Privacy Evaluation for Global Grid for Learning
80%
Overview
Global Grid for Learning provides a cloud-based identity, access management, marketplace, and data analytics platform designed for educational institutions. Global Grid's terms do not say whether they provide social interactions between students and adults, or whether a user's information may be publicly visible. Global Grid's terms say they collect personally identifiable information and non-personal information automatically. Global Grid's terms also say they use strict administrative and technical procedures to keep data safe and secure. In addition, Global Grid’s terms say they do not knowingly collect any information from children under the age of 13 years of age, unless the school or district has obtained appropriate parental consent. Lastly, Global Grid's policy says it is the responsibility of the school or district to obtain consent from parents or guardians of children protected under COPPA.
Global Grid for Learning can be accessed through its website. The Privacy Policy accessed for this evaluation can be found on EduTone’s website. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
The terms of Global Grid say that any publicly shared comments or ratings on our Service(s) may remain in view to other subscribers after an account deletion, but that but nobody will be able to see the identity of a deleted account holder.
Privacy
The terms of Global Grid sat they collect personally identifiable information and non-personal automatically collected information. Global Grid's terms state they will not sell, rent, or use student information to target students or their families for advertising or marketing purposes, or allow third party advertising networks to collect any information about the users of the services. Global Grid's terms say they do not disclose any personal information relating to students, parents, or school officials to third parties without opt-in consent. Lastly, Global Grid's terms say they contractually obligate third-party service providers to keep student PII confidential and to only use it in order to fulfill their responsibilities.
Security
The terms of Global Grid say they use strict administrative and technical procedures to keep data safe and secure. The terms also say that they maintain strict administrative, technical and physical procedures to protect information stored in their servers. The terms say access to information is limited to those employees who require it to perform their job functions. In addition, Global Grid's terms say that the vendor conducts thorough background checks for employees, as well as conducting comprehensive activity audits and ensuring that their work is entirely separate from the rest of our team.
Moreover, the terms describe multiple measures that Global Grid has implemented measures designed to secure PII from accidental loss and from unauthorized access, use, alteration and disclosure. All PII is securely stored behind firewalls in a private cloud environment, and all environments are equipped with intrusion detection systems. The terms state that PII is encrypted at rest and in transit to and from the service using industry-standard encryption technology. Lastly, Global Grid's terms state they follow the Department of Education's recommendations to only store information in jurisdictions specific to their users.
Compliance
Global Grid’s terms say they do not knowingly collect any information from children under the age of 13, unless the School has obtained appropriate parental consent. The terms say under FERPA, Global Grid requires access to certain student Information or educational records to remain the legal responsibility of the applicable school. Global Grid's terms also say they will only use personally identifiable information from student education records to enable school officials and parents access and use the services provided by Global Grid. Before a school can upload, access or share any data concerning a student with a third party, the school must confirm that they have obtained verifiable parental consent from the parent or guardian of that student, or determined a limited exception under FERPA.
Rating
- Personal information is not sold or rented to third parties.
- Personal information is not shared for third-party marketing.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- User'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.
Data Collection
SCORE: 50%
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is limited to product requirements.
- Geolocation data are collected.
- 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.
- Opt-in consent is requested from users at the time personal information is collected.
- Unclear whether personal information of users is collected by a third party.
Data Sharing
SCORE: 65%
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- Unclear whether the categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 80%
How does it secure data?
- Unclear whether a user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 80%
What rights do I have to the data?
- Unclear whether users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Unclear whether methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 25%
Is the data sold?
- Personal information is not sold or rented to third parties.
- Unclear whether users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Unclear whether users are notified if their information is transferred to a third party.
- Unclear whether user information can be deleted prior to its transfer to a third party.
- Third-party transfer is contractually required to use the same privacy practices.
- 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.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 0%
How safe is this product?
- Unclear whether this product supports interactions between trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Unclear whether profile information must be shared for social interactions.
- Unclear whether personal information can be displayed publicly.
- Unclear whether this product allows users to control how their data are displayed to others.
- Unclear whether 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.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 70%
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Traditional or contextual advertisements are not displayed.
- Personalised advertising is not displayed.
- Data are not collected by third-parties for their own purposes.
- User'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.
- Unclear whether this company can send marketing messages.
- Unclear whether this company provides promotional sweepstakes, contests, or surveys.
- 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.
Parental Consent
SCORE: 55%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Unclear whether intended for parents or guardians.
- Company does not have 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.
- 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.
School Purpose
SCORE: 75%
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- 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.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 60%
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is available for users to file a complaint.
- 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.
Common Sense Standard Privacy Report (SPR)
The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.
About Privacy Evaluations
The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.
Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.