maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information.
The terms state VoiceThread will continually develop and implement features to keep users' personal information safe - for example, when they enter any information anywhere on the Service, VoiceThread encrypts the transmission of that information using secure socket layer technology (SSL) by default. In addition the terms specify they ensure passwords are stored and transferred securely using encryption and salted hashing and provide notification in the event of a data breach.
Compliance
The terms of VoiceThread state users under 18 years of age cannot register for the Service, but rather a grade-school educator or administrator must register students. The terms specify that student education records are created and protected under FERPA, and teachers or administrators can access, review, modify, or delete student data. Teachers should be aware they are responsible for obtaining verifiable parental consent for use of the Service by students.
Ed.voicethread.com is the part of the Service dedicated for use with grade-school students and educators. It has policies in place to ensure that students have as safe and nurturing a learning environment as possible. The terms state these policies are unique to Ed.VoiceThread, and taken as a whole, provide the transparency and accountability that are the underpinning of all safe and nurturing grade-school learning communities. Because the educational version of VoiceThread is often purchased at the district, agency, or state level, it is possible that an additional data use agreement is in place that would address these compliance issues. Teachers should ask for confirmation of any additional data use agreements.
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 | 87 | 66 |
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 | 75 | 50 |
| Data Sharing: Protecting data from third parties | 100 | 90 |
| Data Security: Protecting against unauthorized access | 100 | 70 |
| Data Rights: Controlling data use | 63 | 85 |
| Data Sold: Preventing sale of data | 75 | 80 |
| Data Safety: Promoting responsible use | 50 | 55 |
| Ads & Tracking: Prohibiting the exploitation of users' decision making process | 100 | 60 |
| Parental Consent: Protecting children’s personal information | 100 | 70 |
| School Purpose: Following student data privacy laws | 100 | 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) | 75 | 65 |
| Children's Online Privacy Protection Act (COPPA) | 83 | 69 |
| Family Educational Rights and Privacy Act (FERPA) | 94 | 63 |
| Student Online Personal Information Protection Act (SOPIPA) | 96 | 74 |
| General Data Protection Regulation (GDPR) | 89 | 76 |
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 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
- Intended for children under 13.
- Unclear whether intended for teens.
- 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 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 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
- 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
- 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
- Unclear whether 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
- 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
- Social or federated login is supported.
- Personal information from social or federated login providers is collected.
- 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 placed on third-party data use.
- Unclear whether 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 treated 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
- Opt-in consent is requested from users at the time personal information is collected.
5.3: Remedy Process
- A grievance or remedy mechanism is not 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.
- 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.
- 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
- Unclear whether this product provides processes to access and review user data.
- 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.
- 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
- 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.
- 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.
- Unclear whether 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 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.
- 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 displayed publicly.
- Users can control how their data are displayed.
9.3: Monitor and Review
- User-created content is not 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 not moderated.
- Unclear whether social interactions of users are logged.
9.4: Report Content
- Users can filter or block inappropriate content.
- Unclear whether 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
- Unclear whether this 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
- Vendor does not respond 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.
- 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.
- Unclear whether this product designates the vendor as a school official.
11.3: Parental Consent
- Parental consent is required.
- Unclear whether this product limits parental consent 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.
- 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.
- 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.
- 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
- A user's data are subject to International data transfer or jurisdiction laws, such as the GDPR.
- The vendor has indicated it is a Data Controller or Data Processor.